On November 15, 2025, India’s Ministry of Home Affairs issued a landmark circular that fundamentally transformed the regulatory framework governing repatriation of mortal remains. This technical policy shift—reclassifying human remains as ‘cargo’ rather than ‘passengers’ under Section 19 of the Immigration and Foreigners Act, 2025—represents a convergence of aviation logistics, digital health infrastructure, and humanitarian advocacy. At the centre of this reform stands Mohan Nannapaneni, Boston-based entrepreneur and TEAM Aid founder, whose systematic documentation of over 5,000 repatriation cases provided the evidentiary foundation that catalyzed governmental action.

The repatriation of mortal remains represents one of the most complex logistical operations in modern aviation, requiring seamless coordination across multiple technical domains: air cargo regulations (IATA Dangerous Goods Regulations), public health protocols (WHO International Health Regulations 2005), customs procedures, and immigration frameworks. For decades, this complexity was compounded by a regulatory ambiguity that trapped grieving families in bureaucratic limbo: airlines refused to transport human remains without the deceased’s original passport, even when Indian diplomatic missions had issued formal No Objection Certificates (NOCs) verifying nationality and authorizing transport.

This wasn’t merely an administrative inconvenience—it constituted a humanitarian crisis affecting thousands of families annually. According to data compiled by TEAM Aid, the nonprofit organization founded by Mohan Nannapaneni in 2017, more than 5,000 Indian citizens have died abroad over the past eight years requiring repatriation assistance. In cases where passports were lost, stolen, destroyed in accidents, or retained by foreign authorities during investigations, families faced weeks or months of delay, incurring substantial financial costs and profound emotional suffering.

Aviation Cargo Classification vs. Immigration Passenger Protocols

To understand the significance of the November 2025 reform, one must grasp the technical and regulatory classifications governing international cargo movement. Under IATA (International Air Transport Association) standards and ICAO (International Civil Aviation Organization) Annex 9 (Facilitation), items transported internationally fall into distinct categories:

• Passengers: Require complete immigration clearance, including valid travel documents
• Personal Baggage: Subject to customs procedures but simplified immigration treatment
• Cargo: Defined under IATA as ‘any property carried on an aircraft other than mail, stores, and accompanied or mishandled baggage,’ operating under fundamentally different clearance mechanisms
• Mail: Governed by Universal Postal Union conventions

Human remains, despite their profound significance and special handling requirements, existed in a regulatory grey zone. While they physically occupy aircraft cargo holds (they cannot be seated in passenger cabins) and are transported in specialized containers meeting WHO guidelines for pathogenic containment, they were historically processed using passenger-level documentation requirements. This created what systems engineers would recognize as a ‘classification mismatch’—cargo operations governed by passenger-level clearance protocols.

The eCARE Digital Infrastructure: A Case Study in E-Governance Innovation

In August 2023, recognizing the systemic inefficiencies in repatriation processes, India’s Ministry of Health and Family Welfare launched the eCARE (e-Clearance for Afterlife Remains) portal—a sophisticated digital platform that represents a significant advancement in e-governance for health and aviation sectors. While the eCARE portal predated the November 2025 immigration clarification, Nannapaneni’s advocacy and TEAM Aid’s operational insights were instrumental in highlighting the need for unified digital infrastructure.

Technical Architecture of eCARE Portal

The eCARE portal exemplifies modern digital health infrastructure design, integrating multiple stakeholder systems into a unified interface:

• Multi-Actor Access Architecture: The platform enables direct submission by individuals, organizations (NGOs, funeral services, embalmers), Indian diplomatic missions, and airlines—eliminating the previous requirement for airlines to serve as exclusive intermediaries
• Real-Time Notification System: Automated SMS/WhatsApp alerts to all stakeholders at each processing stage, addressing previous communication gaps across international time zones
• Digital Document Management: Secure upload and verification of critical documents (death certificates, embalming certificates, NOCs) with cryptographic authentication
• 24/7 Processing Capability: Airport Health Organizations can approve applications around the clock, with over 95% of cases processed within 24 hours since launch
• Integration with Immigration Systems: Direct connectivity with Bureau of Immigration databases, enabling seamless updating of deceased persons’ records

