High Court rules in favor of Sidharth K. Bhattathiri, emphasizing liberal interpretation of the Railways Act, 1989, to protect accident victims.
In a landmark judgment, the Kerala High Court overturned the Railway Claims Tribunal's rejection of a compensation claim by Sidharth K. Bhattathiri, a television journalist who suffered grievous injuries while attempting to board a moving train. The court awarded him a compensation of Rs. 8,00,000, highlighting the necessity for a liberal interpretation of the Railways Act, 1989, particularly its beneficial provisions aimed at protecting victims of railway accidents.
The incident occurred on November 19, 2022, when Bhattathiri, travelling on the Kochuveli - Yog Nagari Rishikesh Super-Fast Express, attempted to re-board the train at Surat Railway Station after alighting. Unfortunately, he fell, resulting in the amputation of both legs and a fractured clavicle. The Railway Claims Tribunal had initially dismissed his claim, categorizing the injuries as self-inflicted based on the evidence, including CCTV footage and the train guard’s testimony.
However, Justice S. Manu of the Kerala High Court found the Tribunal's conclusion unsustainable. The court emphasized that "self-inflicted injury" requires intent, not mere negligence, citing the Supreme Court's ruling in Union of India v. Rina Devi, which clarified that contributory negligence cannot be considered under the "no fault theory" of the Railways Act.
The High Court further criticized the Tribunal's procedural lapses, such as improperly marking affidavits as exhibits, and directed adherence to the Railway Claims Tribunal (Procedure) Rules, 1989. In exercising its supervisory jurisdiction under Article 227 of the Constitution, the court mandated the Tribunal to annex comprehensive appendices to its judgments, detailing witnesses and documents, to enhance clarity and proper adjudication of appeals.
This judgment reinforces the protective intent of Chapter XIII of the Railways Act, ensuring that victims of railway accidents receive due compensation even in the face of procedural and evidentiary challenges.
Bottom Line:
Railway Claims Tribunal's rejection of compensation on grounds of self-inflicted injury overturned - Liberal interpretation of beneficial provisions under Railways Act, 1989 upheld - Compensation awarded to appellant for injuries sustained while boarding a moving train.
Statutory provision(s): Railways Act, 1989 Section 123(c), Section 124A, Chapter XIII; Railway Claims Tribunal (Procedure) Rules, 1989 Rules 14 and 15-C; Article 227 of the Constitution of India.
Sidharth K. Bhattathiri v. Union of India, (Kerala) : Law Finder Doc Id # 2833340