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Carriage of Persons with Reduced Mobility

CAR relating to Persons with Reduced Mobility: FIA Views

A CAR (Civil Aviation Requirement) on the subject of 'Carriage by Air of Disabled Persons or Persons with Reduced Mobility' is being debated by the Directorate General of Civil Aviation (DGCA). The Directorate is also inviting the views of various stake-holder organisations. Based on member airlines' feedback, the Federation of Indian Airlines has collated the Airline industry's response to the Draft CAR.
  • The airlines appreciate and recognise fully, their responsibility to passengers with special needs; and are fully agreeable to providing the facilitation required for such passengers.

  • Airlines need to have the right to charge and recover costs for the service provided. While the carriers may certainly choose to waive charges in line with their company policy, FIA believes that it is important for the airlines to retain the right to recover costs from the passengers.

    • Any additional service should necessarily come at a charge to the passenger using the service, else the increased costs will need to be borne by all the other airline passengers.

    • The Airlines should however, certainly communicate the charges levied for services offered, clearly & effectively to the passengers.

Draft CAR 'Carriage by Air of Disabled Persons or Persons with Reduced Mobility':
Airline Views - collated by FIA


    • Air transportation today has been made easier than ever. The Government policies on 'Open Sky' allowed the growth of airlines and also non-scheduled operators in the country. The new ideas of Low Cost and Low Frill concept have also brought the common man with average income group to travel by air.

    • Whereas persons with disabilities and persons with reduced mobility like everyone else are increasingly given the possibility to travel by air, there lies a need to standardize the conditions for travel of such persons so as to facilitate their acceptance and handling of their carriage by the airlines and other operators.

    • This CAR establishes regulations for the protection of and provision of assistance to disabled persons and persons with reduced mobility traveling by air, both to protect them against discrimination and to ensure that they receive assistance with due respect and dignity.

    • For the purpose of this CAR, the Incapacitated Persons or Persons with Disability/ Reduced Mobility are considered the same. This CAR is issued under the provisions of Rule 133 A of the Aircraft Rules, 1937 for information, guidance and compliance by the concerned agencies.


    • All operators engaged in scheduled and non-scheduled air transport services for carriage of passengers, shall comply with the requirements of this CAR.


    • 'Disabled person' or 'person with reduced mobility' means any person whose mobility when using transport is reduced due to any physical disability (sensory or locomotor, permanent or temporary), intellectual disability or impairment, or any other cause of disability, or age, and whose situation needs appropriate attention and the adaptation to his or her particular needs of the service made available to all passengers. (Ref. EU Journal L204/1 dt. 26 July, 2006)

    • Incapacitated Passengers shall be defined as those with physical or mental disability; or with a medical condition, who require individual attention or assistance on enplaning / deplaning, during flight and during ground handling which is normally not extended to other passengers. This requirement will become apparent from special requests made by the passengers and/or their family or by a medical authority, or from obvious abnormal physical or mental conditions observed and reported by airline personnel or industry-associated persons (travel agents, etc.). (Ref. IATA Resolution 700 22 edition, June, 2002)

    • A person with reduced mobility (PRM) is understood to mean any person whose mobility is reduced due to any physical disability (sensory or locomotory), an intellectual impairment, age, or any other cause of disability when using transport and whose situation needs special attention and the adaptation to the person's needs of the services made available to all passengers. (Ref. IATA working document, dated 11 May, 2001)


    • No airline should refuse to carry persons with disability or persons with reduced mobility and their assistive aids/devices, escorts and guide dogs, etc.:

      • if such carriage, because of the person's physical or medical conditions determined on the basis of established facts, does not pose a risk to the safety of other passengers and their property, the aircraft or the crew and provided such person submits himself to the specific conditions of carriage required by the airline's published regulations.

      • whose conduct, status, mental or physical condition is determined by the airline to be such, as to render them incapable of assisting in their evacuation of the aircraft.

    • Airlines should develop emergency evacuation procedures and staff training for handling persons with disabilities and include the same in their safety manuals. The training programme shall include detailed procedures of handling, evacuation and develop awareness towards disabled passengers, persons with medical conditions, elderly persons, infants, pregnant women etc.

      Note: The airline shall formulate a detailed procedure for carriage of disabled persons or persons with reduced mobility and publish the same on their website.

    • All airlines shall run program for their staff engaged in passenger handling e.g. cabin crew / commercial staff etc. for sensitization and developing awareness for assisting passengers with disabilities. The training program shall be conducted at the time of initial training and a refresher shall be conducted every 3 years on the subject. Only such persons who have current course shall be assigned to handling disabled persons. The training program should interalia, include assisting disabled persons in filling up travel documents as may be required while providing assistance in flight.