The Science of Remains Transport

The November 2025 circular’s reclassification of remains as cargo does not diminish health safety requirements—rather, it properly aligns classification with the actual technical and health protocols that have always governed remains transport. Understanding these protocols is essential for Neo Science Hub readers focused on health sciences, aviation, and biotechnology:

Mandatory Health Clearance Requirements

Under India’s Aircraft (Public Health) Rules, 1954, and WHO International Health Regulations (2005), all human remains arriving at Indian airports must satisfy rigorous health safety criteria:

• Embalming Certification: Licensed mortuary confirmation that the body has been embalmed using approved chemical preservatives (typically formaldehyde-based solutions meeting WHO standards)
• Hermetic Sealing: Placement in airtight, waterproof caskets with zinc or lead lining, preventing pathogenic leakage during air transport
• Death Certificate with Cause of Death: Medical certification specifying the precise cause of death, enabling epidemiological screening for communicable diseases
• Communicable Disease Screening: Additional protocols for deaths from designated high-consequence infections (yellow fever, plague, anthrax, glanders), requiring cremation and transport only of hermetically sealed ashes
• Packaging Compliance: Verification that casket construction meets WHO guidelines for biohazard containment during aviation transport

These requirements remain fully operative under the new framework. The reform simply clarified that immigration passport requirements—designed for living passengers—do not apply to cargo subject to health and customs clearance.

Technical Reclassification as Regulatory Reform

The November 15, 2025 circular from India’s Ministry of Home Affairs (No. 26011/Misc/60/2025-OCI) represents a masterclass in regulatory innovation. Rather than requiring lengthy parliamentary legislative amendments, the government employed administrative rulemaking to clarify existing legal intent under the Immigration and Foreigners Act, 2025.

Key Provisions of the November 2025 Circular

• Legal Classification: ‘Human mortal remains cannot be treated as “passenger” under Section 19 of the Immigration and Foreigners Act, 2025 as these are treated as Cargo’
• Immigration Clearance Waiver: ‘No immigration clearance is required for such human mortal remains’
• Passport Requirement Elimination: ‘Transportation of human mortal remains without an original passport cannot be considered as a violation under Section 19’
• Airline Authorization: Airlines may accept remains upon production of NOC issued by concerned Indian Mission/Post, along with necessary customs and health clearances
• Documentation on Arrival: Airlines may present details of passport or NOC to immigration authority to update immigration records

Nannapaneni’s Strategic Advocacy

At the centre of this policy transformation stands Mohan Nannapaneni, whose background uniquely positioned him to identify, document, and escalate this systemic problem. As co-founder and CTO of Sigma Systems Inc.—a company that achieved Inc. 500 ranking #24—Nannapaneni possessed both the technical acumen to understand complex logistical systems and the organizational capacity to build evidence-based advocacy campaigns.

This operational experience provided Nannapaneni with something government officials typically lack: granular, systematic data on how regulatory failures manifested in individual cases. By documenting thousands of repatriations, TEAM Aid accumulated irrefutable evidence that the passport requirement wasn’t merely an administrative inconvenience—it was a systemic barrier producing humanitarian crises.

From Documentation to Policy Change

By mid-2025, the accumulation of stranded cases had reached crisis proportions. Besides the extensive correspondence on this, Mohan Nannapaneni again sent in July, 2025, formal correspondence to India’s Home Secretary Govind Mohan, documenting how airlines including Air India, Delta, and international carriers were systematically rejecting remains despite valid NOCs from Indian diplomatic missions.

