Wait-listed rail e-ticket boarding rule upheld, while Railways must consider safeguards against misuse of physical wait-listed tickets.

A challenge to the railway boarding restriction for fully wait-listed e-ticket holders failed because no rule or regulation granted wait-listed physical ticket holders a right to board, and Section 155 of the Railways Act, 1989 barred entry into a compartment without a reserved berth or seat without distinguishing between ticket formats. The Court nevertheless noted a practical difference: physical wait-listed tickets remained in existence until counter cancellation, while e-tickets were automatically cancelled when the final chart was prepared, which could disadvantage e-ticket holders. No illegality or discrimination was found in the circular, but the Railways were directed to consider measures against misuse of physical wait-listed tickets and to examine whether e-ticket holders should be allowed to retain wait-list status after chart preparation.

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Issues: Whether the rule prohibiting fully wait-listed e-ticket holders from boarding the train was discriminatory vis-a -vis wait-listed passengers holding physical tickets, and whether the Railways should be directed to consider measures to prevent abuse of the wait-listing system.

Analysis: The challenge based on discrimination failed because no rule or regulation was shown to confer a right on wait-listed passengers holding physical tickets to board the train. Section 155 of the Railways Act, 1989 prohibited entry into a compartment without a reserved berth or seat and did not distinguish between e-ticket and physical ticket holders. At the same time, the pleadings showed a practical difference: a wait-listed physical ticket continued to exist until cancellation at the counter, whereas a wait-listed e-ticket was automatically cancelled on preparation of the final chart. This created a limited opportunity for physical ticket holders to board and attempt to secure vacant accommodation, and the Court accepted that this possibility could operate to the disadvantage of e-ticket holders.

Conclusion: No illegality or discrimination was made out in the impugned circular, but the Railways were directed to consider, within six months, ways to prevent misuse of physical wait-listed tickets and to examine whether e-ticket holders should be given an option to retain their wait-list position after chart preparation.

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