    • No airline should refuse to engage in interline transactions for carriage of disabled persons or persons with reduced mobility or to commence/continue interline transportation of such persons, if it does not pose a threat to the safety of operation by rendering emergency evacuation difficult. [Airlines can agree with this subject to the caveat that it does not mean that each airline needs to create interline agreements with other airlines, solely for this purpose]

    • Many persons with disabilities do not require constant assistance for their activities. Therefore, if the passenger declares independence in feeding, communication with reasonable accommodation, toileting and personal needs, the airlines shall not insist for the presence of an escort.

      Note: It is clarified that people with Paraplegia where due to existing control over their upper body, can help themselves in emergencies evacuation. In such cases presence of an escort should not be insisted.

    • No airline should refuse to carry persons traveling in a stretcher or incubator or persons with severe mobility impairments and persons with autism, Cerebral Palsy, mental retardation and multiple disabilities, if they are accompanied by an escort who will be responsible for them and their needs of embarking, disembarking, during flight, and during emergency evacuation. However, the airlines shall provide necessary assistance to persons with hearing or vision impairments in case they wish to travel alone without an escort. [Airlines would not refuse carriage; however, the carriage must be paid for. For example, a stretcher requires displacing 9 seats that would otherwise be sold as revenue; and it must be clear that these seats must be reserved in advance and paid for].

    • Persons with disabilities not holding any certificate may also be provided necessary assistance as well as the aids such as wheel chairs, ambulifts etc. In such cases during ticketing the individuals' degree of disability and his need for assistance may be confirmed. [Airlines would not refuse carriage; however, the costs of wheel chairs, ambulifts etc should be borne by the passenger(s) requiring them.]

    • An airline shall have assistance booths/counters at airports with the International symbol of Disability displayed prominently within the visible proximity of the main entrance of the arrival/departure terminal, informing where they may contact for special assistance. [The passengers may inquire at any booth. Separate booths/facilities needs to be avoided due to severe space constraints at most of our airport locations].

    • Sufficient directional signage should be placed inside the airport regarding the availability of assistance for disabled person or person with reduced mobility. [This is an airport issue, not an airline issue.]

    • An airline shall not limit the numbers or types of incapacitated passengers on their flights except for operational reasons such as hindrance to emergency evacuation or undue disruption of the flight schedules. [An extra condition that needs to be added is that if the aircraft is not equipped physically; for example, some of the aircraft can only accommodate one stretcher at a time]

    • All airlines should provide assistance to meet the particular needs of the persons with disabilities and persons with reduced mobility, from the departing airport terminal to the destination airport terminal without any additional charge. [FIA disagrees with this statement. It is one thing to provide service, another to do it for free. No other passengers are provided free-of-charge services.]

    • Persons with disabilities and persons with reduced mobility have equal choice of seat allocation as others, subject to safety requirements. [Should read: subject to safety requirements and physical limitations of the aircraft (for example, some seats have less legroom than others.]

    • Airlines shall have to procedures for carriage of Service Dogs for the assistance of disabled persons or persons with reduced mobility.


    • No Medical clearance or special forms shall be required from persons with disabilities or persons with reduced mobility who only require special assistance at the airport for assistance in embarking/ disembarking and a reasonable accommodation in flight, but are otherwise independent. [It is not practical for the airline staff to determine whether a person only requires certain forms of assistance. Passengers should plan to have all forms ready in advance, or flight disruptions may occur that affect all passengers.]

    • A medical clearance by the airline may be required only when the airline has received information that the passenger

      • suffers from any disease, which is believed to be actively contagious and communicable;

      • who, because of certain diseases, or incapacitation may have or develop an adverse physical condition which could have an adverse effect on safety and emergency evacuation procedures;

      • would require medical attention and / or special equipment to maintain their health during the flights;

      • there exists a possibility of medical condition aggravated during or because of the flight;

        [It is not practical for the airline staff to determine whether a person only requires certain forms of assistance. Passengers should plan to have all forms ready in advance, or flight disruptions may occur that affect all passengers.]

    • Any passenger satisfying any of the conditions mentioned in 5.2 (a) through 5.2 (d) be subjected to prior clearance for air travel by the medical departments/advisors of all carrying airlines, on the basis of the information with respect to the physical and/or mental condition obtained by the airline that is in contact with the passenger through its medical department/advisor directly or through a licensed physician familiar with the condition of the passenger. In case the passenger has a connecting flight with another airline, this medical clearance should be accepted at the first point of check-in and the information transmitted to the connecting airlines so that the passenger is not required to furnish the same again and again. [It is not practical for the airline staff to determine whether a person has prepared accurate or adequate forms with another airline in advance. Copies should be filed with each airline to avoid flight disruptions that affect all passengers.]

