Two Indian pilots died of cardiac arrest in 24 hours. The phrase used to explain their deaths is the same phrase that will explain the next one.

On the morning of 29 April 2026, Capt. Tarundeep Singh of Air India was found dead in a hotel room in Bali. He was around 40, on his scheduled crew rest after the previous evening’s Delhi–Denpasar flight. The cause was reported as cardiac arrest. The next day, Capt. Arjun Naidu of Akasa Air, 44 years old, died of a heart attack during a training session in Bengaluru. ALPA India’s letter to the Director General of Civil Aviation, dated 1 May 2026, recorded both as having died “in the line of duty.”

Two Indian commercial pilots. Both under 45. Both, by their employers’ statements, within DGCA limits. Both had passed their statutory medical examinations a few months earlier. Neither had any known pre-existing condition.

This piece does not make a final medical finding on the cause of death of either pilot. That is for inquest and inquiry. What I want to address is the regulatory framework inside which both deaths occurred, because the documents the Directorate General of Civil Aviation released only after the Central Information Commission ordered them released show, in the regulator’s own ink, why within limits and safe to fly are not the same sentence.

In October 2023, the DGCA presented an internal Impact Analysis to the Hon’ble Minister of Civil Aviation. The document — a 24-slide PowerPoint — examined ten proposed pilot-fatigue reforms. The regulator’s own experts concluded, on slide 11, that all ten could be adopted “without affecting flight operations and would not hamper growth of aviation in India.” Three months later, the press release the Ministry issued adopted four of the ten. As of April 2026, after carrier-specific exemptions granted between October 2025 and February 2026, only two of the original ten remain in unrestricted force.

The press release said the reforms reflected “extensive data analysis.” The internal file does not support the later public framing that safety reform and aviation growth were in unavoidable conflict. The regulator’s analysis told it ten reforms were operationally feasible. The press release announced four. Within DGCA limits is the residual ceiling left after that filtering.

The 2025 fatigue-report data each operator has now filed with the regulator settles the rest of the question. Air India received 1,578 fatigue reports from its pilots in 2025 and rejected 860 of them — a 54.5% rejection rate. IndiGo received 8,721 reports and rejected 8,449 — a 96.9% rejection rate. The IndiGo column header, reproduced verbatim from the operator’s own statutory submission, classifies the rejected reports as “Fatigue Reports Rejected (Perceived).” The operator’s framing, on a regulatory filing, is that pilot fatigue is imagined ninety-seven per cent of the time.

Air India Express — the short-haul subsidiary of the same Tata-owned parent — accepted every single one of the 278 fatigue reports its pilots filed in 2025. The same Indian pilot training pipeline. The same Class 1 medical standards. The same DGCA. The acceptance rate ranges from 0% rejection to 96.9% rejection depending on which operator the pilot happens to fly for. The data are more consistent with operator-level screening, rejection or under-reporting effects than with a true absence of fatigue. Pilots are not the variable. Operator policy is.

In Air India’s case, the policy has a mechanism. Since September 2024, a pilot’s fatigue report is marked initially as sick leave on the crew portal. If the Fatigue Committee subsequently rejects the report, the entry remains classified as sick leave. An Air India narrow-body pilot has six sick days a year. Two or three rejected fatigue reports exhaust the entire annual entitlement. Pilots learn the policy. They file fewer reports. The non-punitive principle that the DGCA’s own Civil Aviation Requirement enshrines (Para 4.10.2) is, on this mechanism, materially difficult to defend.

There is a deeper failure underneath the policy choices. The DGCA Civil Aviation Requirement Section 7, Series J, Part III, §8.1 permits a pilot to be rostered for up to 60 hours of duty in any 7 consecutive days. The World Health Organization and the International Labour Organization, in their May 2021 Joint Estimate of the Work-related Burden of Disease, found that working 55 or more hours per week is associated with a 35% higher risk of stroke and a 17% higher risk of dying from ischemic heart disease. India’s regulatory ceiling for its commercial pilots sits five hours above the international scientific threshold for elevated cardiovascular mortality.

ICAO Annex 6, Part 1, Standard 4.10.6 requires that prescriptive duty-time limits be based on scientific principles and knowledge. The international scientific consensus on the maximum Flight Duty Period for night-encroaching duty — established by the 2008 EASA-commissioned Moebus Report, confirmed by EASA’s own 2018 effectiveness review, and reinforced by the NASA Ames Fatigue Countermeasures Group — is 10 hours. ICAO Doc 9966 requires that any State adopting prescriptive limits beyond the science-aligned threshold publish an equivalent scientific derogation analysis demonstrating, with bio-mathematical modelling, that conditions in its jurisdiction make the higher limit safe.

India has not, on the public record, published any such analysis. The CAR permits FDPs of up to 13 hours (2-pilot, daytime), 14–18 hours (augmented), and 21 hours (Ultra-Long Range). The Indian limit therefore stands on no documented scientific basis other than the ministerial signature on the Civil Aviation Requirement.

