On Monday, the state chief minister said 37 people had died, but railway officials later revised the toll down.
An angry mob then assaulted the driver and set the train alight.
The victims, mostly Hindu pilgrims, had just alighted from a local train at Dhamara Ghat station and were on their way to a temple in Saharsa district.
The pilgrims were hit by the Rajya Rani Express travelling on the opposite track.
"When I reached the scene, bodies were lying scattered all around. People were crying for help and there was no medical facility to be seen. Help came only after four or five hours," eyewitness Tuntun Ram told the BBC on Tuesday morning.
Railway officials said the express train was travelling at high speed as it was not expected to stop at Dhamara Ghat station.
But after the accident, it stopped a few hundred metres away. An angry mob then pulled out the driver and severely assaulted him.
India's state-owned railway network is vast - it operates 9,000 passenger trains and carries some 18 million passengers every day.
A government-appointed safety panel in its report last year said about 15,000 people were killed each year crossing train tracks in what officials describe as "unlawful trespassing".
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