Definition: In this task, you need to generate an appropriate title for the given summary of some paragraph. The generated title must be short and should include the main topic of the given text. Your summary should be less than 20 words long.
Input: A barrister who avoided paying train tickets could have cost a rail company £23,000 a court has heard.

Barrister Peter Barnett 'may have cost Chiltern Railways £23k in unpaid fares'