The structural reason this can happen is that the DGCA is not, in India, a statutorily independent regulator. It is a subordinate office of the Ministry of Civil Aviation. The Director General reports administratively up the line to the Secretary, MoCA, and onward to the Hon’ble Minister. Promotions, postings, parliamentary answers — and the political signal on a contested rule — travel down the same line. Globally, mature aviation safety regulators are statutorily independent civil aviation authorities. The Civil Aviation Authority of India Bill, drafted to convert the DGCA into a statutorily independent CAA on the global model, has been pending without passage for over a decade.

The ICAO USOAP audit of 2022 confirms the structural cost. India’s headline Effective Implementation score is 85.65%. The audit’s sub-findings record 93 open protocol findings, a Support-area Safety Index of 0.98 — below the threshold for adequate regulatory controls relative to traffic volume — no overall State Safety Programme Foundation value, and 12 open findings concentrated in Critical Element 4 (Technical Personnel Qualification & Training) in Air Navigation Services. The 85.65% headline number does not refute the sub-findings; it averages across them.

Capt. Tarundeep Singh and Capt. Arjun Naidu were within DGCA limits. So is every Indian commercial pilot reading this. Further serious health events among working pilots are foreseeable on the trend lines documented above unless one or more of the components changes — the rule book brought into alignment with the international science, the carrier-specific exemptions ended, the fatigue-as-sick-leave mechanism withdrawn, the regulator’s data published proactively, and the Civil Aviation Authority Bill passed.

Within DGCA limits is a description of the ceiling, not of safety. It is what the regulator has bound itself to, not what the science says is enough. The country needs to stop letting the phrase do the work of an answer.

Capt. Amit Singh FRAeS is a senior commercial pilot, founder of Safety Matters Foundation — India’s independent aviation safety think tank — and author of mindFly: Human Follies & Malice in Aviation. This piece is published in the public interest. It does not make a final medical finding on the cause of death of any individual pilot.

Every October, the Indo-Gangetic Plain performs a quiet national arithmetic. Twenty million tonnes of paddy straw are set on fire in Punjab, Haryana and western Uttar Pradesh. The smoke travels south to Delhi. The airshed closes. Schools shut. Hospitals report a spike in respiratory admissions. The Supreme Court admonishes the states. The states admonish the Centre. The Centre commissions a committee. The rabi sowing begins. The smoke clears. The cycle waits for next October.

Eight months from now, on 1 January 2027, a second fire will start — one most Indians will never see. Every Indian international carrier will enter the mandatory phase of the Carbon Offsetting and Reduction Scheme for International Aviation. The offset liability through 2035 is projected at between one and a half and two billion US dollars.

These are the same fire. The first one produces the very feedstock that could extinguish the second. And India is currently on course to burn both ends.

This piece is not about whether Sustainable Aviation Fuel works. It works. It is certified under ASTM D7566, it is chemically indistinguishable from Jet A-1 at the tailpipe, and a Boeing 777 at FL370 cannot tell the difference. This piece is about a narrower and sharper question: of the Indian government’s announced SAF capacity build-out, what share of it uses the feedstock India actually has in abundance? The answer, as of April 2026, is approximately zero per cent.

The landscape, in one picture

India’s position on SAF is not an absence of activity. The government has announced targets. Indian Oil has commissioned a certified facility. BPCL has committed capital. Airlines have signed offtake agreements. What is missing is the arithmetic between the announced capacity and the target it is meant to meet.

The gap is not marginal. It is roughly three-fifths of the 2030 target. And every announced tonne of Indian SAF capacity through 2027 uses the same feedstock: used cooking oil, processed via the HEFA pathway. This is a specific strategic choice. It is also, at scale, the wrong one.

HEFA and ATJ — the two serious answers

There are eleven ASTM-certified pathways to Sustainable Aviation Fuel. Two account for essentially all commercial SAF production through 2030: HEFA (Hydroprocessed Esters and Fatty Acids) and ATJ (Alcohol-to-Jet). Two more — Fischer-Tropsch and Power-to-Liquid — are strategically important but do not operate at commercial scale in aviation fuel anywhere in the world today.

HEFA is commercial today, cheap, and fast. It uses used cooking oil, animal fat, and vegetable oils. It is also the pathway that runs out of feedstock at the exact blending percentage where India’s ambition is supposed to begin. India’s total used cooking oil supply, after accounting for existing biodiesel commitments, is around three to five hundred thousand tonnes per year — just enough to hit the 2030 5% target at theoretical maximum collection, with nothing left for the 2035 target or beyond.

ATJ uses ethanol from agricultural residue as its feedstock. It is technically immature at commercial scale — the LanzaJet facility in Georgia, USA, due online in late 2025, is the world’s first. It is capital-intensive, at roughly 2.5 times the cost per tonne of HEFA capacity. It is also the only pathway that can match the Indian feedstock base to Indian aviation fuel demand over the next twenty years.

This is not a minor engineering distinction. It is the central strategic choice that Indian SAF policy must make — and has not made.

The feedstock picture

The scale disparity between used cooking oil and crop residue is best shown visually. The KPMG report published in November 2025 cites 230 million tonnes of surplus agricultural biomass. The ICAO ACT-SAF feasibility study published the same year cites 140 million tonnes using a stricter definition. Either number dwarfs the used cooking oil supply by between two and three orders of magnitude.

India does not lack capacity. India lacks pathway capacity.

