Author: Preyasi Singh

Introduction

In early December 2025, IndiGo Airlines cancelled more than 2,000 domestic flights within a matter of days, leaving thousands of passengers stranded across major Indian airports. The unprecedented disruption quickly drew public scrutiny and regulatory attention, exposing legal questions surrounding airline operational preparedness, consumer protection enforcement, and regulatory oversight. At the core of the crisis was the airline’s alleged failure to comply with updated safety regulations governing pilot workload and rest requirements. This episode illustrates the complex balance Indian aviation law must maintain between flight safety, airline accountability, and passenger rights.

Background: Flight Duty Time Limitations

The immediate cause of the disruptions stemmed from the full implementation of the Directorate General of Civil Aviation’s revised Flight Duty Time Limitations (FDTL) regulations, which took effect on November 1, 2025. These measures update fatigue management standards consistent with international safety protocols and substantially restrict pilot duty schedules.

Under the revised framework, pilots must receive a continuous 48-hour weekly rest period instead of the earlier fragmented 36-hour arrangement. The protected “biological night” period has been extended to cover midnight to 6:00 a.m., reflecting higher fatigue risks during these hours. Night operations are now limited to two landings per week with restrictions on consecutive nighttime duties. Additional constraints tighten permissible flying hours per duty period.

These reforms emerged from long-standing research linking pilot fatigue to aviation accidents. Although the DGCA introduced the changes in phases commencing in July 2025 and provided nearly two years’ advance notice to airlines, operational preparedness lagged. IndiGo’s aggressive winter scheduling reportedly conflicted with crew availability under the stricter duty limitations. As a result, large-scale cancellations followed within weeks of the full regulatory rollout.

Passenger Rights Under DGCA Regulations

Passenger entitlements during flight disruptions are primarily governed by the Civil Aviation Requirements (CAR), Section 3, Series M, Part IV. Airlines must notify passengers of cancellations at least 24 hours before departure. When notice is provided within this window, airlines must offer either an alternate flight or a full refund.

However, when cancellations occur with less than 24 hours’ notice, the airline incurs additional financial liability in the form of statutory compensation, as well as rescheduling or refunds. The compensation scale is based on block time:

• Flights up to two hours: INR 5,000
• Flights between two and four hours: INR 7,500
• Flights exceeding four hours: INR 10,000
  

During extended waiting periods, airlines must provide refreshments and, when overnight delays occur, hotel accommodation with transport support. These protections are mandatory and cannot be waived contractually.

Most December cancellations allegedly occurred with brief or no notice, thereby triggering full compensation obligations across large numbers of affected passengers.

Consumer Protection Act: Expanded Remedies

Beyond DGCA rules, airline services fall within the scope of the Consumer Protection Act, 2019, allowing passengers to pursue claims for “deficiency in service.” Consumer fora may award compensation beyond statutory DGCA amounts to cover actual losses and non-pecuniary harm.

Recent consumer jurisprudence supports this approach. In multiple district-level decisions involving abrupt cancellations, tribunals have awarded damages substantially above regulatory compensation thresholds when carriers failed to justify operational failures or mitigate passenger hardship. In December 2025, the Delhi State Consumer Commission clarified that DGCA compensation limits represent minimum relief, not a ceiling on broader compensation claims.

This legal position opens the door for affected passengers to recover consequential damages, including non-refundable bookings, business losses, and mental distress. The IndiGo crisis, affecting thousands simultaneously, could therefore produce aggregated liabilities far exceeding routine regulatory penalties.

Force Majeure: A Limited Defence

CAR permits airlines to deny compensation for cancellations attributable to force majeure events beyond their control, such as natural disasters, political unrest, security risks, or adverse weather. The burden lies on the airline to establish both the existence of such events and diligent efforts to avoid disruption.

IndiGo’s reliance on crew shortages prompted by regulatory compliance presents a difficult defence. Courts have consistently distinguished unforeseen emergencies from consequences of inadequate operational planning. Given the extended implementation timeline of the FDTL rules, the shortages appear foreseeable. Failure to recruit or schedule sufficient staff may therefore constitute internal mismanagement rather than force majeure.

