Official Ticket Verification as Prima Facie Proof of Bona Fide Travel under Section 124-A: Supreme Court’s Burden-Shifting Clarification in Rajni v. Union of India

Introduction

The Supreme Court of India in Rajni v. Union of India (2025 INSC 1201) has issued a significant ruling under the Railway Claims framework, sharpening the evidentiary contours of compensation claims arising from “untoward incidents” under Section 124-A of the Railways Act, 1989. The case arises from the death of late Sanjesh Kumar Yagnik, who allegedly fell from the Ranthambore Express while travelling from Indore to Ujjain on 19.05.2017 due to overcrowding. His widow and minor son sought compensation under the no-fault regime of Section 124-A, but the Railway Claims Tribunal (RCT), and subsequently the Madhya Pradesh High Court, rejected the claim primarily on the ground that the deceased was not proved to be a bona fide passenger, as no ticket was recovered from his person.

Before the Supreme Court, the central questions were:

What is the evidentiary threshold to establish that a victim of an “untoward incident” was a “passenger” within the meaning of Explanation (ii) to Section 124-A?
Does the absence of a seized physical ticket or non-examination of the investigating officer defeat the claim?
When and how does the burden of proof shift to the Railways to rebut a claimant’s case?

The Court, per Aravind Kumar, J. (with N.V. Anjaria, J. concurring), reversed the concurrent findings below and laid down a clear burden-shifting rule: official railway verification of ticket issuance for the pertinent date and route constitutes prima facie proof of bona fide travel, shifting the evidentiary burden to the Railways. The Court also cautioned against importing criminal-trial standards into welfare proceedings, emphasizing a preponderance-of-probabilities approach.

Summary of the Judgment

The Supreme Court set aside the orders of the Railway Claims Tribunal (16.01.2023) and the Madhya Pradesh High Court (15.05.2024), which had dismissed the claim for want of proof that the deceased was a bona fide passenger.
While the High Court had accepted that the death resulted from an “untoward incident” under Section 123(c)(2), it denied compensation due to non-recovery of a ticket and perceived evidentiary gaps. The Supreme Court disagreed, holding that such a hyper-technical approach is inconsistent with the welfare nature of the statute.
Relying on the widow’s affidavit and—critically—the Divisional Railway Manager’s (DRM) report verifying that a valid ticket (No. L10274210) from Indore to Ujjain was issued on the date of the incident and certified by the Chief Booking Supervisor, the Court held that the claimants discharged their initial burden.
The Court declared that where official railway inquiry or records verify the issuance of a pertinent ticket, such verification is prima facie proof of bona fide travel, shifting the burden to the Railways. Absence of a seizure memo or non-examination of the investigating officer, by itself, cannot defeat the claim.
Compensation of Rs. 8,00,000 was awarded to the appellants, payable within 8 weeks, failing which interest at 6% per annum from the date of the Supreme Court’s order would apply.

Detailed Analysis

1. Precedents Cited and Their Influence

Union Of India v. Rina Devi, (2019) 3 SCC 572:
This landmark decision established that compensation under Sections 124/124-A is payable on a strict/no-fault basis, subject only to the narrow exceptions in the proviso to Section 124-A. Importantly, it articulated a pragmatic evidentiary rule: mere non-recovery of a ticket does not automatically defeat a claim if the claimant lays a credible prima facie foundation, whereafter the burden shifts to the Railways. The Court in Rajni explicitly adopts and applies this burden-shifting framework.
Doli Rani Saha v. Union of India, (2024) 9 SCC 656:
Building on Rina Devi, the Supreme Court reiterated that a claimant can discharge the initial burden through an affidavit of relevant facts and reliance on materials emanating from official investigations. Once done, the onus shifts to the Railways. Rajni follows Doli Rani Saha in treating the claimant’s affidavit and official verification as adequate to trigger burden-shifting.
Kamukayi and Others v. Union of India and Others, (2023) 19 SCC 116:
This decision reaffirmed Rina Devi’s principles and contextualized the meaning of “passenger” via Explanation (ii) to Section 124-A—encompassing anyone who has purchased a valid travel or platform ticket and becomes a victim of an untoward incident. Rajni draws upon Kamukayi’s synthesis to hold that official ticket verification satisfies the statutory definition and supports the presumption of bona fide travel.
Related High Court and Supreme Court authorities noted via Kamukayi and Rina Devi:
Raj Kumari v. Union of India (MP High Court), Gurcharan Singh v. Union of India (Delhi High Court), Jetty Naga Lakshmi Parvathi v. Union Of India (AP High Court), and Kamrunnissa v. Union of India, (2019) 12 SCC 391—these cases collectively underpin the trajectory towards a claimant-friendly, welfare-oriented evidentiary regime, which Rajni consolidates and operationalizes through a clear prima facie verification rule.