The distinction is crucial. In August 2025, Indian Oil’s Panipat refinery received India’s first ISCC CORSIA certification. Commercial production began shortly thereafter, targeting 30,000 tonnes per year of HEFA-pathway SAF from used cooking oil. Air India signed an offtake. The Minister of Civil Aviation announced it as a national milestone. All of this is true.

What is also true: that facility, at full design capacity, produces approximately six per cent of the 2030 5% blend target. One facility is not a plan. It is a prototype. And every additional announced Indian facility through 2027 — BPCL’s commitments across Mumbai, Kochi, and Bina; MRPL’s Mangalore plant — uses the same HEFA pathway on the same constrained UCO feedstock base.

The first cellulosic facility in India, IOC’s 86,800-tonne LanzaJet ATJ plant at Panipat, is scheduled for March 2028. That date depends on LanzaJet’s first-of-a-kind commercial facility in Georgia, USA, which was itself delayed more than a year. India’s entire cellulosic SAF hope through 2028 is anchored to a single US startup’s technology that has not yet demonstrated commercial reliability anywhere in the world.

The four-column bill India already pays

Aviation policy is usually discussed in the register of carbon and trade. For India specifically, the correct register is also public health. The twenty million tonnes of paddy straw burned in Punjab and Haryana each October is the single largest source of particulate matter in the National Capital Region during the burn window — and the NCR airshed contains some thirty million people whose respiratory systems bear the cost.

The burden of not acting falls into four separate budgets across four separate ministries — aviation (offsets), health (NCR healthcare), agriculture (foregone farmer income), and petroleum (imported fuel). No single minister sees the aggregate. The burden of acting would fall on a single coordinating decision. That is the asymmetry at the heart of the policy paralysis.

The order-of-magnitude estimate is approximately ₹1.2 lakh crore per year in avoidable cost, split roughly as: NCR healthcare ~₹1 lakh crore, foregone farmer income ~₹19,000 crore, CORSIA offset outflow ~₹1,500 crore, plus foregone fuel import savings. A domestic cellulosic SAF industry, at scale, would convert somewhere in the range of ₹1 lakh crore per year of net cost into ₹40,000 crore per year of net value — farmer income, fuel substitution, carbon credit exports. The full arithmetic is in the PDF report.

Why hydrogen is not the answer this decade

Any complete analysis must address hydrogen-fuelled aviation. Hydrogen aviation is real, it is being developed by Airbus under the ZEROe programme with entry into service targeted for the mid-2030s, and it will eventually play a role. It is also, for the CORSIA-era question this piece addresses, the wrong conversation.

Hydrogen aircraft require an entirely new airframe, new engines, new fuel storage, new airport infrastructure, and new regulatory certification. Short-haul entry into service targets the 2035 window. Long-haul hydrogen aviation is not in any credible industry roadmap before 2050. For the 2027 CORSIA mandatory phase, hydrogen is irrelevant. For the 2030 blending target, hydrogen is irrelevant.

Where the hydrogen conversation does become useful is on Power-to-Liquid (PtL) SAF, synthesised from green hydrogen and captured CO₂. India’s National Green Hydrogen Mission target of five million tonnes by 2030, if realised, could underwrite a meaningful PtL SAF industry — but that linkage is entirely unmade in current Indian policy.

What India should actually be doing

The specific shape of India’s policy absence can be described in five items, each of which has a counterpart in jurisdictions that have succeeded, and each of which requires a coordinating decision rather than new legislation.

1. A statutory blending mandate under the Aircraft Act, converting the indicative 1%/2%/5% targets into binding compliance. Precedent: EU ReFuelEU.
2. A Contract-for-Difference price-support mechanism, transferring SAF price risk from refiner to state. Precedent: UK (2024 launch).
3. A cellulosic SAF viability gap fund of approximately ₹10,000 crore over five years, competitively awarded to integrated residue-to-SAF facilities. Precedent: US IRA 40B; Japan Green Transition Bonds.
4. An aviation-specific domestic carbon credit registry, retaining offset revenue within India. Precedent: Brazil’s RenovaBio.
5. A technology-transfer risk underwriting mechanism for first-of-kind facilities dependent on overseas technology providers. Precedent: UK Advanced Fuels Fund.

Each of these can be announced in a Union Budget. None require Parliamentary approval. All of them have been recommended in whole or part by the ICAO ACT-SAF Feasibility Study (2025) and the KPMG Fuelling a cleaner sky (November 2025) reports commissioned or received by the Indian government.

The closing argument

The seat-back safety card on every aircraft instructs passengers that, in the event of a loss of cabin pressure, oxygen masks will drop from the overhead panel. A passenger must secure their own mask before assisting others. A person who cannot breathe cannot help anyone else breathe either.

India’s aviation policy is currently reaching for the overhead panel. CORSIA is the cabin descending through ten thousand feet. The mask is there. The oxygen is there. The feedstock is in the fields. The refineries are standing ready to be upgraded. What is missing is the last mechanical step — the hand that pulls the mask down and secures it.

That step is, in the Indian institutional context, a single coordinating decision from the Prime Minister’s Office, authorising the Ministry of Civil Aviation to issue a statutory blending mandate under the Aircraft Act, backed by a Contract-for-Difference price-support mechanism administered by the Ministry of Petroleum and Natural Gas, and a viability gap fund for cellulosic SAF administered jointly with the Ministry of Agriculture. None of these require new legislation. All of them require the coordination of existing instruments.

