Bomb Blast in Train Constitutes ‘Accident’; Railways Liable to Pay Compensation: Punjab & Haryana High Court
Case Name: Union of India v. Usha Singla & Others (Connected Matters)
Date of Judgment: 18.05.2026
Citation: FAO-186-1994
Bench: Hon’ble Mr. Justice Pankaj Jain
Held: The Punjab & Haryana High Court held that a bomb blast inside a moving passenger train constitutes an “accident” under Section 124 of the Railways Act, 1989, making the Railway Administration statutorily liable to compensate victims or their legal heirs. The Court further held that a terrorist or criminal act does not absolve the Railways of its liability where death or injury results from such an accident.
Summary: The case arose from a bomb explosion in the 24-Down Janta Express travelling from Tohana to Jind, resulting in multiple fatalities and injuries. The legal heirs of deceased passengers approached the Railway Claims Tribunal seeking compensation, which was awarded on the ground that the incident amounted to an “accident” under Section 124 of the Railways Act.
Challenging the award, the Union of India argued that a bomb blast is essentially a law and order issue and does not fall within the scope of an “untoward incident” or “accident” envisaged under the Act.
The High Court rejected this contention after examining Section 124 of the Railways Act and the Northern Railway Accident Manual. It observed that the Manual classifies train accidents to include incidents involving fire and explosions, thereby bringing bomb blasts within the ambit of train accidents.
The Court also relied upon the Supreme Court’s decision in Union of India v. Sunil Kumar Ghosh, which explained that an accident is an unforeseen and unexpected event occurring during a railway journey. Since a bomb explosion is neither ordinary nor inherent to train travel, it squarely qualifies as an accident attracting statutory compensation.
The Court held that once an explosion or fire in a train is recognized as an accident, the Railway Administration cannot evade liability merely because the cause is a criminal or terrorist act. The liability under Section 124 is statutory and independent of any wrongful act or negligence on the part of the Railways.
With respect to the cross-objections seeking enhancement of compensation to ₹8 lakhs based on Union of India v. Rina Devi, the Court held that the Tribunal’s award had been passed in 1993 when the prescribed compensation was ₹2 lakhs. Consequently, the claimants were not entitled to enhanced compensation under the later regime. However, the Court modified the award by directing payment of compensation applicable on the date of the accident along with interest at 9% per annum from the date of filing of the claim petition until actual realization.
Decision: The High Court dismissed the appeals filed by the Union of India and upheld the finding that a bomb blast in a moving train is an “accident” under Section 124 of the Railways Act, making the Railway Administration liable to pay compensation. The cross-objections were disposed of by modifying the award to grant compensation with 9% interest while rejecting the claim for enhanced compensation of ₹8 lakhs.