Capt Amit Kumar Yadav v. Union of India & Ors.

Delhi High Court · 03 Jul 2026 · 2026:DHC:5330-DB
V. Kameswar Rao; Manmeet Pritam Singh Arora
LPA 595/2023
2026:DHC:5330-DB
administrative petition_dismissed

AI Summary

The Delhi High Court dismissed the review petition, holding that blood and urine tests conducted without airline direction cannot be considered, affirming that pre-flight breath alcohol tests alone suffice under aviation regulations.

Full Text
Translation output
REVIEW PET. 282/2026
HIGH COURT OF DELHI
Date of Decision: 03.07.2026
LPA 595/2023
CAPT AMIT KUMAR YADAV .....Appellant
Through: Mr. Sanjeev Kumar and Mr. Anshul Sehgal, Advs.
VERSUS
UNION OF INDIA & ORS. .....Respondents
Through: Ms. Charul Sarin and Mr. Harish Kumar, Advs. for R-3.
Mr. Amit Mishra, Ms. Mitakshara Goyal, Mr. Azeem Samuel, Mr. Vaibhav Kharbanda, Mr. Shivam Goel and Ms. Shrijeta Pratik, Advs. for R-4
CORAM:
HON'BLE MR. JUSTICE V. KAMESWAR RAO
HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA
V. KAMESWAR RAO, J. (ORAL)
CM APPL. 40335/2026 (for long list of dates)
JUDGMENT

1. For the reasons stated in the application, the same is allowed.

2. The application stands disposed of.

3. This is a review petition filed by the appellant seeking review of order passed by this Court on 04.05.2026, whereby this Court has dismissed the appeal filed by the appellant challenging the order dated 11.07.2023 of the learned Single Judge.

4. The only ground urged by the learned counsel for the appellant/ review petitioner is that the learned Single Judge had given a finding that blood/ urine tests could have been considered had they been directed by Vistara but the same were not directed by the airline is erroneous. In this regard, he has drawn our attention to paragraph no. 49 of the order of the learned Single Judge wherein learned Single Judge has stated as under:-

“49. This Court is quite convinced with the averment of Vistara since the presence of blood alcohol content at the time of reporting at Airport before the flying duty, has to be checked as per CAR. So, it is mandatory that the blood alcohol content at that time must be zero as stipulated in CAR. Also, on conjoint reading of Para 4.3 and Para 6.1 of CAR, it is clear that Airlines/operators have been imposed with the duty to conduct pre-flight BA tests of pilots, crew members and maintenance personnel before each flight. Thus, since the duty of conducting pre-flight BA Tests is upon the operator, so the blood and urine tests, which were undergone by the Petitioner himself, without any direction or reference from the operator/Vistara Airlines and which were not conducted by Vistara, results of such tests cannot be considered by this Court. DGCA also rightly did not rely upon them. If these blood and urine tests would have been conducted by Vistara, then in that case, these results might have been considered by this Court in favour of the Petitioner, but, since the Petitioner himself had undergone the same without any such reference or direction of Vistara, the same cannot be considered by this Court under any circumstance.”

5. The submission of the learned counsel for the appellant/ review petitioner is that the conclusion of the learned Single Judge that the appellant himself without any direction or any reference from operator Airlines Vistra took it upon himself to undergo a test, is because the Vistra Airlines itself in its communication dated 22.11.2017 to the DGCA has in paragraph no.3 stated as under:- “3. Additionally, as recommended during the recently held meeting held with Industry representatives to confirm the BA positive status, FO Amit Yadav had undergone blood test at two NBAL approval Laboratories and the test results were negative (copies of blood reports enclosed).” (emphasis supplied)

6. The said submission of the learned counsel for the appellant does not really help the case of the appellant, in view of the conclusion of the learned Single Judge in paragraph 48 of the judgment which we reproduce as under: “48. This Court first needs to adjudicate that whether the results of blood and urine tests undergone by Petitioner can be relied upon or not. It was submitted by learned counsel on behalf of Petitioner that DGCA has not controverted the results of blood and urine tests neither in its Counter Affidavit nor at the time of final arguments. It is true that the counsel for DGCA did not controvert the results of blood and urine tests during the arguments. Even Vistara has not controverted the results of blood and urine tests in its affidavit but, it has been stated in its affidavit that the same cannot be relied upon because any test results subsequent to the BA Tests conducted at Airport are irrelevant.”

7. Suffice to state that in paragraph no.53, the learned Single Judge has dealt with the submission made by the learned counsel for the appellant that Vistra Airlines should have also conducted the blood and the urine test, in the following manner:-

“53. Another contention of Petitioner is that the Vistara Airlines should have also conducted the blood and urine tests of the Petitioner. It was further his contention that blood and urine tests should particularly be done when a crew member tests positive in BA Tests. It is his contention that the Vistara Airlines itself knew about the number of false positives which occur on use of the equipment manufactured by Respondent No. 3, so blood and urine tests of subject persons should also be
conducted. On the other hand, Ms. Anjana Gosain, learned counsel for DGCA in her response submitted that as per CAR or Rule 24 of 1937 Rules, it is not mandatory for an operator/airline to conduct all three tests i.e. breath, blood and urine analysis. It was her contention that the word 'or' has been used in Rule 24 of 1937 Rules and thus, if the operator is only conducting pre-flight BA Tests, then that is also sufficient and there is no need to conduct blood or urine tests. It was further her contention that the usual practice is that the blood and urine tests would be conducted in a case of accident.”

8. Having perused the grounds taken in the review petition, by the appellant in his challenge to the order passed by us on 04.05.2026, it is clear, the same is on merits and in that sense, there is no submission that there is an error apparent on the face of the order passed by this Court on 04.05.2026.

9. We find no merit in this review petition, the same is dismissed.

V. KAMESWAR RAO, J

MANMEET PRITAM SINGH ARORA, J JULY 03, 2026