The policy architecture is not missing. The decision is.

We are building the wrong kind of plant fast and the right kind of plant slow. We are paying for air quality in hospital bills and for carbon in forex reserves, when we could be paying farmers and saving both. We are treating as separate four problems that are, in their economic substance, one problem.

The fire we cannot see is the more expensive one. It is the fire of institutional inaction — the fire that burns, slowly, at the base of every policy paralysis that leaves a national opportunity uncollected. That fire has been burning for at least five years, since the original CORSIA reservation was filed. It is burning hotter now, because the deadline is closer. And it is, unlike the one over Delhi, entirely inside the government’s capacity to extinguish.

Capt. Amit Singh, FRAeS, is a Boeing 777 and Airbus A320 captain with over 18,000 flight hours. He is the founder of Safety Matters Foundation (safetymatters.co.in), hosts the mindFly Katha podcast, and writes on aviation safety, human factors and regulatory policy. Views expressed are personal.

Primary sources: ICAO ACT-SAF Feasibility Study for India (van Dyk & Deshpande, 2025); KPMG India Fuelling a cleaner sky (November 2025); DGCA India CORSIA Seminar Presentation; Lok Sabha Unstarred Question No. 4012 (12 December 2019); Argus Media coverage of IOC Panipat ISCC certification (21 August 2025); IATA Net Zero Progress Report 2024; ICAO Default Life Cycle Emissions Values for CORSIA Eligible Fuels (November 2025); ASTM D7566 and D1655 specifications.

If you want to understand Sustainable Aviation Fuel in one sentence, borrow a picture from the Indian kitchen.

Crude oil is milk. Refine it and you get Jet A-1, the kerosene that has flown the world for seventy years — the butter of aviation. Now take that butter and clarify it further: strip the water, the milk solids, all the stubborn fractions that scorch and smoke. What you get is ghee. Purer. Cleaner. Burns hotter, stores longer, and — to anyone eating the paratha — utterly indistinguishable from the butter it came from.

SAF is the ghee. And the aircraft burning it cannot tell the difference.

This is the single most important fact about SAF, and it is the one most consistently missed in the policy conversation. A Boeing 777 at FL370 does not know whether the fuel crossing its high-pressure pump came from a Texan oilfield or a Pune sugar refinery. It does not need to know. The certification standard — ASTM D7566 — was written precisely so that once a blended batch has been tested, it is redesignated under ASTM D1655 as ordinary Jet A-1. Same freeze point. Same flash point. Same energy density. Same lubricity. The fuel that leaves the refinery gate is, by specification, the fuel the aircraft was always certified to burn.

For the passenger in 14A, nothing changes. For the atmosphere, everything does.

Why only half the ladle?

And yet — and this is where every SAF conversation eventually runs into the same wall — the current global standard permits a maximum blend of only fifty per cent. Pour in one drop more and the fuel is no longer certified. For algae-derived (HC-HEFA) and synthesised iso-paraffin (SIP) pathways, the ceiling is even lower: ten per cent. Why? If SAF is chemically equivalent kerosene, why the arbitrary fraction?

The answer sits not in the engine, but in the seals, hoses and fuel-system elastomers of the thirty thousand aircraft already in service.

Conventional Jet A-1 contains between eight and twenty-five per cent aromatics — complex ring-shaped hydrocarbons, the benzene family. Aromatics are the moody cousins of the paraffin molecules that actually release the energy. They contribute almost nothing to combustion efficiency. They are, in the cold accounting of propulsion, an inconvenience.

But they do one job that nothing else has yet replicated. They swell rubber.

Every aircraft fuel system carries a spiderweb of nitrile O-rings, elastomeric seals and flexible couplings. These seals are designed — at the certification level of the Boeing 737 Classic and the Airbus A320ceo, of the CFM56 and the V2500, of every fuel bowser on every apron from Bahrain to Bengaluru — to sit in contact with a fuel that contains aromatics. The aromatic molecules slip into the elastomer matrix and keep the rubber plump and pliant. Without them, the seals shrink. A shrunk seal leaks. A leak on the ground is a fire risk; a leak in flight is worse.

Most SAF pathways — HEFA, Fischer-Tropsch SPK, alcohol-to-jet — produce a fuel that is almost entirely paraffinic. Zero aromatics, or close to it. Chemically elegant. Operationally, for a legacy fleet, a problem. Industry testing indicates that aromatics content must not fall below roughly eight per cent for seals to remain dimensionally stable.

Run the arithmetic. Blend a paraffinic SAF with zero aromatics against a conventional Jet A-1 averaging around seventeen per cent aromatics, at a fifty-fifty ratio, and you arrive at 8.5 per cent — just above the safety line. Push to sixty per cent SAF and you drop below the threshold. That is the whole story. The fifty per cent cap is not a political concession or an environmental half-measure. It is a rubber problem.

The 50% cap is arithmetic, not policy: 17% aromatics in conventional Jet A-1, diluted 50:50 with zero-aromatic SAF, lands at 8.5% — just above the seal-integrity floor.

