Supreme Court Urges Railways to Prevent Overcrowding, Recommends Dropping the Term ‘Second Class Passenger’
In a significant judgment highlighting passenger safety and constitutional dignity, the Supreme Court has urged the Indian Railways to take concrete and effective measures to curb overcrowding in trains, observing that overcrowded coaches continue to result in fatal accidents across the country. The Court also suggested that the Railways discontinue the expression “second class passenger” in its manuals and official terminology, holding that while coaches may be classified into different categories, passengers themselves should never be described by a label that carries a sense of social hierarchy inconsistent with the values of the Constitution.
A Bench comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh made these observations while deciding an appeal filed by the widow of a passenger who died after falling from a moving train in 2015. Allowing the appeal, the Supreme Court awarded ₹8 lakh compensation, holding that the mere non-recovery of the deceased’s railway ticket could not, by itself, defeat a genuine claim under the no-fault liability provisions of the Railways Act.
Expressing concern over recurring incidents of passengers falling from overcrowded trains, the Court remarked that such tragedies are “not a rare occurrence.” Referring to recent railway accidents, including overcrowding-related incidents in Mumbai suburban trains and the New Delhi Railway Station stampede during the Maha Kumbh rush, the Bench observed that these events demonstrate the urgent need for stronger crowd management and passenger safety measures. The Court stressed that although these incidents may appear statistically insignificant against the backdrop of Indian Railways’ vast operations, they represent irreversible personal tragedies for the affected families.
Examining the Indian Railway Commercial Manual, the Supreme Court noted that the Railways has already framed detailed operational guidelines requiring station masters, guards and ticket-checking staff to regulate passenger flow, prevent overcrowding, distribute passengers evenly across coaches, alert stations ahead when trains become excessively crowded and arrange additional coaches wherever feasible. However, the Bench observed that “the forethought is clearly visible, but the execution leaves much to be desired,” indicating that the principal deficiency lies in implementation rather than policy formulation.
The Court also suggested that effective enforcement of these safety measures would require strengthening the Railway workforce. Observing that Indian Railways remains one of the country’s largest public employers, the Bench recommended greater recruitment of young personnel, noting that increased manpower would not only generate employment but also enhance passenger safety through improved operational supervision and crowd management.
One of the most notable aspects of the judgment concerns the terminology used in Railway manuals. The Supreme Court observed that the expression “second class passenger” is inconsistent with the constitutional ethos because it attaches a class-based description to an individual rather than to the category of coach in which the person travels. The Bench stated that the classification should relate only to the coach, observing that, given India’s historical experience with social divisions, describing a traveller as a “second class passenger” is “offensive to the spirit of the Constitution of India.”
At the same time, the Court clarified that responsibility for passenger safety is shared by both the Railways and the travelling public. While directing the Railways to strengthen preventive measures, the Bench cautioned that passengers must also avoid unsafe practices such as attempting to board moving trains or travelling in dangerously overcrowded conditions whenever possible. Nevertheless, the Court made it clear that the State-run Railways, as a public welfare institution, bears the primary obligation to provide a safe travel environment.
The judgment is expected to have far-reaching implications for railway administration and passenger rights. Beyond granting compensation in the individual case, the Supreme Court has called for improvements in crowd management, greater investment in operational manpower and a shift toward more dignified official language. Legal experts believe the ruling reinforces the constitutional principles of equality, dignity and welfare governance, while reminding public authorities that administrative terminology and safety practices must reflect the values embodied in the Constitution.