2. Legal Reasoning

Threshold for Supreme Court Intervention under Article 136:
Although the Tribunal and High Court recorded concurrent findings, the Supreme Court intervened because those findings overlooked material evidence—specifically, the DRM report and Chief Booking Supervisor’s verification of the ticket. Such omission rendered the conclusions unsustainable, warranting correction even within the deferential Article 136 framework.
Statutory Framework and Definitions:
Section 124-A provides a no-fault compensation regime for “untoward incidents” (as defined in Section 123(c)). Explanation (ii) to Section 124-A defines “passenger” to include a person who has purchased a valid ticket for travel by a passenger train (or a valid platform ticket) and becomes a victim of an untoward incident. The judgment’s pivot is the interpretive reach of this explanation when physical possession of the ticket is absent.
Preponderance of Probabilities, Not Criminal Standards:
The Court emphatically rejected the adoption of criminal-trial standards (“beyond reasonable doubt”) in these welfare proceedings. Instead, it reiterated that Section 124-A claims are governed by the civil standard—preponderance of probabilities. Technical or procedural lapses (e.g., lack of a seizure memo, non-examination of the investigating officer) cannot, by themselves, negate a claim supported by credible official material.
The Burden-Shifting Mechanism:
The claimant discharged the initial burden by filing a sworn affidavit and producing the DRM report dated 23.02.2019, which recorded the Chief Booking Supervisor’s verification that ticket No. L10274210 (Indore–Ujjain) was issued on 19.05.2017. At that point, the evidentiary burden shifted to the Railways to rebut bona fide travel with cogent evidence. The Railways failed to do so.
Declaratory Principle Articulated:
The Court declared a clear operational rule for tribunals and High Courts: where an official railway inquiry or evidentiary record verifies the issuance of a ticket corresponding to the date and route of the untoward incident, that verification constitutes prima facie proof of bona fide travel, shifting the burden to the Railways. The absence of a seizure memo or the inability to preserve physical evidence cannot, by itself, defeat a legitimate claim when the totality of circumstances supports the claimant.
Treatment of Inconsistencies:
While lower fora noted inconsistencies (e.g., train number references and the absence of a seized ticket at the site), the Supreme Court held that such aspects cannot eclipse official verification and other contemporaneous materials (e.g., Section 174 CrPC inquest closed as accidental fall; post-mortem indicating head injury from blunt force impact). The Court favored substance over form, consistent with welfare-statute interpretation.

3. Impact and Forward-Looking Significance

Evidentiary Clarity and Reduced Dismissals:
By elevating official ticket verification to prima facie status, the judgment reduces the incidence of claims failing merely due to non-recovery of a physical ticket—an all-too-common scenario in accidental falls. Tribunals now have a clearer pathway to recognize bona fide travel and to place the onus on Railways to produce rebuttal evidence.
Operational Imperatives for the Railways:
Once the burden shifts, Railways are expected to marshal “best evidence” within their control—CCTV footage, station and guard logs, alarm-chain pulling records, ticketing datasets, platform registers, RPF/GRP reports, and any internal inquiry materials—to rebut or corroborate the claim. Silence or reliance on procedural gaps will no longer suffice.
Harmonization with Welfare Objectives:
The decision reinforces the welfare and humanitarian purpose of Chapter XIII of the Railways Act. It cautions against a “forensic obstacle race” mentality that frustrates social-justice remedies.
Quantum and Timelines:
The Court awarded Rs. 8,00,000 (the schedule amount for death) with a pragmatic interest direction—6% per annum applicable only upon default beyond 8 weeks. The clear timeline promotes prompt compliance while avoiding further litigation over execution.
Guidance to Lower Courts and Tribunals:
The judgment is prescriptive: treat official ticket verification as prima facie proof, apply the balance-of-probabilities standard, and avoid over-reliance on procedural formalities that are not integral to truth-finding in a welfare claim.