There are other considerations — lubricity, cold-flow behaviour at the minus-47°C freeze specification, thermal stability in a hot wing tank on a Doha afternoon — but aromatics are the binding constraint. Work is under way on bio-aromatics that would let paraffinic SAF self-supply the compound it needs, and on new elastomer formulations for clean-sheet aircraft that never needed the aromatics in the first place. Both Airbus and Boeing have flown single-engine, hundred-per-cent SAF test flights. The cap will eventually rise. But for the fleet flying tonight, fifty per cent is the honest limit of current engineering.

The money question

Ghee costs more than butter. SAF costs more than Jet A-1 — currently two to five times more, depending on feedstock, pathway and geography. That premium is not a conspiracy, it is a consequence of scale: the global SAF industry produces a rounding error against the three hundred billion litres of jet fuel the world burns each year. Supply is constrained, feedstock logistics are immature, and capital is still being deployed cautiously.

In a competitive commodity market, a twice-priced substitute cannot sell itself. Airlines will not voluntarily pour more expensive fuel into wings already operating on razor-thin margins. Which is why the entire climate calculus of aviation rests not on SAF’s chemistry, but on SAF’s economics. And economics, in aviation, follows regulation.

Enter CORSIA.

The scheme India argued against, then had to accept

The Carbon Offsetting and Reduction Scheme for International Aviation was adopted at the ICAO Assembly in 2016. Its architecture is straightforward, if uncomfortable: international aviation emissions are capped at eighty-five per cent of 2019 levels, and any airline growing beyond that line must either (a) burn eligible SAF, or (b) buy carbon offsets to cover the excess. Monitoring begins for everyone. Offsetting begins in phases.

The scheme was always going to roll out in two stages — a voluntary phase from 2021 to 2026 in which states could opt in, and a mandatory phase from 2027 to 2035 in which they could not opt out. India, along with China and Russia, declined the voluntary phase. The argument was made cleanly and, frankly, correctly, at the 40th ICAO Assembly in 2019 and again on the floor of the Lok Sabha that December, when the Minister of State for Civil Aviation, in reply to Unstarred Question No. 4012, stated in terms that CORSIA’s design was “not fair to the airlines of developing states who have potential to grow much more after 2020 compared to the airlines of developed states.” India filed reservations with ICAO in both 2016 and 2019.

There was substance to that grievance. A scheme baselined on 2019 emissions locks in the historical advantage of mature aviation markets and penalises the growth that developing markets still need. An American carrier in 2019 was already flying close to its asymptote; an Indian carrier in 2019 was flying twenty per cent of what it projected to fly by 2035. The offsetting bill, calibrated to growth above the baseline, would therefore fall disproportionately on the newcomers.

And yet: the argument was lost. Not in the corridors of ICAO Montreal, but in the arithmetic of membership. CORSIA’s mandatory phase applies, from 1 January 2027, to every ICAO member state above a 0.5 per cent share of global international Revenue Tonne Kilometres. India crosses that threshold several times over. The reservation made India’s position clear. It did not exempt India from the scheme.

So here we stand, eight months out. On 1 January 2027, every Indian operator flying internationally — IndiGo, Air India, Air India Express, Akasa, SpiceJet — enters the mandatory phase. The monitoring has been in place since 2019. The bill lands in 2028 for the 2027 compliance year.

What the bill actually looks like

The DGCA’s own projection, presented at the ICAO CORSIA Seminar, shows Indian international CO₂ emissions growing at 7.8 per cent annually — from 6.28 million tonnes in 2022 to a projected 21.48 million tonnes by 2035. The CORSIA baseline for India, set at 85 per cent of 2019 emissions, is 7.17 MT. The gap between projected emissions and the baseline — the offset-eligible growth — compounds every year.

To put that in numbers an airline treasurer understands: IATA has projected industry-wide CORSIA compliance costs of $1.7 billion for 2026 alone, with cumulative costs through 2035 approaching ten billion dollars. Offset prices, currently around $22 per tonne of CO₂, are forecast by several market analysts to rise to $30–45 by 2030 as the mandatory phase tightens demand against a constrained supply of eligible credits. For the Indian industry, a back-of-the-envelope calculation on the DGCA’s own growth projections puts the cumulative offset liability through 2035 somewhere north of one and a half billion dollars — and that is the optimistic end.

What India should actually be doing

India’s indicative SAF blending targets — one per cent in 2027, two per cent in 2028, five per cent by 2030 — are modest by European standards (the ReFuelEU mandate hits six per cent by 2030 and seventy per cent by 2050) and extremely modest relative to what CORSIA arithmetic will demand. They are a floor, not a ceiling, and even the floor requires domestic SAF production capacity that India does not yet have.

The country has the feedstock. India generates used cooking oil, agricultural residue and municipal solid waste on a scale that could comfortably support a million-tonne SAF industry within a decade. What it lacks is the refinery infrastructure, the certification pathway throughput, and the offtake contracts that would de-risk investment. NABCB’s accreditation framework is in place; two Indian verification bodies are operational; the MoU with ISCC for CORSIA sustainability certification is signed. The scaffolding exists. The building does not.

