In Brief
This appeal resolved conflicting interpretations of the Railways Act, 1989 regarding compensation for deaths in 'untoward incidents'. The Court clarified that strict (no-fault) liability applies to railway compensation regardless of the railway administration's wrongfulness. 'Self-inflicted injury' under the Act requires intent to injure, not mere negligence—hence, deaths during boarding/de-boarding qualify as untoward incidents. The initial burden lies on the claimant to prove the deceased was a bona fide passenger through affidavit; absence of a ticket alone does not defeat this. Regarding compensation quantum, liability accrues on the accident date; compensation is based on that date's rate plus reasonable interest (on par with motor accident claims). If the revised rate as of the award date is higher, the claimant receives the higher amount. The Court clarified conflicting precedents and established uniform interest rates applicable from accident to payment date.
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