The complaints upheld against the Nottingham Evening Post and the Leicester were brought by the mother of a primary school child who had been on a school trip when the bus her daughter was travelling on crashed into a railway bridge.
The image showed her daughter and other children after the accident. The child's parent said the picture was taken and published without consent and as a result had caused her daughter further upset.
In their submissions to the PCC, both papers said they had considered whether or not to publish the photograph very carefully before deciding that it was in the public interest.
The Leicester Mercury suggested that publication would not have had an impact on the welfare of the children while the Nottingham Evening Post said the lack of serious injuries or fatalities had been an important factor in its decision.
Publishing its ruling today, the PCC said that newspapers "are entitled to publish stories and pictures of serious road accidents, which take place in public and often have wide-reaching consequences", and that it "did not wish to interfere unnecessarily" with the newspapers' right to report the story.
The PCC said its code of conduct had been breached as there was "no doubt" the close-up photograph of the complainant's daughter related to her welfare and it was not disputed that the image had been taken and published without parental consent.
"There may be occasions where the scale and gravity of the circumstances can mean that [such material] can be published in the public interest without consent" the PCC said. However, on this occasion the PCC judged the newspapers to be "just the wrong side of the line".
"The commission's ruling sends an important reminder to editors of the exceptionally high standards which the Commission expects when reporting stories related to children," said Stephen Abell, director of the PCC.
Oliver Luft writes for Press Gazette.