IndiGo: Crisis, compliance and consumer impact

Civil aviation plays an important part in India’s economic footprint. It is a sector where commercial operations are inseparable from regulatory oversight. Safety considerations, public interest, and commercial decision-making are closely intertwined, leaving limited room for error. Against this backdrop, the recent developments involving IndiGo, India’s largest airline by market share, warrant examination from the perspective of compliance, governance, and regulatory engagement in an industry where scale inevitably attracts scrutiny.

With a market share of approximately 63.6 per cent, IndiGo today occupies a dominant position in India’s aviation landscape. Its growth trajectory has been instrumental in expanding access to air travel across the country. Market leadership, however, carries heightened regulatory and public expectations. Operational disruptions, regulatory interventions, or governance-related concerns, however episodic, assume wider significance when they involve an airline of IndiGo’s scale, given the potential ripple effects across passengers, airports, and the broader aviation ecosystem.

In December 2025, India’s civil aviation sector witnessed significant operational disruption during the peak festive and holiday travel period. IndiGo cancelled a substantial number of flights over a span of several days, alongside widespread delays, leaving thousands of passengers affected across multiple airports in the country.

What began as isolated delays progressively escalated into a broader network-wide disruption, resulting in cascading operational challenges nationwide. This collapse was so widespread that basic operations broke down. Crew members were left at the wrong locations, baggage went missing and reached destinations even after flights were cancelled, and pilots waited at airports without assigned duties. Customer support systems were overwhelmed, with call centres failing under pressure. Passenger frustration was evident at airports, with protests and slogans raised against IndiGo inside terminal buildings.

This turbulence can be traced to the enforcement of revised Flight Duty Time Limitation (FDTL) norms, mandating extended pilot rest periods and tighter restrictions on night operations. FDTL norms are safety regulations issued by the Directorate General of Civil Aviation (DGCA) that govern the maximum duration of pilot duty hours, permissible flight time, limits on night landings, and mandatory rest periods. These norms are intended to mitigate pilot fatigue, minimise human error, and strengthen overall aviation safety, and are aligned with internationally recognised aviation standards.

Under the 2019 FDTL framework issued by the DGCA (Civil Aviation Requirement, Section 7, Series J PART III dated April 24, 2019), pilots were required to receive a minimum weekly rest of 36 hours and were permitted up to six night landings in a single duty period, allowing for longer duty hours and greater operational flexibility, particularly for night and multi-sector operations, thus allowing airlines to run dense schedules with fewer crew. However, findings from global accident investigations have consistently shown that fatigue can materially impair pilot performance and increase the risk of serious operational errors. Against this background, India’s earlier FDTL framework came to be viewed as outdated and insufficiently responsive to evolving safety expectations and workload realities, failing to adequately address the persistent and often understated risk of pilot fatigue.

The need for a revised FDTL regime traces its institutional genesis to a public interest litigation instituted before the Delhi High Court by three representative pilot bodies: the Indian Commercial Pilots Association, the Indian Pilots Guild (IPG), and the Federation of Indian Pilots (FIP). The petition challenged the adequacy of the 2019 FDTL framework, contending that it failed to sufficiently address pilot fatigue and seeking judicial intervention to strengthen safety and fatigue management standards (Indian Commercial Pilots Association & Ors. v. Union of India & Ors.).

Pursuant to this judicial scrutiny, the DGCA notified a revised and more stringent FDTL framework in January 2024 (Civil Aviation Requirement, Section 7, Series J PART III dated April 24, 2019, Rev. Jan 8, 2024). The updated regime significantly tightened regulatory controls over pilot duty hours, rest periods, and night operations, with the stated objective of enhancing safety and mitigating fatigue-related risks. Key safety measures introduced under the revised framework include a mandatory 48 hours of consecutive weekly rest for pilots, a reduction in permissible night landings to two per duty period, lower maximum duty hour thresholds, mandatory roster adjustments, and quarterly fatigue reporting requirements.

Following stakeholder consultations, the revised norms were rolled out through a phased implementation approach. Rather than being enforced in a single step, the DGCA staggered the implementation across two phases, effective from July 1, 2025, and November 1, 2025, to allow airlines a transition period to realign crew planning and operational systems.

By an order dated July 7, 2025, the Delhi High Court took note of the ongoing process of notifying the revised Civil Aviation Requirement (CAR) and directed all airlines to submit their updated FDTL schemes to the DGCA expeditiously and in any event within three weeks. The Court further granted liberty to the pilot unions to approach the judiciary in the event of non-compliance, delay, or deviation in the implementation of the revised norms. Airlines, therefore, had several months to prepare and adjust staffing and rosters. The first phase of implementation passed without major disruption. The second phase, which placed tighter limits on night operations and crew use, proved more challenging and revealed operational stress within IndiGo.

IndiGo attributed the disruption to a combination of factors converging at the same time, including fog-related delays, peak seasonal travel demand, technical issues, air traffic congestion, and the tighter FDTL limits. Given IndiGo’s high aircraft utilisation, even a single delay tends to cascade rapidly across the network, triggering a wider nationwide disruption.

