Bomb Blast in Passenger Train Is a Railway ‘Accident’: Punjab & Haryana HC Dismisses Union of India’s Appeals, Modifies Compensation

The Punjab & Haryana High Court held that a bomb explosion aboard the Janta Express in 1992 constitutes an ‘accident’ under Section 124 of the Railways Act, 1989, making the Union of India liable to pay compensation to the families of five deceased passengers.

Three decades after a bomb tore through a moving passenger train, the Punjab and Haryana High Court at Chandigarh has confirmed that the Union of India cannot escape its statutory liability to compensate the families of those who died. Justice Pankaj Jain, sitting singly, disposed of two first appeals filed by the Union of India and three cross-objections filed by the claimants through a common judgment dated 18 May 2026. The central question was whether a bomb blast aboard a passenger train falls within the definition of ‘accident’ under Section 124 of the Railways Act, 1989. The court answered in the affirmative, relying on the Railways’ own Accident Manual and a binding Supreme Court precedent, and went on to recalibrate the rate of interest on compensation in line with the Supreme Court’s ruling in Union of India v. Rina Devi, (2019) 3 SCC 572.

The 1992 Bomb Blast on the Janta Express

On 8 February 1992, a bomb exploded inside train 24-Down Janta Express, which was travelling from Tohana to Jind. Many passengers sustained fatal injuries and five passengers died. FIR No. 14 dated 8 February 1992 was registered under Section 4 of the Explosive Act, Sections 3, 4 and 5 of the T.D.A. Act, Sections 307 and 326 of the IPC, and Section 150 of the Indian Railways Act.

Three separate claim petitions were filed before the Railway Claims Tribunal. OA-II-123/93, filed by Smt. Usha Singla and others, sought compensation for the death of Om Prakash. OA-II-131/93, filed by Smt. Shakuntala Devi and others, related to the death of Girdhari Lal. OA-II-122/93, filed by Smt. Santosh Jain and others, related to the death of Prem Sagar Jain. The Tribunal awarded compensation in all three matters, holding that the bomb blast fell within the ambit of ‘accident’ under Section 124 of the 1989 Act.

The Union of India challenged the awards in FAO No. 186 of 1994 (arising from OA-II-123/93) and FAO No. 187 of 1994 (arising from OA-II-122/93). FAO No. 1018 of 1995, arising from OA-II-131/93, had already been dismissed for non-prosecution on 22 January 2020. The claimants in all three matters filed cross-objections seeking enhancement of compensation to Rs. 8 lakhs, relying on Rina Devi.

Whether a Bomb Blast Is an ‘Accident’ Under Section 124

Section 124 of the Railways Act, 1989 imposes a no-fault liability on the railway administration when, in the course of working a railway, an accident occurs — whether a collision between trains carrying passengers, a derailment, or “other accident to a train or any part of a train carrying passengers.” The provision makes the railway administration liable to pay prescribed compensation regardless of whether there was any wrongful act, neglect or default on its part.

The Union of India argued that the bomb blast did not fall within this definition of ‘untoward incident’ or ‘accident’ and that its liability was therefore not attracted. Justice Pankaj Jain found these arguments to be without merit.

The court first turned to the Accident Manual issued by the Northern Railway Administration. Item No. 103 of the Manual classifies train accidents into consequential train accidents and other train accidents. Consequential train accidents include collisions, fire, level crossing accidents, derailments, and miscellaneous incidents. Item No. 202 of the Manual defines a collision as occurring when a train collides head-on or from the rear against any train or vehicle, whether moving or stationary. Crucially, the Manual also classifies fire in trains as a consequential train accident under categories B-1 to B-4.

The court then relied on the Supreme Court’s analysis in Union of India and others v. Sunil Kumar Ghosh, (1984) 4 SCC 246, where the Supreme Court explained what constitutes an ‘accident’ for the purposes of railway liability. The Supreme Court had observed that an accident is “the happening of the unexpected, not the happening of the expected.” It had specifically noted that “blowing up of a train is something which no one ordinarily expects in the course of a journey” and therefore falls within the parameters of the definition of accident.

Drawing on both the Accident Manual and Sunil Kumar Ghosh, Justice Pankaj Jain held that once fire or explosion in a train falls within the definition of ‘accident’, the Union of India cannot escape its liability to pay compensation on account of deaths arising out of a bomb blast in a train or at a railway station. The Tribunal’s finding on liability was affirmed without interference.

The Cross-Objections: Compensation Quantum and the Rina Devi Formula

The claimants filed cross-objections contending that they were entitled to Rs. 8 lakhs each, relying on the ratio in Union of India v. Rina Devi, (2019) 3 SCC 572. The Tribunal had awarded compensation at the rate prescribed as on the date of the award, i.e., 25 August 1993, which was Rs. 2 lakhs. The Tribunal had also directed that if payment was not made within 60 days, interest at 12% per annum would run from the date of the order.

In Rina Devi, the Supreme Court had laid down that compensation is payable as applicable on the date of the accident, with reasonable interest from that date. If the amount so calculated is less than the amount prescribed on the date of the Tribunal’s award, the claimant is entitled to the higher of the two amounts. The Supreme Court had also clarified that this formula would not affect awards that had already become final and where the limitation for challenging such awards had expired.

Justice Pankaj Jain applied this formula to the facts. The accident occurred on 8 February 1992. The Tribunal passed its award on 25 August 1993. On the date the award was passed, the prescribed amount was Rs. 2 lakhs. The court found that the claimants’ case fell within the exceptions carved out in Rina Devi: the compensation had to abide by the schedule in force on the date of the award, i.e., Rs. 2 lakhs. The plea for Rs. 8 lakhs was accordingly rejected.

However, the court modified the interest component. Instead of the Tribunal’s direction of 12% per annum running only from the date of the order (and only if payment was not made within 60 days), the court held that the claimants are entitled to interest at 9% per annum from the date of filing of the claim petition till the date of actual realisation. This modification brought the interest calculation in line with the Rina Devi framework, which requires reasonable interest to run from the relevant date so as to give effect to the mandate of the beneficial legislation.

Outcome

FAO No. 186 of 1994 and FAO No. 187 of 1994, both filed by the Union of India, were dismissed. FAO No. 1018 of 1995 had already been dismissed for non-prosecution on 22 January 2020. The three cross-objections filed by the claimants — XOBJC-661-1995, XOBJC-662-1995, and XOBJC-42-CII-1995 — were disposed of with the modification that compensation awarded by the Tribunal stands confirmed at the amount prescribed as on the date of the award, with interest at 9% per annum from the date of filing of the respective claim petitions till actual realisation. All pending applications, if any, were also disposed of.