The advocacy campaign employed several sophisticated strategies:

• Systematic Case Documentation: Detailed records of multiple cases, including dates, airlines, diplomatic correspondence, and family testimonies
• Technical Legal Analysis: Identification of the specific regulatory ambiguity (cargo vs. passenger classification under Section 19) and proposed technical solution
• Multi-Ministry Coordination: Simultaneous engagement with Ministry of Home Affairs, Ministry of External Affairs, Ministry of Health and Family Welfare, and Bureau of Immigration
• Diplomatic Channel Activation: Collaboration with Indian embassies and high commissions globally to document airline refusals
• Media Engagement: Strategic coverage in Economic Times, Rediff, India New England News, and other outlets to maintain public pressure

Lessons for Technology, Aviation, and Health Policy Integration

1. Digital Infrastructure as Policy Enabler

The eCARE portal demonstrates how digital platforms can transform bureaucratic processes. By creating unified digital infrastructure connecting multiple stakeholders (health officials, immigration authorities, airlines, families), the government eliminated information silos and processing delays. This model has applications across numerous domains where multi-actor coordination creates bottlenecks—customs clearance for medical devices, pharmaceutical import approvals, aviation safety certification, etc.

2. Regulatory Classification as Technical Innovation

The cargo vs. passenger reclassification illustrates how technical legal interpretation can resolve systemic problems without legislative overhaul. In an era of regulatory gridlock, this approach—using administrative clarification rather than statutory amendment—offers a pathway for addressing other classification ambiguities in aviation, telecommunications, biotechnology, and emerging technology sectors.

3. Evidence-Based Advocacy and NGO-Government Collaboration

Nannapaneni’s success stemmed not from political connections but from TEAM Aid’s accumulated operational expertise managing thousands of cases. This demonstrates the value of NGOs as ‘early warning systems’ for regulatory failures—organizations operating at scale in specific domains often identify systemic problems before government agencies recognize patterns. Creating formal channels for NGO-government knowledge transfer could accelerate policy improvements across numerous sectors.

4. Aviation Logistics and Public Health Integration

The repatriation framework demonstrates sophisticated integration of aviation safety protocols and public health requirements. The same technical principles—hermetic sealing, pathogenic containment, cross-border health clearance—apply to other aviation-transported biohazardous materials: medical specimens, pharmaceutical cold chain logistics, organ transport for transplantation, and infectious disease surveillance samples. India’s streamlined system could serve as a model for other nations managing similar logistics.

A Model for Technology-Enabled Humanitarian Innovation

 

The November 2025 repatriation reform demonstrates how technical innovation—spanning digital infrastructure (eCARE portal), regulatory reclassification (cargo vs. passenger), and systematic advocacy (evidence-based documentation)—can resolve humanitarian crises that persist for years due to bureaucratic inertia.

For thousands of Indian families globally, the reform eliminates a source of profound anguish during already devastating circumstances. Families no longer face the cruel paradox of obtaining official government authorization for repatriation, only to be refused by airlines citing a technically unjustified requirement.

For policy analysts and technology professionals, the case offers a blueprint for addressing regulatory bottlenecks through multi-pronged approaches: digital platform development, administrative rule clarification, and NGO-government collaboration grounded in operational data.

TECHNICAL SPECIFICATIONS: Aviation and Health Requirements for Remains Transport

Container Requirements:

• Hermetically sealed, airtight, waterproof construction
• Zinc or lead lining for pathogenic containment
• WHO-compliant packaging standards

Embalming Standards:

• Formaldehyde-based chemical preservation by licensed facilities
• Certification by authorized mortuary/embalming agency

Documentation Required:

• Death certificate with specific cause of death
• Embalming certificate
• No Objection Certificate (NOC) from Indian diplomatic mission
• Packaging compliance certificate (WHO guidelines)
• Consignee endorsement (casket contents verification)
• Communicable disease screening (if applicable)

Processing Timeline (Post-eCARE Implementation):

• Over 95% of applications processed within 24 hours
• 24/7 Airport Health Organization approval capability
• Real-time SMS/WhatsApp notifications to all stakeholders

– Naresh Nunna