The Pilots’ Association of India offered a sharply different account of events. According to pilot representatives, the airline had advance notice that the revised FDTL norms would necessitate additional pilots and standby crew, but staffing levels were not increased proportionately. They contend that prolonged fatigue among existing crew led to simultaneous leave by a significant number of pilots, while the absence of an adequate reserve workforce limited the airline’s ability to absorb operational shocks. In their view, these factors compounded the disruption and allowed the situation to escalate, raising concerns about preparedness and fatigue management under the new regulatory framework.

In response to the widespread disruption and its impact on passengers, the government, through the DGCA, stepped in with a series of immediate regulatory measures. These included a one-time temporary relaxation of the revised FDTL norms to stabilise operations and the imposition of emergency fare caps to protect consumers from price escalation during the period of disruption. In addition, the Ministry of Civil Aviation ordered a high-level inquiry into the disruption (MCA press release dated December 5, 2025).

Multiple petitions were filed before the Supreme Court of India and various High Courts in relation to the flight cancellation crisis, with the Chief Justice of India observing that the matter was a serious one. In parallel, the IPG and the FIP approached the Delhi High Court by initiating contempt proceedings against the Directorate General of Civil Aviation for granting exemptions to IndiGo from the revised FDTL norms (Federation of Indian Pilots v. Faiz Ahmad Kidwai). The pilot bodies contended that disruption stemmed from the airline’s own operational decisions rather than external constraints, and alleged that the DGCA and a senior civil aviation official had wilfully disregarded the High Court’s earlier directions. They further asserted that there was no industry-wide shortage of pilots or crew, noting that airlines had been informed of the revised FDTL framework as early as January 2024 and that the implementation timeline had been reiterated in February 2025.

In its defence, the DGCA submitted that it retains statutory authority to grant limited exemptions under specific circumstances. It clarified that the relaxation granted to IndiGo was temporary, subject to review every fifteen days, and was not granted as a matter of routine. The regulator further stated that the exemption was time-bound and valid only until February.

IndiGo’s market dominance has long been a subject of discussion among aviation experts. Under the Competition Act, 2002, dominance by itself is not unlawful; it is only the abuse of a dominant position through practices such as capacity control, unfair pricing, or market manipulation that attracts regulatory sanction. However, when a single airline commands a substantial share of the market, any large-scale operational failure has disproportionate consequences for consumers. In this context, the Competition Commission of India (CCI) has taken cognisance of information filed against IndiGo and is examining, at a preliminary stage, whether the facts disclosed warrant scrutiny under the Competition Act (CCI press release dated December 5, 2025).

From a consumer protection perspective, the disruption also raises serious questions around passenger rights and enforcement. Under the Consumer Protection Act, 2019, the DGCA’s CAR, and the Carriage by Air Act, 1972, passengers are legally entitled to specific remedies, including full refunds or alternate flights in the event of cancellations, meals, accommodation, and local transport during extended delays, and compensation for denied boarding or prolonged disruption in defined circumstances. However, on the ground, many stranded passengers reported being left without food, hotel accommodation, or meaningful assistance.

In a suo motu proceeding, the Delhi High Court directed the aviation authorities and the Centre to ensure that affected passengers receive timely compensation and damages. The Court further observed that compensation should not be limited merely to flight cancellations, but must also account for the hardship and mental agony suffered by passengers. In response, IndiGo initiated the compensation process and indicated that it will extend travel vouchers to affected passengers, in addition to the government-prescribed compensation in the range of ₹5,000 to ₹10,000.

In parallel with these consumer-facing measures, the regulatory response has also moved beyond interim relief. The DGCA constituted a dedicated high-level committee to examine the circumstances leading to the disruption, assess compliance with regulatory obligations, and evaluate the adequacy of airline preparedness under the revised FDTL regime. The four-member led committee has now submitted its confidential report.

Air travel today is not a luxury or a discretionary pastime. It is an essential, time-bound public service intertwined with medical needs, livelihoods, family obligations, and carefully planned commitments. When large-scale breakdowns arise not from extraordinary events such as extreme weather or external sabotage, but from prolonged staffing constraints, fatigue exposure, and regulatory warnings that were well known, the outcome cannot be dismissed as misfortune. It reflects a failure of governance.

IndiGo remains one of the most significant business success stories in India. It democratised flying and connected smaller cities to the national aviation network. Yet scale brings responsibility, and market dominance demands restraint. Decisions taken at the board and management level must account not only for efficiency and profitability, but also for systemic resilience, safety, and consumer impact.

The December disruption should therefore not be buried as a routine operational setback. It warrants transparent investigation, rigorous legal scrutiny, and firm regulatory follow-through. Accountability, whether operational, regulatory, or managerial, is essential to restoring trust. Viewed through the lens of governance and social responsibility, the episode highlights a basic point: compliance with safety norms is not a procedural box-ticking exercise, but a fundamental obligation.

Viewed against the DGCA’s regulatory framework, the crisis was not just an operational failure. Rather, it tested the airline’s institutional responsibility. When India’s largest airline falters, the consequence is not merely missed flights; it is a temporary erosion of confidence in the systems that keep the nation’s skies moving.

About the author: Anchal Nanda is a Senior Associate at KLA Legal.

Disclaimer: The opinions expressed in this article are those of the author(s). The opinions presented do not necessarily reflect the views of Bar & Bench.

If you would like your Deals, Columns, Press Releases to be published on Bar & Bench, please fill in the form available here.