The 2019 rule change that fastened Indian aviation’s growth journey, helped fuel IndiGo’s supremacy

IndiGo’s 2019 donation to the BJP came against a backdrop of a policy shift in pilot work hours and the airline’s rapid operational growth.

WrittenBy:Prateek Goyal
Date:
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In February 2009, Colgan Air Flight 3407 crashed near Buffalo, New York, killing all 49 people on board. The US National Transportation Safety Board linked the accident to pilot fatigue. 

One year later, 158 passengers died when Air India Express Flight 812 overshot the runway at Mangalore. Investigators from India’s Aircraft Accident Investigation Bureau, the Directorate General of Civil Aviation and even the NTSB pointed to fatigue as a possible contributing factor.

These disasters, separated by continents, reinforced a lesson aviation regulators have long agreed upon: exhausted pilots are a danger to themselves and to everyone else in the sky. That consensus is the reason Flight Duty Time Limitation rules — known as FDTL — exist. They are meant to draw a hard line between commercial efficiency and human endurance.

This month, however, IndiGo has been at the centre of an operational crisis that many pilot unions say reflects long-standing tensions over these duty-time norms. Despite being given advance notice to implement revised FDTL rules mandated by a 2024 court order, the airline reportedly cancelled hundreds of flights at short notice. Passengers across major airports were stranded, and the DGCA eventually rolled back parts of the revised norms. 

Civil Aviation Minister Ram Mohan Naidu publicly questioned why other airlines could comply when IndiGo could not. And at least one pilot union alleged the crisis was artificially created.

The 2024 FDTL changes had followed several years of campaigning by pilots for stronger fatigue safeguards. These concerns had intensified in 2019, when the DGCA introduced a controversial new Civil Aviation Requirement (CAR) that pilot unions described as reducing rest, increasing fatigue risk and as a profit maximising tool for airline owners.

Nine days after this rule took effect, two entities linked to IndiGo promoter Rahul Bhatia – InterGlobe Air Transport Ltd and InterGlobe Real Estate Ventures – donated Rs 31 crore to the BJP through electoral bonds on May 10, 2019. According to electoral bond data, IndiGo-linked entities were the only airline-affiliated donors to make such a contribution immediately after the rollout and the only ones to do so in the 2019–20 financial year.

During the five years that the 2019 CAR remained in force, the Indian aviation industry expanded significantly, and IndiGo, already the country’s largest airline, grew steadily during this period as well. Between 2019–20 and 2024–25, its fleet increased from 262 to 434 aircraft – more than 65 percent – while its network grew from 86 destinations (24 international) to 131 (40 international). Daily flights rose from 1,674 to about 2,200, and operational revenue more than doubled from Rs 35,756 crore to Rs 80,802 crore. The pandemic caused a temporary setback in 2020–21, but IndiGo recovered quickly, crossing 300 aircraft by 2022–23 and reaching nearly Rs 69,000 crore in revenue the following year. 

It is difficult to quantify exactly how much this single regulatory change contributed to IndiGo’s performance, which was also shaped by market share, fleet orders, cost structures and post-pandemic demand. 

However, a part of IndiGo’s business model has depended on squeezing revenue out of every hour of the day by keeping its aircraft flying through the night, when airspace is quieter and airport slots are cheaper. According to a Newslaundry analysis based on data on the websites of DGCA, IndiGo, the Open Government Data Platform and Kaggle, this model expanded after the 2019 CAR increased the permissible number of night landings from two to six, allowing IndiGo to build a denser late-night and dawn network that neither full-service carriers nor rival low-cost airlines matched because of its scale. 

By 2019 and 2020, night operations accounted for roughly a quarter of IndiGo’s schedule. In winter 2018, IndiGo operated just 302 night/early-morning flights, but after the 2019 CAR this number surged to over 500. This suggests how FDTL limits are important to its strategy.

Former pilot and aviation expert Captain Sohil Handa stated that these night and early-morning sectors are central to IndiGo’s high-utilisation strategy: planes spend less time on the ground, fixed costs are spread over more flights, and each aircraft generates more revenue. 

Compared with the 2019 rules, the 2024 framework placed clearer and more conservative boundaries around night operations of the kind IndiGo routinely runs, shifting regulatory emphasis from operational flexibility toward stronger fatigue-management protections.

The new FDTL norms ordered by the Delhi High Court in 2024, reducing night landings back to two, extending the night window to 00:00–06:00, capping consecutive night duties, and increasing pilot rest, impacted the foundation of this model. While all airlines agreed to a phased rollout starting July 2025, IndiGo later increased night and early-morning flights –  from 225 in its winter 2024 schedule to 297 in winter 2025 – undermining the revised norms it had formally accepted. 

