The Bench cited Union of India v. Upendra Singh [1994], which laid down the narrow grounds for judicial review of charge sheets.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

The IndiGo operational crisis exposed serious gaps in DGCA’s enforcement of consumer rights, including weak compensation, monitoring, and grievance systems and raised urgent questions on whether current aviation regulations sufficiently protected consumers or needed major reforms.