      Before refusing carriage of such passengers, the airlines shall refer to their medical departments/ advisors for advise/ clarification in accordance with a procedure, which shall be documented by the airlines. For such clearance the airline may seek the necessary medical information from the passengers. [If the forms are not filled out in advance, the procedure suggested would trigger lengthy flight delays. This should be removed.]

      Note 1 - The airline shall enter for each person with disabilities or person with reduced mobility or incapacitated passenger the information sheet requiring special assistance.

      Note 2 - The airline shall establish a procedure for expeditious clearance by their medical departments, where required, to avoid delays causing inconvenience to passengers. [It needs to be the responsibility of the passenger to pre-clear themselves with the airline. Airlines need to provide forms and procedures on their websites and through their call centres to make the process simple; however, it is simply not practical to do this in real time at the airport or on the airplane.]

      Note 3 - The airline shall ensure that at time of check-in airline staff is alerted and shall verify that all needs required by the passenger have been made available. [This can be done only if the passenger has filled in required forms and alerted the staff prior to check in.]

      Note 4 - Airlines shall obtain all the information about the medical conditions of the persons with disabilities at the time of ticketing and necessary investigation/ verification be completed before confirming the ticket. Once the ticket is confirmed no further enquires should be made. [This can be done only if the passenger has taken responsibility to fill in all required forms and alerted the staff prior to check in.]

      Note 5 - The procedures involving medical clearances shall be documented and published in each airlines websites.


    All assistive aids shall be provided without any extra cost to the passengers. However, where additional human assistance is required, airlines may charge a fee, details of which should be included in the airline website. [it is not clear what "all assistive aids" means].

    • Wheelchairs

      • Airlines shall ensure that at all stations, for boarding / disembarking purposes, before departure, during intermediate stops and on arrival wheel chairs are available without any extra charge [however human assistance may be charged for per the above statement] and that advance arrangements made with other concerned agencies where necessary to ensure that movement of persons with disabilities and persons with reduced mobility within the airport is not restricted.

      • Passengers who intend to check-in with their own wheelchair shall be given the option of using a station/airport wheelchair. If the passengers prefer to use their own wheelchair within the airport, they shall be permitted to use it up to the aircraft, whereupon it may be stowed at an appropriate place in the aircraft. At the time of disembarking, the passenger's wheel chair should be returned to him to enable him to transfer himself from the aisle seat directly into his own wheel chair. [subject to security requirements and advance notification by the passenger].

    • Stretchers

      Upon request, the airlines shall make stretchers and associated equipment, e.g. blankets, pillows, sheets, nursing materials and privacy curtains, available for passengers who cannot use the standard airline seat in a sitting or reclining position for the class of service desired. [Upon advance request; and with a charge for all materials required and the seats that are made unavailable for sale as a result. This can not be done without advance notice.]

    • Ambulifts at airport

      Every airport authority shall endeavor to make provision for ambulifts to enable disabled passengers or passengers with reduced mobility to enter the aircraft without inconvenience. [1. At a charge; 2. Facilities like ambulift at airports should become a part of airport equipment as it would be impossible for airlines to provide ambulift at all airports where it operates].

    • Other Assistive Devices

      • To board/disembark the disabled persons, immobile or incapacitated passengers not traveling on stretchers, airlines shall have available narrow wheelchair-type devices, without armrests, preferably foldable type that can be moved about in the passenger cabin. [some very nominal charge could (and should) be levied for the capital expense of providing these wheelchairs, and the operating expense of carrying them around]

      • Upon request the airlines shall endeavour to have available on board a special wheel chair capable of carrying a handicapped passenger to enable them to use lavatory facilities, or as a boarding /disembarkation vehicle where these are not available.


    • Boarding

      • The presence of all categories of incapacitated passengers and persons with disabilities or reduced mobility their escorts and any special arrangements made for them while on board, shall always be referred to the captain / senior cabin crew member.

      • Incapacitated passengers and persons with disabilities or reduced mobility and their escorts shall be offered pre-boarding facilities. [it is not clear what "pre-boarding facilities" means. If it means special reserved space at the airport, this is an airport issue, not an airline issue. In any event, it should be more clearly defined]

      • If passengers for any reason have to be offloaded, the highest possible priority for transportation shall be given to disabled persons or persons with reduced mobility, and to their escorts.

      • The checked-in baggage of the persons with disability or with reduced mobility should be given 'Priority Tags' to ensure early identification and assistance by the airline ground staff.

    • Seating

      Incapacitated passengers and persons with disabilities or reduced mobility including blind shall not be restricted to any particular cabin or seating areas, except when it is done for safety of passengers and interfere with evacuations [or due to physical limitations of the aircraft].