Newslaundry reached out to IndiGo, InterGlobe Air Transport Ltd, InterGlobe Real Estate Ventures, the DGCA, the BJP and the union civil aviation ministry. This report will be updated if responses are received.

Former pilot and aviation expert Captain Sohil Handa stated that these night and early-morning sectors are central to IndiGo’s high-utilisation strategy: planes spend less time on the ground, fixed costs are spread over more flights, and each aircraft generates more revenue.

What a 2010 panel said

To understand the entire chain of events leading to the current Indigo fracas, one must return to the Naseem Zaidi Committee report that was made public on September 15, 2010.

In September 2010, then DGCA chief Naseem Zaidi set up a committee to review flight duty and rest rules for pilots. The panel based its recommendations on International Civil Aviation Organisation standards and global practices from countries such as the US, UK, Australia and New Zealand, and also consulted pilot unions and airlines. 

It clearly recognised fatigue as a major safety risk. It defined rest as uninterrupted, free from all duties and standby, mandated longer recovery after time zone crossings, and imposed strict safeguards for ultra-long-range (ULR) flights.

A year later, drawing directly from the panel’s recommendations, the DGCA notified India’s first formal rules on pilot work limits – the CAR on FDTL and rest – on August 11, 2011.

The 2011 CAR set clear, easy-to-follow limits to protect pilots from fatigue. On domestic and neighbouring country routes, a two-pilot crew could fly between 8 and 9 hours in any 24-hour period, depending on the schedule. Day flights were capped at 8 hours of flying with up to six landings, while night flights allowed a maximum of 9 hours but with no more than two landings. In some daytime schedules, pilots could fly up to 9 hours, but only with a maximum of three landings.

For international flights, the rules became stricter based on how many pilots were on board. With two pilots, flying time was limited to 10 hours on a daytime flight with one landing, 9 hours during the day with up to three landings, or 9 hours at night with no more than two landings. Adding more pilots allowed longer flights: three-pilot crews could fly up to 12 hours with one landing, and four-pilot crews up to 16 hours with one landing. Ultra-long-range flights lasting over 16 hours needed at least four pilots and special DGCA approval for each specific route.

To prevent fatigue from building up over time, the CAR also fixed strict weekly, monthly and yearly limits. Pilots were not allowed to fly more than 35 hours in seven days, 125 hours in 30 days, or 1,000 hours in a year, ensuring that rest, not just flying, remained central to flight safety.

The 2011 CAR also put firm limits on how long pilots could remain on duty. For international flights operated by two pilots, the maximum Flight Duty Period (FDP) – measured from the time a pilot reports for duty until the aircraft is parked and the engines are shut down – was capped at 13 hours if the flight involved just one landing and up to 10 hours of flying. If the operation was more demanding, such as a night flight with two landings or a day flight with three landings, the FDP was reduced to 12.5 hours, with flying time limited to 9 hours.

The rules were stricter when flights overlapped with the Window of Circadian Low (WOCL), the period between 2 am and 6 am, when the human body is naturally at its most fatigued. If a duty period started during the WOCL, the allowable FDP was cut by the entire time spent in the WOCL, up to a maximum reduction of two hours. If the duty ended during the WOCL or passed through it completely, the FDP was reduced by half the time spent in that window.

These provisions were meant to recognise human limits and ensure pilots were not pushed to fly when their bodies were naturally least alert.

A senior airline pilot associated with unions and associations, who played a key role in pushing for stronger Flight Duty Time Limitation (FDTL) norms, outlined the chronology that led to the DGCA notifying the revised rules under the Civil Aviation Requirement (CAR) in January 2024.

Speaking to Newslaundry on condition of anonymity, he said, “India followed ICAO standards for flight duty and rest until the DGCA formally introduced FDTL in 2011, based on the Naseem Zaidi Committee report of 2010. Soon after, private airlines began routinely seeking variations to extend duty hours for specific flights. What were meant to be exceptional approvals, such as stretching an eight-hour duty to eight hours and 15 minutes, were gradually formalised as annexures to the 2011 CAR…Over time, repeated airline-driven variations diluted the original safeguards.”

“By 2017, pilot bodies like the IPG and the Federation of Indian Pilots (FIP) concluded that only a comprehensive revision could address the damage. After multiple consultations, the DGCA released a draft CAR in January 2018, prompting nearly 2,400 pilots to submit detailed objections and recommendations. When the final CAR was notified in April 2019 and enforced from May 1, most of these inputs were ignored. A formal representation was addressed to DGCA which again went ignored, leaving pilot bodies with little choice but to approach the courts.”

Although the legal battle was long and frustrating, pilot groups persisted. In 2022, they proposed to the court that out-of-court discussions with the DGCA be allowed. This led to structured negotiations beginning in 2023 at the DGCA office near Safdarjung Airport, involving pilot bodies, DGCA officials and airline operators, even as the case continued in court. The process culminated in a January 2024 Delhi High Court order directing the implementation of revised FDTL norms.

