The review sought to answer a central question: How many pilots are sleepy as they begin their final landing? In Europe, where day flights are more common, the predicted figure stands at 16 in 100.
The foundation said the short answer was that pilots are mostly alert during daytime operations but often fatigued during night and late-evening duties. It pointed out that a duty can comply with every roster rule and still leave most of the crew sleepy.
The central message of the review is that a legally permitted duty period can still be tiring. According to the foundation, addressing the problem requires changes to the rules rather than placing the responsibility on pilots.
The review clarified that it does not claim flying in India is unsafe or that any particular pilot was unsafe. The figure of 63 in 100 is a forecast for a specific type of duty, in this case from 9pm to 7am, and not a count of identified pilots.
The finding comes from a sleep and body-clock model applied to legal duty limits and anonymised rosters of 13 pilots.
Capt Amit Singh FRAeS, founder and author of the review, said the findings were consistent with concerns that pilots had repeatedly raised.
"Indian pilots have told us, survey after survey, that they are too tired to fly," Capt Singh said.
He said the scientific evidence explained why fatigue remained a concern, pointing to India's rules that leave late-evening duties open, permit a 13-hour day without considering its starting time, and classify most fatigue reports as "perceived".
"The rules count the hours. The body counts the clock," he said.
The foundation's surveys of Indian pilots also point to widespread fatigue concerns. In 2022, 542 pilots responded to its survey, while 530 participated in 2024. Across the surveys, 71 in 100 pilots said they had often been too tired for cockpit duty, while 66 in 100 reported unplanned sleep or microsleeps while on duty.
The review assessed India's regulations against the International Civil Aviation Organisation's (ICAO) requirement that duty rules be based on science, knowledge and operational experience. It rated India as "partly met" on science and knowledge, while the requirement concerning operational experience was rated "not shown".
According to the foundation's release, India manages deep-night duties relatively well. Duties that touch the period between midnight and 6am are limited to 10 hours and two landings.
However, the review found a different picture for daytime operations.
"India allows 13 hours as a routine day, for any start up to 10:30am, with no extra safeguard," the foundation said.
A duty ending just before midnight may include six landings. On a legally permitted duty involving a landing at 11:30pm, between 55 and 77 in every 100 pilots are predicted to be sleepy.
The review explained that fatigue is driven by two factors: sleep pressure and the body's internal clock.
From the moment a person wakes up, sleep pressure builds, similar to a phone battery gradually draining. Only sleep replenishes it. Separately, the body clock influences alertness, which falls to its lowest levels between approximately 2am and 6am.
Night flying combines reduced sleep reserves with the body's natural low-alertness period. When sleep is shortened repeatedly over several nights, the resulting deficit accumulates, creating what the review described as a sleep debt.
The foundation also drew a comparison between fatigue and alcohol impairment.
"India takes a pilot off the roster for any detectable alcohol and suspends the licence above 0.009%," the review said.
It added that after 17 to 19 hours of being awake, a person's performance can deteriorate to a level comparable to that associated with a blood alcohol concentration of 0.05%, which is more than five times the level cited in the review.
The foundation also questioned the process through which India's pilot duty regulations were developed.
According to its release, the Directorate General of Civil Aviation's (DGCA) 2023 study, which formed the basis for the 2024 rules, "reviewed rosters and reports only".
The study did not use wrist-worn sleep monitors or measure alertness, the foundation said.
The review also highlighted developments following the implementation of the night-duty rules. Five weeks after the rules took full effect in late 2025, the DGCA suspended them for one large operator.
The government told Parliament that operators' safety risk assessments had been checked. However, the foundation said none of those assessments had been published.
Investigators have previously raised concerns about fatigue in aviation incidents.
In the 2010 Mangalore crash, which killed 158 people, the Court of Inquiry found that the captain had slept for most of the recorded cruise.
In 2013, investigators found that fatigue had contributed to an error in a serious incident in Mumbai.
The foundation has urged three changes to India's pilot duty regulations. These include setting duty limits according to the time a duty begins, introducing penalty-free fatigue reporting and conducting an independent study of pilot sleep and alertness.
It has also called for the evidence supporting every exemption to be published, along with an end date for each exemption.
The review reiterated that its findings do not establish that flying in India is unsafe or that any individual pilot was unsafe. The predicted fatigue figures relate to specific duty patterns and are based on a model, rather than observations of named pilots.
The foundation's findings have renewed attention on how aviation duty rules account for sleep, circadian rhythms and accumulated fatigue, particularly during night and late-evening operations.
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