High Court of Karnataka Quashes Criminal Proceedings Against Entrepreneur for Developing Tatkal Ticket Auto-Fill Software. The software tool merely auto-filled passenger details on IRCTC website and did not circumvent any security protocols, thus not constituting an offence under Section 143 of the Railways Act, 1989.

High Court: Karnataka High Court Bench: BENGALURU In Favour of Accused

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2026-05-18 16:41:55

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Case Note & Summary

The petitioner, Gaurav Dahake, an IIT Kharagpur graduate and entrepreneur, developed a software tool called 'Tatkalforsure' in August 2017. The tool was designed to auto-fill passenger details on the official IRCTC website to facilitate faster booking of Tatkal tickets. The Railway Protection Force (RPF) filed an Occurrence Report No.895/2020 dated 30.09.2023 against the petitioner for an offence punishable under Section 143(2) of the Railways Act, 1989. The XXXV Additional Chief Metropolitan Magistrate/Special Metropolitan Magistrate (Railways), Bangalore took cognizance of the offence in C.C.No.3401 of 2023. The petitioner challenged this order by filing a criminal petition under Section 482 of the Code of Criminal Procedure, 1973 (Cr.P.C.) before the High Court of Karnataka. The court heard arguments from both sides. The petitioner's counsel argued that the tool merely automated the filling of details on the official website and did not circumvent any security protocols or hack the system. The respondent's counsel contended that the tool interfered with the railway's ticketing system. The court analyzed Section 143 of the Railways Act and found that the provision penalizes unauthorized access or interference with railway property or systems. Since the tool only auto-filled details on the official IRCTC website without bypassing any security measures, the court held that no prima facie offence was made out. The court quashed the Occurrence Report and all subsequent proceedings.

Headnote

A) Criminal Law - Quashing of Criminal Proceedings - Section 482 Cr.P.C. - Section 143 Railways Act, 1989 - The petitioner developed a software tool 'Tatkalforsure' that auto-filled passenger details on the official IRCTC website for booking Tatkal tickets. The court held that the tool did not circumvent any security protocols or hack the system, but merely automated the filling of details, which is not an offence under Section 143 of the Railways Act. The proceedings were quashed. (Paras 1-10)

B) Railways Act - Offence under Section 143 - Interpretation - Section 143 Railways Act, 1989 - The court interpreted Section 143 and held that it penalizes unauthorized access or interference with railway property or systems. Since the tool only auto-filled details on the official website without bypassing any security, no offence was made out. (Paras 5-8)

Issue of Consideration

Whether the development and use of a software tool that auto-fills passenger details on the official IRCTC website for booking Tatkal tickets constitutes an offence under Section 143 of the Railways Act, 1989?

Final Decision

The court allowed the petition and quashed the Occurrence Report No.895/2020 dated 30.09.2023 and the order dated 31-10-2023 taking cognizance in C.C.No.3401 of 2023, along with all subsequent proceedings.

Law Points

Section 143 of the Railways Act
1989
does not penalize mere auto-filling of passenger details on the official IRCTC website without circumventing security protocols
Criminal proceedings under Section 482 Cr.P.C. can be quashed if no prima facie offence is made out

Case Details

2024 LawText (KAR) (09) 51

Criminal Petition No.2926 of 2024

2024-09-03

M. Nagaprasanna

Sri Rohan Kothari, Sri Sathvik Upadhya, Sri Ajay Prabhu M.

Gaurav Dahake

The Union of India

Nature of Litigation

Criminal petition under Section 482 Cr.P.C. seeking quashing of an Occurrence Report and cognizance order for alleged offence under Section 143 of the Railways Act, 1989.

Remedy Sought

Petitioner sought quashing of Occurrence Report No.895/2020 dated 30.09.2023 and order dated 31-10-2023 taking cognizance in C.C.No.3401 of 2023.

Filing Reason

Petitioner developed a software tool 'Tatkalforsure' that auto-fills passenger details on IRCTC website for booking Tatkal tickets, which was alleged to be an offence under Section 143 of the Railways Act.

Previous Decisions

The XXXV Additional Chief Metropolitan Magistrate/Special Metropolitan Magistrate (Railways), Bangalore took cognizance of the offence on 31-10-2023 in C.C.No.3401 of 2023.

Issues

Whether the development and use of a software tool that auto-fills passenger details on the official IRCTC website for booking Tatkal tickets constitutes an offence under Section 143 of the Railways Act, 1989?

Submissions/Arguments

Petitioner argued that the tool merely auto-filled details on the official website and did not circumvent any security protocols or hack the system, thus no offence under Section 143. Respondent argued that the tool interfered with the railway's ticketing system and amounted to an offence under Section 143.

Ratio Decidendi

Section 143 of the Railways Act, 1989 penalizes unauthorized access or interference with railway property or systems. A software tool that merely auto-fills passenger details on the official IRCTC website without circumventing any security protocols does not constitute an offence under Section 143.

Judgment Excerpts

The petitioner is before this Court calling in question an order dated 31-10-2023 passed by the XXXV Additional Chief Metropolitan Magistrate/Special Metropolitan Magistrate (Railways), Bangalore in C.C.No.3401 of 2023 taking cognizance of the offence punishable under Section 143 of the Railways Act, 1989. The petitioner claims to be an IIT Graduate from IIT Kharagpur with a deep passion for entrepreneurship. The petitioner subsequently in the month of August 2017 develops a software tool called ‘Tatkalforsure’ which auto fills the details of travellers intending to book Tatkal tickets on official IRCTC website.

Procedural History

The petitioner developed the software tool in August 2017. The RPF filed Occurrence Report No.895/2020 on 30.09.2023. The Magistrate took cognizance on 31-10-2023 in C.C.No.3401 of 2023. The petitioner filed Criminal Petition No.2926 of 2024 under Section 482 Cr.P.C. before the High Court of Karnataka. The petition was reserved on 08.08.2024 and pronounced on 03.09.2024.