Bomb Blast In Passenger Train Is An 'Accident' Under Railways Act; Railways Liable To Pay Compensation: Punjab & Haryana High Court
The Punjab and Haryana High Court has upheld the liability of the Union of India to pay compensation to victims of a bomb blast in a passenger train, holding that such an incident falls within the definition of an “accident” under Section 124 of the Railways Act, 1989. [2026 LiveLaw (PH) 204]Justice Pankaj Jain said, "once it has been held that fire or explosion in the train falls within...
The Punjab and Haryana High Court has upheld the liability of the Union of India to pay compensation to victims of a bomb blast in a passenger train, holding that such an incident falls within the definition of an “accident” under Section 124 of the Railways Act, 1989. [2026 LiveLaw (PH) 204]
Justice Pankaj Jain said, "once it has been held that fire or explosion in the train falls within the definition of 'accident', the Union of India can not escape its liability to pay compensation on account of death arising out of bomb blast in the train/railway station."
The Court dismissed multiple appeals filed by the Union of India challenging awards granted by the Railway Claims Tribunal to families of passengers who died in the blast.
The case arose from a bomb explosion in the 24-Down Janta Express travelling from Tohana to Jind on February 8, 1992. The blast resulted in multiple fatalities and injuries. An FIR was registered under provisions of the Explosive Substances Act, TADA, IPC, and the Railways Act.
Several pleas were filed before the Railway Claims Tribunal by families of deceased passengers, including Usha Singla, Shakuntala Devi, and Santosh Jain. The Tribunal awarded compensation, holding that the incident qualified as an “accident” under Section 124 of the Railways Act.
Aggrieved, the Union of India filed appeals contending that a bomb blast does not fall within the statutory definition of an “untoward incident” or accident, and therefore no liability could be fastened on the Railways.
The Court considered that whether a bomb blast inside a running train constitutes an “accident” under Section 124 of the Railways Act, thereby attracting strict liability for compensation.
The Court examined Section 124 of the Railways Act, which imposes strict liability on the Railways to compensate passengers for death or injury resulting from an “accident,” regardless of fault.
It also relied on the Accident Manual issued by the Northern Railway, which classifies train accidents to include incidents involving fire, explosion, and other serious occurrences resulting in loss of life or injury.
Further, the Court referred to the Supreme Court's judgment in Union of India v. Sunil Kumar Ghosh (1984) 4 SCC 246, which explained that an accident is an unforeseen and unexpected event not ordinarily anticipated in the course of a railway journey.
In the light of the above, the judge held that it finds no reason to interfere in the findings recorded by the Tribunal to hold that the Administration is liable to pay compensation on account of death of the passengers caused on account of bomb blast in the moving train.
Hence, the compensation awarded by the Tribunal was modified. The Court held that claimants are held entitled to compensation as applicable on the date of accident along with interest @ 9% per annum from the date of filing of the claim petition till the date of actual realization.
Mr. S.K. Jain, Advocate.
Mr. Deepak Jain, Advocate (Through V.C.) and Mr. Akshay Jain, Advocate for the X-Objectors/Respondents.
Mr. Sandeep Bhatia, Sr. Panel Counsel for the appellant.
Title: UNION OF INDIA v. USHA SINGLA AND OTHERS