All airlines agreed before the court to implement the new rules in phases by July and November 2025. 

However, IndiGo struggled to comply, as seen in the latest fiasco.

The pilot further alleged, “IndiGo has opposed stricter FDTL norms from the beginning because proper implementation would require hiring more pilots and increasing costs. It even attempted to shift blame onto FDTL for recent operational chaos. In reality, IndiGo operates a large Airbus A320 fleet and was severely affected by a global grounding of thousands of Airbus aircraft for software upgrades following a JetBlue A320 flight-control incident linked to cosmic radiation in October 2025…IndiGo, which has around 240 Airbus aircraft, suffered large-scale cancellations due to this global Airbus issue, but instead of acknowledging that, the airline is trying to pin the blame on FDTL.”

India followed ICAO standards for flight duty and rest until the DGCA formally introduced FDTL in 2011, based on the Naseem Zaidi Committee report of 2010. Soon after, private airlines began routinely seeking variations to extend duty hours for specific flights. What were meant to be exceptional approvals, such as stretching an eight-hour duty to eight hours and 15 minutes, were gradually formalised as annexures to the 2011 CAR…Over time, repeated airline-driven variations diluted the original safeguards.

A senior airline pilot

Did 2019 changes help IndiGo?

It is important to note that the 2011 CAR was far more pilot-centric, with stronger safeguards for fatigue mitigation and rest, whereas the 2018 draft CAR for the proposed 2019 CAR marked a clear shift in favour of airline operators, offering greater scheduling flexibility at the cost of pilot wellbeing and flight safety.

The 2018 draft of the proposed CAR, which was notified in April 2019, also reduced the rest period provided to flight crew operating ultra-long-range flights in comparison to the 2011 CAR based on Naseem Zaidi Committee report.

A closer reading of the 2018 draft which was notified on April 24, 2019, shows a framework that weakens fatigue protection while giving airlines wide discretion to stretch pilot duties to near human limits.

In the 2019 CAR, the DGCA had not clearly defined continuous night operations or provided a uniform definition of night, leaving the rules open to exploitation. It restricts flight duty between 00:00 hours and 05:00 hours to no more than two consecutive days, but airlines can easily bypass this by rostering pilots at 05:01 for several days in a row. Each such duty still forces pilots to wake up around 02:30-03:00 in the night, repeatedly disrupting their sleep cycle. While operators remain technically compliant, the core objective of fatigue mitigation is defeated, exposing pilots to sustained circadian disruption.

It’s significant to note that pilot unions like Indian Pilots Guild (IPG), Indian Commercial Pilot Association (ICPA), and National Aviators Guild (NAG) came down heavily against the 2019 CAR. They wrote to DGCA that DGCA appears as a facilitator of exploitative practices that will only result in quick commercial gains for the airlines and their management at the cost of safety.

In a letter to DGCA in November 2018, IPG, ICPA and NAG wrote, “The illegal ‘variations’ to the existing FDTL regulations which had been introduced at the behest of various airlines have now been incorporated directly into the draft CAR itself, and creating a front door entry for the very unsafe practices. This CAR draft on FDTL, however, reads like a tailor-made tool created for airline owners to enable them to flog their pilots even more, in order to cut costs and generate profits at the cost of safety.”

It further said, “We have, over a sustained period, communicated to you both verbally and through our written submissions as to how airline operators have been misusing and interpreting various clauses of existing FDTL rules to suit their vested interests and are pressurising pilots to fly beyond safe limits at the cost of flight safety. None of our submissions have been given cognizance or taken into account by you in the draft CAR.”

Similarly, in May 2019, IPG in a letter to DGCA wrote that the 2019 CAR regulation dilutes fatigue mitigation safeguards and tilts heavily in favour of airline operators. It pointed out that acclimatisation is not clearly defined and should clearly require 48 hours at one location for a pilot's body clock to adjust, especially on east-west routes like Delhi-London-Newark. 

It strongly opposed cuts in unrestricted rest at layover (ULR) at outstation stops, particularly on India-USA Boeing 777 flights, where rest was reduced from 48 hours with two local nights to just 36 hours, calling the change unscientific and unsafe. IPG also objected to the DGCA oversight in unforeseen circumstances, warning that excluding the regulator allows airlines to pressure fatigued pilots into accepting longer duties.

Despite strong objections from multiple pilot bodies, the DGCA notified the regulation on April 24, 2019, and made it effective from May 1 the same year. 