If there is one argument I would press on Raisina Hill and in the corner offices of Bharat Petroleum, Indian Oil and Reliance, it is this: every litre of SAF India imports from 2027 is a litre of offset cost India is paying to somebody else’s refinery. Every litre India produces domestically is both a climate instrument and an import substitution. The same argument that justified the ethanol blending programme for petrol applies in its entirety to the aviation fuel stream. The numbers are, if anything, larger.

India’s CORSIA position was honourable in 2016 and defensible in 2019. In 2026, with the mandatory phase eight months away, it has to be operationally complete. That means scaled domestic SAF production, clear price-support mechanisms for the blending years of 2027 to 2030, and a sovereign position in the carbon offset market so that Indian airlines are not forced buyers in a sellers’ market dominated by credits from Brazilian forestry and Kenyan cookstove projects.

The alternative is to pay the bill in foreign exchange while our crops are burned in the fields of Punjab.

The closing thought

The seat-back safety card on every aircraft reminds passengers that in the event of a loss of cabin pressure, they should fit their own oxygen mask before helping others. CORSIA is the moment the mask has dropped. The voluntary phase was the announcement; the mandatory phase is the cabin descending through ten thousand feet.

India can breathe through this. The fuel is already certified. The engineering is already understood. The ghee is already on the stove.

What remains to be decided is whether we produce it ourselves, or send our money abroad to buy somebody else’s.

Capt. Amit Singh, FRAeS, is a Boeing 777 and Airbus A320 captain with over 18,000 flight hours. He is the founder of Safety Matters Foundation (safetymatters.co.in), hosts the mindFly Katha podcast, and writes on aviation safety, human factors and regulatory policy. Views expressed are personal.

Sources: ASTM D7566 / D1655 specifications; ICAO CORSIA SARPs (Annex 16 Vol. IV); DGCA India CORSIA Seminar presentation; Lok Sabha Unstarred Question No. 4012 (12 December 2019); IATA CORSIA compliance cost projections; Fastmarkets CORSIA market outlook (September 2025); ICAO CORSIA Fact Sheet (December 2025).

The MiG-21 has been retired. A Tejas has fallen in Dubai. Between them lies a causal pattern the Indian Air Force has the evidence, the science and the institutions to address — if it chooses to.

By the Safety Matters Foundation — 19 April 2026

On 26 September 2025, at Chandigarh Air Force Station, the Indian Air Force retired its last MiG-21 Bison after sixty-two years of service. Air Chief Marshal A.P. Singh flew historic Bison CU2777 on the type’s final sorties. The ceremony drew the Defence Minister and the Chief of Defence Staff. Two months later, on 21 November 2025, Wing Commander Namansh Syal was killed when his HAL Tejas nosedived into the tarmac during a flying display at the Dubai Airshow. It was the first Tejas fatality, and the second Tejas hull loss in twenty months.

Between those two events sit ten years of accidents and near-misses we have compiled, cross-checked and counted: sixty-five documented incidents, ninety-three lives, the death of a Chief of Defence Staff in the Nilgiris, the first combat aircraft losses India has taken since Kargil, a friendly-fire shootdown of an Indian helicopter by an Indian surface-to-air missile, a fatal mid-air collision at the country’s premier airshow the day before it opened, the disappearance of a transport aircraft with twenty-nine aboard that was found only eight years later at three-and-a-half kilometres under the Bay of Bengal, and the quiet, cumulative attrition of fighter and trainer airframes that ministers patiently recite to Parliament each year as “accident rates” expressed in decimals.

The numbers have, in fairness, improved. In the Defence Ministry’s telling, the IAF’s accident rate has fallen from approximately 0.9 per 10,000 flight hours in 2020 to 0.2 per 10,000 by 2024. Converted to the international convention — per 100,000 hours — that is a move from roughly nine to two. It is real progress. The US Air Force, for comparison, reported 1.9 Class A mishaps per 100,000 hours in fiscal year 2024, a four-year high in its own trend line. On headline rate alone, the IAF has closed most of a historical gap.

So the question is no longer “is the IAF getting safer?” It is. The question is what — specifically, programmatically — remains to be done. And here the decade’s record tells a more instructive story than the rate line does.

What the cases have in common

On 19 February 2019, the day before Aero India 2019 opened at Yelahanka, two BAe Hawks of the Surya Kiran Aerobatic Team collided during a rehearsal. Wing Commander Sahil Gandhi was killed. The preliminary finding pointed to pilot error during a mirror manoeuvre — a classic skill-based error at the end of a high-tempo rehearsal week.

On 27 February 2019, within ten minutes of takeoff from Srinagar, an IAF Mi-17V-5 of 154 Helicopter Unit was hit by an IAF SPYDER surface-to-air missile. Six airmen and one civilian on the ground were killed. The helicopter’s IFF transponder had been switched off; under the tempo of the ongoing engagement with Pakistani fighter packages, the radar return was misclassified as a possible hostile drone. Air Chief Marshal R.K.S. Bhadauria subsequently called it “a big mistake.”

On 1 February 2019, two test pilots — Squadron Leaders Samir Abrol and Siddhartha Negi — had already been killed when an upgraded Mirage 2000 crashed on takeoff at HAL Bengaluru during a user acceptance flight. The Court of Inquiry pointed to a software or control anomaly tied to the HAL upgrade, compounded by the failure of a runway arrester barrier — a double-failure event whose causes span the HAL/IAF interface rather than sitting in either organisation alone.