    • Briefing

      • Before take off, certain types of persons with disabilities or persons with reduced mobility, incapacitated passengers and their escorts may be individually briefed on emergency procedures, cabin layout and specialized equipment supplied by the airline. The responsibility for such special briefing shall rests with airline's senior cabin crew.

      • Blind passengers may be briefed verbally, and Braille brochures may back up such briefing. Instructions in large print may be made available for persons with low vision. [It is not practical to carry various braille / large print / etc. documents; the airlines believe that this should be limited to a verbal briefing]

    • In Transit off loading

      When overnight accommodation is offered such as when disabled persons are offloaded or when airlines are forced to have an overnight halt, wheel chair users must be allocated accommodation that is suitable to their needs. [Should be amended to read "airlines must endeavour to ensure that... Because a flight may be unexpectedly diverted to a location and the airline may not be fully prepared.]

    • Loading of special equipment of persons with disabilities or reduced mobility.

      Special equipment required by incapacitated passengers and persons with disabilities or reduced mobility in connection with their trip, if not carried in the passenger cabin, shall be loaded in the baggage holds where it is easily accessible for timely return to the passenger. Any such item must be properly identified and tagged, must always travel with the passenger, and shall be loaded in such a way as to be readily and immediately available at transfer and destination points.

      Note: Passengers carrying spare calipers or mobility aid may be allowed to take the same as a hand baggage as these devices are delicate and prone to breakage.

    • Transit stations

      Incapacitated passengers and persons with disabilities or reduced mobility requiring special assistance or protection from disturbance, and their escorts, shall be permitted to stay on board during transit stops, if they so desire, subject to the observance of applicable safety security norms.

    • Disembarkation at point of transfer or destination

      • Upon request, the airline shall make arrangements for assisting persons with disabilities or persons with reduced mobility and incapacitated passengers in baggage delivery and getting out of the airport, even when they are accompanied by an escort. The checked in baggage with 'Priority Tags' should be kept in a safe place by the ground staff till the passenger arrives. [Airlines may charge for any such special requests]

      • Wheelchairs and other assistive devices checked in shall, within the shortest possible time, be delivered as close as possible to the door of the aircraft. However, the passenger may, at his option, use an airline/ airport wheelchair.

    • Transmission of Information / Down line notice

      The airline checking in the incapacitated passenger and persons with disabilities or reduced mobility (or any person delegated by such airline) shall be responsible for advising its ground staff at transit stations and at the airport of disembarkation about the presence of incapacitated passengers and the location of wheelchairs and assistive devices on board and about the need to arrange for special assistance.


    • The Aerodrome operator shall provide ambulance facility for the passenger on arrival and departure at/from the airport, to such passengers on stretchers, upon advance request by the passengers or their representative or by the airline.

    • Incapacitated passengers arriving at the airport in hospital/ outside ambulance may be given an option of either taking the ambulance up to the aircraft boarding point or use the airport ambulance for going to the aircraft. In the former case the airport management shall provide escort to direct the ambulance driver through designated areas for vehicle driving.


    • All airlines should assist a passenger with disability or reduced mobility to get to the toilet and to provide essential safety information.

    • Airlines shall provide accommodation for passenger with disability or reduced mobility which may require extra leg space without any extra charge. [It would be provided at no additional charge than that levied of any other passenger, and only if available.]

    • Airline should ensure proper storage and handling of mobility equipment or any such assistive devices used by the persons with disability or reduced mobility. In case of lost or damage to such equipment the airlines should provide suitable compensation.

    • Airlines should provide necessary procedure for emergency evacuation in respect of person with disability or reduce mobility in the form of passengers briefing card. [It is not practical for airlines to have special briefing cards with respect to each type of disability or reduced mobility. This can only be handled by individual briefings by the crew with respect to the particular circumstances.]

    • All information required by the airlines to facilitate carriage of the disable person or person with reduced mobility must be gathered by the airline during the online booking process. The following information should help the airline to make arrangements: [the booking process is not always online; this should include call centre. Also, it is the passenger's responsibility to provide the information, the airline has no way of knowing if the information is accurate or complete.]

      • the nature and level of special assistance required when embarking, disembarking and in-flight assistance required;

      • mobility equipment and disability aids that need to be carried by the airline;

      • whether the passenger will be accompanied with an escort.

      • The above is not an exhaustive list and during online booking, the airlines should gather all such information without requiring the passenger to provide additional information later.


    A disabled person or person with reduced mobility who considers that this regulation has been infringed may bring the matter to the attention of the managing body of airlines, airport or other concerned authorities, as the case may be.

    The managing body of the airlines and the airport shall ensure speedy and proper redressal of these complaints.