On these facts, reliance on statutory exemptions appears legally vulnerable.

Regulatory Investigation and Enforcement

In response to the collapse of operations, the DGCA established a special investigative panel to examine IndiGo’s preparedness, compliance practices, and disruption mitigation efforts. Under powers conferred by the Aircraft Act, regulatory enforcement measures may range from monetary penalties and special audits to suspension of approvals or flight permissions, depending on findings.

Although punitive action is discretionary, the inquiry signals regulatory intolerance for operational strategies that compromise passenger reliability while disregarding aviation safety mandates.

Collective Redress Mechanisms

The scale of consumer impact renders individual litigation impractical. The Consumer Protection Act (Section 35(1)(c)) enables representative or class-style complaints where consumers share common grievances. Authorized representative filings allow adjudicatory bodies to assess systemic liability and award group remedies.

Judicial commentary in December 2025 indicated receptiveness toward collective claims where nationwide cancellations demonstrate persistent service deficiencies. Such proceedings could significantly raise economic exposure for the airline while creating a streamlined avenue of redress for aggrieved passengers.

Systemic Governance Concerns

The crisis highlighted broader deficiencies within airline customer response mechanisms. Reports of inaccessible helplines, contradictory notifications, delayed refund processing, and limited reimbursement documentation aggravated passenger distress. These operational weaknesses may themselves constitute deficiencies under consumer law, irrespective of the legality of cancellations.

Addressing such gaps will require structural reforms, including transparent compensation portals, real-time notification platforms, and standardized procedures for reimbursing incidental losses. Regulatory proposals emerging from the crisis emphasize the need for statutory codification of passenger rights within aviation operations rather than exclusive reliance on judicial enforcement.

Conclusion

The IndiGo disruptions reflect the tension inherent in contemporary aviation regulation between safety-focused obligations and commercial scheduling pressures. While FDTL requirements are essential to mitigate fatigue-related risks, airlines remain responsible for proactively adapting their operational models. Consumer law and aviation regulations jointly provide strong remedial frameworks, ensuring that safety compliance does not occur at the expense of stranded passengers.

As regulatory investigations progress and collective litigation matures, the crisis may recalibrate industry expectations regarding contingency planning and passenger service accountability. The outcome will shape whether India’s aviation sector internalizes safety reforms alongside genuine consumer protection or continues to treat regulatory compliance as merely a logistical afterthought.

Reference List

1. Directorate General of Civil Aviation (DGCA). Civil Aviation Requirements (CAR), Section 3, Series M, Part IV. Revised January 2023.
2. Ministry of Civil Aviation. Flight Duty Time Limitations (FDTL) Regulations. Notified January 2024, phased implementation July 2025 – November 2025.
3. Delhi State Consumer Disputes Redressal Commission. Justice Sangita Dhingra Sehgal’s statement and orders, December 2025.
4. Ernakulam District Consumer Disputes Redressal Commission. IndiGo Airways case, February 2025. Compensation award for the cancelled connecting flight.
5. Rangareddy District Consumer Disputes Redressal Commission. IndiGo Airways v. Passenger, July 2024. Compensation for abrupt flight cancellation with inadequate notice.
6. Consumer Protection Act, 2019. Section 2(1)(g), 2(1)(o), 35(1)(c); sections addressing deficiency in service and collective redressal.
7. Aircraft Act, 1934 (as amended). Regulatory enforcement mechanisms; penalties for serious violations.
8. The Week India. “IndiGo flight cancellations: DGCA launches probe into nationwide travel chaos.” December 4, 2025.
9. Hindustan Times. “DGCA probes IndiGo flight disruption; asks airline to submit reasons, mitigation plans.” December 3, 2025.
10. Indian Express. “IndiGo flight cancellations: Your rights when a flight is cancelled.” December 9, 2025.