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Supreme Court of India 2018-05-09 disposed

Union of India vs Rina Devi

Bench: 2 — Adarsh Kumar Goel

In Brief

This civil appeal clarifies key principles under the Railways Act, 1989 governing compensation for deaths and injuries in railway untoward incidents. The Court held that railways impose strict liability regardless of negligence. The concept of 'self-inflicted injury' requires intentional action and cannot be stretched to cover mere negligence. Compensation applies as of the accident date with reasonable interest, not the award date. The initial burden lies on claimants to prove the deceased was a bona fide passenger via affidavit; burden then shifts to railways. Mere ticket absence does not negate passenger status. These holdings resolve conflicts among High Court decisions on burden of proof, compensation timing, and the scope of the self-inflicted injury defence.

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Railways Act Compensation Strict Liability Untoward Incident Burden of Proof Passenger Definition Self Inflicted Injury Interest on Damages Evidence Civil Procedure

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