Within DGCA Limits — What India’s Own FDTL Documents Show

By Capt. Amit Singh, FRAeS • Founder, Safety Matters Foundation

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.