And on 8 December 2021, a Mi-17V-5 carrying Chief of Defence Staff General Bipin Rawat, his wife, Brigadier L.S. Lidder and eleven others struck a hillside near Nanjappachatiram in the Nilgiris in degrading weather on a short transit to the Wellington staff college. Thirteen died at the scene. Group Captain Varun Singh — who a year earlier had won the Shaurya Chakra for recovering a stricken Tejas after a triple flight-control-channel failure — was the sole temporary survivor and died of his injuries a week later. The IAF’s Court of Inquiry, and a rare public finding by the parliamentary Standing Committee on Defence in December 2024, attributed the crash to Controlled Flight Into Terrain in adverse weather, with human factors at the crew level identified as the proximate cause.

These four cases — Yelahanka, Budgam, Bengaluru Mirage, Coonoor — are not mysterious. Each has a fingerprint that the published human-factors and cognitive-safety literature has been mapping for decades.

Yelahanka is skill-based error under time pressure: the sort of event every CRM module has covered since the 1980s, but which reads differently when you examine how rehearsal schedules, crew duty periods, and expectation violations interact in high-tempo demonstration flying.

Budgam is a level-two situational-awareness failure on the air-defence side: the operators perceived the return; the meaning was misclassified under combat stress, task saturation and fragmented IFF discipline. Contemporary cognitive-safety literature describes exactly this pattern under the heading of “fratricide prevention” and has operational countermeasures.

The Bengaluru Mirage crash sits in the literature on automation surprise and post-upgrade verification-and-validation: when software changes the aircraft’s behaviour in ways the pilot’s mental model hasn’t caught up with, and when an administrative barrier (the arrester) is the only remaining line of defence.

Coonoor is plan-continuation bias in its purest operational form: the NASA-Ames review of thirty-seven investigated accidents found approximately seventy-five per cent of tactical-decision errors were plan-continuation decisions — the unconscious drive to press on with the original plan rather than return or hold. Landman and colleagues’ 2022 review in Frontiers in Physiology shows that rotary-wing operations produce spatial-disorientation incidence roughly 5.7 times higher than fixed-wing. In adverse weather in mountainous terrain, the Coonoor profile is precisely where that risk concentrates.

What these fingerprints have in common is not that the aircraft were old, or that maintenance was at fault, or that equipment failed, though each of those stories is also present elsewhere in the record. The common thread is that the human operating system — attention, expectation, decision-making under stress, mode awareness, spatial orientation — failed predictably, in ways that the science has characterised and the civil airlines and several allied air forces have been engineering around for more than a decade.

That is what we mean by cognitive safety.

The shape of a programme

A formal cognitive-safety programme is not exotic. Its components exist — and crucially, the Indian components already exist. The Human Factors Analysis and Classification System developed by Shappell and Wiegmann, now a US Department of Defense standard at version 8.0, is the accident-coding taxonomy the IAF should adopt. Endsley’s three-level situational-awareness construct has simulator-ready measurement instruments. Unexpected-event simulator training for startle and surprise is embedded in the US Navy, USAF and several NATO operational conversion syllabi. Threat and Error Management is the sixth-generation Crew Resource Management framework, with plan-continuation bias and automation complacency as named threats. Fatigue Risk Management Systems are codified in ICAO Annex 6 and deployed in commercial aviation worldwide.

But here is the point worth making in India: the two most important pieces of the puzzle are already ours.

The first is pSuMEDhA — Psychomotor Evaluation Designed for Aviators — an indigenous psychometric cognitive test battery developed at the Institute of Aerospace Medicine in Bengaluru. Thambidurai, Sharma, Sowgandhi and Biswal published the first comparative validation of pSuMEDhA against the international benchmark CogScreen-AE in the Indian Journal of Aerospace Medicine in late 2024. Their fifty-subject comparison found that pSuMEDhA’s Digit Symbol Substitution Test and CogScreen-AE’s Symbol Digit Coding produced congruent speed and accuracy measures (Pearson’s r = 0.6, p = 0.000) — in other words, on the canonical working-memory task, India’s home-grown battery performs on par with the international standard. pSuMEDhA also includes a Threat Perception and Estimation Test that CogScreen-AE does not offer — a module that produces a threat-index score directly relevant to the combat-cognitive scenarios Budgam and Operation Sindoor exemplify. The authors explicitly flag that pSuMEDhA’s flight-simulator validation is the natural next step. That step is a matter of institutional decision, not of science.

The second is Perceptiva Chakshu Yan — a Safety Matters Foundation research construct authored by Capt. Amit Singh FRAeS. In its ideation form (Proposal 1024-01, October 2024) Chakshu Yan was a real-time eye-tracking and near-infrared spectroscopy pilot-state monitor aimed at fixation, cognitive overload, and inadequate situational awareness — the three causal fingerprints we have already seen in Air France 447, Colgan 3407, Eastern 401, TransAsia 235, and, in the Indian record, in the Coonoor and Yelahanka events. Its peer-review iteration (Indian Journal of Aerospace Medicine, manuscript IJASM_15_2026) develops Chakshu Yan into a full methodological framework: a comparative modality review, a 2,400-subject synthetic-population simulation, a twelve-item Cognitive Load and Overload Questionnaire with strong psychometric properties, and a fieldable multimodal sensing stack — pupillometry, blink/gaze dynamics, heart-rate variability, respiration, and ambient-light normalisation — achieving modelled classification performance of macro-F1 0.84 in the primary configuration and 0.87 with fNIRS validation.

