The Supreme Court on Friday urged the Indian Railways to take effective measures to curb overcrowding in trains, observing that such incidents frequently lead to passengers falling from moving trains and losing their lives. The Court also suggested that the Railways discontinue the use of the expression "second class passenger" in its manuals, stating that the class distinction should be attached to the coach and not to the passenger, in keeping with the constitutional ethos.

A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh made these observations while allowing an appeal filed by the widow of a man who died after falling from a running train in 2015. The Court awarded her compensation of ₹8 lakh after holding that the absence of the deceased's ticket could not by itself defeat a genuine claim under the Railway Act.

Observing that deaths due to passengers falling from overcrowded trains are "not a rare occurrence", the Bench said that although such incidents may appear statistically insignificant in the context of the Railways' vast operations, they are life-altering tragedies for affected families.

The Court referred to recent incidents of overcrowding, including the Mumbai suburban train accident in June 2025 in which four commuters died after falling from overcrowded local trains, the New Delhi railway station stampede during the Maha Kumbh rush, and several other accidents across the country. It noted that these incidents underscore the continuing safety concerns arising from overcrowding.

Examining the Indian Railway Commercial Manual, the Court noted that the Railways has already framed detailed guidelines requiring station masters, guards and ticket checking staff to prevent overcrowding, distribute passengers evenly across coaches, warn stations ahead when trains become overcrowded, and arrange additional coaches where necessary.

"The forethought is clearly visible, but the execution leaves much to be desired," the Bench remarked.

The Court further observed that implementation of many of these measures would require substantially greater manpower. In this context, it suggested that the Railways consider employing more young people.

"While we are in the era of modernisation, we may suggest that it may be only felicitous both for the Organisation and the country as a whole if the youth of today are employed by the Organisation, not only giving them a stable source of livelihood but also preserving human lives," the judgment said.

At the same time, the Bench said passengers also share responsibility for their own safety.

"It would be entirely unfair to cast sole responsibility upon the Railways. The passengers themselves have an equal responsibility... Sometimes practical considerations must give way to the preservation of life," the Court observed, referring to the risks undertaken by passengers while boarding or travelling on overcrowded trains.

The Court also took exception to the terminology used in Railway manuals describing travellers as "second class passengers."

"While it is ostensibly linked to the expenditure incurred by the passenger to travel, we may suggest that the class connotation be attached to the coach and not to the passenger, in recognition of the history of class divisions in our country and the same being offensive to the spirit of the Constitution of India," the Bench observed.

On the facts of the case, the Court held that the Railway Claims Tribunal and the Madhya Pradesh High Court had wrongly denied compensation merely because the deceased's journey ticket was not recovered. His widow had consistently stated that the ticket was kept in his travel bag, which went missing after the accident.

Reiterating that Section 124A of the Railways Act embodies a beneficial "no-fault liability" regime, the Court held that the claimant had discharged the initial burden by filing an affidavit stating that the deceased possessed a valid ticket. Merely because the ticket was lost in the accident could not negate his status as a bona fide passenger.

Accordingly, the Court set aside the orders of the Tribunal and the High Court and directed the Railways to pay compensation of ₹8 lakh within four weeks, failing which the amount would carry interest at 8% from the date of filing of the claim petition.

Appearances :

For Petitioner(s) :Ms. Shweta Priyadarshini , AOR

For Respondent(s) : Mr. Brijender Chahar, A.S.G. Ms. Seema Bengani, Adv. Mr. Prashant Singh-ii, Adv. Ms. Sweksha, Adv. Ms. Radhika Mishra, Adv. Mr. Amrish Kumar, AOR

Case : Lata v Union of India

Citation : 2026 LiveLaw (SC) 689

Click here to read the judgment

Related- Railway Compensation Claim - Mere Absence Of Ticket Doesn't Mean Victim Wasn't Bona Fide Passenger : Supreme Court

Railway Accident Claims Not Criminal Trial For Proof Beyond Reasonable Doubt; Avoid Hypertechnical Approach : Supreme Court