Complex Concepts Simplified

Untoward Incident:
Defined in Section 123(c) of the Railways Act; includes accidental falls from trains. Compensation under Section 124-A applies to such incidents on a strict/no-fault basis.
No-Fault Liability:
Compensation is payable regardless of negligence or fault, subject to limited statutory exceptions (e.g., self-inflicted injury, criminal acts). The focus is on the occurrence of the incident, not on proving fault.
Bona Fide Passenger:
Under Explanation (ii) to Section 124-A, includes a person who has purchased a valid travel ticket (or platform ticket) and becomes a victim of an untoward incident. Physical possession at the time of the accident, though relevant, is not indispensable if credible official proof of issuance exists.
Burden of Proof and Shifting Onus:
Initially, the claimant must present a credible case (e.g., affidavit, official reports). Upon this showing, the burden shifts to the Railways to disprove bona fide travel or the occurrence of an untoward incident.
Preponderance of Probabilities:
The civil standard of proof. A fact is established if, on the overall evidence, it is more likely than not. This is distinct from the “beyond reasonable doubt” standard used in criminal trials.
DRM Report and Chief Booking Supervisor Verification:
Administrative records and certifications generated within the Railway system. A DRM report confirming ticket issuance as per ticketing records, verified by a Chief Booking Supervisor, is strong official evidence of bona fide travel.
Article 136 Interference:
The Supreme Court ordinarily avoids interfering with concurrent findings of fact. It will, however, intervene where such findings ignore material evidence or are perverse—precisely the situation identified in this case.

Key Practical Takeaways and Checklists

For Claimants

File a detailed affidavit narrating the travel plan and accident circumstances.
Obtain and file official railway records: DRM notes/reports, ticket verification by booking authorities, inquiry reports, GRP/RPF records, and post-mortem/inquest papers.
Do not be deterred if the physical ticket is not recovered; focus on official verification of issuance for the relevant date and route.
Seek CCTV/guard logs/alarm-chain records via discovery or summons to shift the onus further onto the Railways.

For Railways

Once a claimant shows official verification of ticket issuance, be prepared to produce rebuttal evidence (CCTV, logs, ticketing data, statements of staff).
Avoid reliance on procedural lapses (e.g., no seizure memo) as a standalone defense.
Ensure robust coordination between GRP, RPF, Station Masters, and Booking offices for timely, accurate record-keeping.

For Tribunals/High Courts

Treat official verification of ticket issuance as prima facie proof of bona fide travel.
Apply a balance-of-probabilities standard and avoid criminal-trial rigour.
Evaluate the totality of circumstances; do not dismiss claims solely due to missing physical tickets or non-examination of formal witnesses when credible official materials exist.
Where possible, call for best evidence from Railways to test the veracity of the claimant’s case.

Conclusion

Rajni v. Union of India consolidates and advances the claimant-friendly jurisprudence under Section 124-A by crystallizing a workable, fair, and welfare-aligned evidentiary rule: official verification of ticket issuance for the relevant date and route is prima facie proof of bona fide travel, shifting the burden to the Railways. The decision resists hyper-technical insistence on seizure memos or strict procedural compliance in the face of credible official material, reinforces the preponderance-of-probabilities standard, and aligns adjudication with the humanitarian purpose of the Railways Act’s compensation regime.

By setting aside the lower fora’s decisions and awarding Rs. 8,00,000 with a clear payment timeline (and conditional interest), the Supreme Court underscores both the doctrinal and practical dimensions of access to compensation. Going forward, this ruling will guide Tribunals and High Courts toward a more consistent, equitable application of Section 124-A, ensuring that legitimate claims are not defeated by avoidable procedural hurdles and that the social-justice objectives of the statute are realized in substance and not merely in form.