The two instruments are complementary. pSuMEDhA is a psychometric assessment administered off-line, producing a profile of an aviator’s cognitive capabilities that belongs at the selection and periodic-evaluation tier. Chakshu Yan is a real-time multimodal monitor administered during task performance, producing continuous estimates of workload and overload risk that belong at the simulator and, where headgear is acceptable, the operational tier. Neither substitutes for the other. Together, they approximate the two-tier cognitive-safety architecture the international literature converges on.

We would therefore put it this way. The IAF should establish a Cognitive Safety Branch, sitting between the Directorate of Flight Safety and the Institute of Aerospace Medicine, with five core functions. First, adopt HFACS 8.0 as the standard IAF accident-coding taxonomy and publish anonymised annual distributions. Second, accelerate the flight-simulator validation of pSuMEDhA so its sub-scores — threat perception, vigilance, psychomotor tracking — become routine inputs into aircrew training emphasis and re-currency decisions. Third, pilot Chakshu Yan at the operational-monitoring tier, beginning at the Air Force Academy and selected Operational Conversion Units’ simulators, with cross-construct validation against pSuMEDhA. Fourth, embed unexpected-event simulator scenarios targeting startle and surprise into operational conversion, and make plan-continuation bias an explicit element of TEM-grade CRM. Fifth, build an IAF-specific Fatigue Risk Management System with circadian and sleep-homeostatic modelling and wearable fatigue monitoring for high-tempo windows.

None of this is revolutionary. None of it is expensive at the scale of a fighter-procurement programme. All of it is evidence-based. And the two centrepieces — pSuMEDhA and Chakshu Yan — are already Indian.

The transparency dividend

There is a second argument for a programme of this shape, which has less to do with training and more to do with governance. Over the last decade the public record of the IAF’s safety performance has improved in one respect — ministerial replies to Parliament have become more regular and more numerate — while remaining sparse in another: Court of Inquiry findings rarely enter the public domain. The December 2024 Standing Committee report on Coonoor, with its explicit human-factors attribution, is the exception that proves the rule. Outside that case, almost every row in our register ends with “CoI ordered” and very little more.

There is a serviceable argument for operational-security discretion on investigation detail, especially in combat or border-related cases. There is not, in our view, a serviceable argument against a USAF-style annual Safety Statistical Abstract that publishes Class A-equivalent rates per 100,000 hours, disaggregated by platform and phase of flight, alongside an HFACS distribution that shows — anonymously — what the service is seeing and what it is learning. The USAF publishes this. The US Naval Safety Command publishes this. The UK Ministry of Defence publishes a more restricted but still public annual health-and-safety statistics report. In 2026 there is no meaningful reason the IAF could not publish a version of the same.

What we are not saying

We are not saying the IAF is unusually unsafe. The decade’s own rate line argues the opposite. We are not saying human error is everywhere or that technical faults have ceased to matter; the Porbandar Dhruv swashplate and the Nashik Su-30 post-overhaul losses are real airworthiness stories that need their own institutional response. We are not saying that any one case — Coonoor, Budgam, Yelahanka — is reducible to a single cognitive pattern; real accidents are always layered, and the HFACS framework exists precisely to preserve that layering.

What we are saying is simpler. The causal patterns visible in the decade’s record are the patterns the cognitive-safety field has characterised in detail. The instruments that would convert those patterns into targeted interventions already exist — some in allied services and civil aviation, and, crucially, two of the most important in India itself. pSuMEDhA, validated in 2024, belongs at the selection and evaluation tier. Chakshu Yan, conceptualised in 2024 and methodologically developed in the 2026 IJASM draft, belongs at the operational-monitoring tier. Together with the institutional base — the Institute of Aerospace Medicine, the Directorate of Flight Safety, TACDE — and an evidence base of sixty-five documented incidents over ten years, the IAF has everything needed to operationalise a programme. The MiG-21 has been retired. A chapter has closed. The cognitive-safety chapter is ready to be opened.

About this opinion piece

This is a Safety Matters Foundation opinion publication, released alongside the Foundation’s research paper Indian Air Force Safety, 2016–2025 (document no. SMF/RES/IAF-SAF/2026/001). The Foundation is not affiliated with the Indian Air Force, the Ministry of Defence, Government of India, or any aircraft manufacturer. This piece expresses the considered view of the Foundation’s safety research programme and is based on open-source material. Any errors or omissions are the Foundation’s; the Foundation welcomes corrections and clarifications from the service, its institutions, and the broader research community.

Citation: Safety Matters Foundation. The cognitive-safety moment India’s Air Force cannot postpone. Opinion paper, SMF/OPN/IAF-SAF/2026/002, April 2026. Contact:Admin@safetymatters.co.in