The 2019 FDTL CAR remained in force for nearly five years and supported IndiGo’s maximum utilisation model. Aircraft typically fly 12-14 hours or more each day, supported by very short turnarounds ( less time on ground) of about 25–30 minutes, dense crew rostering close to duty-hour limits, and multi-sector duties in which crews may operate five to six short flights in a single duty period. The model relies heavily on six-sector patterns (six take-offs and landings), red-eye flights, early-morning departures, and shoulder-hour operations, flights scheduled just before and after peak hours, primarily in the early morning and late evening.

It’s significant to note that pilot unions like Indian Pilots Guild (IPG), Indian Commercial Pilot Association (ICPA), and National Aviators Guild (NAG) came down heavily against the 2019 CAR. They wrote to DGCA that DGCA appears as a facilitator of exploitative practices that will only result in quick commercial gains for the airlines and their management at the cost of safety.

What pilots have to say

Newslaundry spoke to several pilots, both current and former IndiGo employees, who said the airline often puts profits ahead of flight safety. They claimed that FDTLs are consistently stretched to their maximum.

A former IndiGo pilot, speaking on condition of anonymity, recalled a disturbing incident mid-flight. “We had just taken off from Mumbai and were transitioning to cruise when, while going through the procedures, I noticed the first officer had passed out in his seat. He regained consciousness moments later, and panicked. But I asked him to remain calm and relax for a while,” he claimed. “After landing, we spoke at length. The first officer revealed he was under severe stress due to a family issue and was also badly fatigued. He had requested the rostering team not to schedule him for the flight, but despite this, he was assigned the duty and had to operate as he was indirectly threatened with consequences.”

Another pilot claimed, “When pilots are too fatigued to fly safely, they report sick. We get 12 sick days a year, but if you cross that limit, the company starts deducting 1.5 times your daily salary and places you under the Pilot Dependability and Disciplinary Control Programme. Once you are put on that programme, privileges like staff travel and bonuses are taken away. First, they push you to overwork, and then they target you for reporting sick because of fatigue.”

Documents reviewed by Newslaundry show that in 2022, IndiGo pilot Capt Shubojit Chatterjee repeatedly raised concerns about fatigue on six-sector flights and was eventually terminated. Six-sector flying means a single duty with six stops involving multiple landings and take-offs.

In December 2021, he reported fatigue during the fourth sector of a six-sector duty. Despite completing four sectors, the airline recorded the day as full sick leave. In January 2022, he was flagged for a Flight Operations Review (FOR) for refusing six-sector duties during standby. When he asked to be removed from the review, citing fatigue risks, he was allegedly summoned to meetings where senior officials pressured him to accept six-sector patterns and warned of termination.

In April 2022, during another six-sector duty, Chatterjee reported fatigue during the fifth sector and was taken off the sixth, later writing that continuing such patterns posed a safety risk. Despite this, he continued to be rostered on the same fatigue-inducing pattern. In April 2023, after again requesting reassignment due to repeated fatigue reports, he was called to a meeting with top airline officials and told to either accept six-sector flights or resign. When he refused on safety grounds, he was taken off flying duties and terminated within a month. Chatterjee later complained to the DGCA, alleging he was fired for raising fatigue and safety concerns, but received no response.

A captain-rank pilot currently serving with IndiGo claimed, “Early reporting times required pilots to wake up as early as 02:30 or 03:00, combined with long duty hours disrupting normal sleep patterns and the body clock. Repeated six-sector rosters cause cumulative fatigue, especially when they are assigned on consecutive days.

"Despite that, pilots continue to fly under pressure, because reporting fatigue or calling in sick often brings scrutiny or penalties. Earlier FDTL rules allowed up to six night landings, but the new FDTL which came in January 2024 limits this to two, which is a good change.”

Captain Sohil Handa said, “By engaging with senior officials in the ministry and the DGCA, airlines have pushed for FDTL rules tailored to maximise profits. The 2019 CAR was designed to extract the maximum output. IndiGo, in particular, used this CAR to overwork pilots and generate large profits by flying more aircraft with the least possible crew.”

Capt C S Randhawa, president of Federation of India Pilots, said, “Five years back, the last flight of IndiGo used to land by around 12.30 in the night. Now 35 percent of its flights are scheduled in the night, which means they get maximum dispensation of the night grades. IndiGo has exploited the 2019 CAR to the fullest…The recent fiasco of IndiGo is a direct consequence of IndiGo’s prolonged and unorthodox lean manpower strategy across departments, particularly in flight operations. Despite the two-year preparatory window before full FDTL implementation, the airline inexplicably adopted a hiring freeze, entered non-poaching arrangements, maintained a pilot pay freeze through cartel-like behavior, and demonstrated other short-sighted planning practices….It’s important to understand that new FDTL regulations for pilots are being adopted by all other airlines except IndiGo, which even tried to blame it for its personal benefits.”

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