Mister Minister, Where Is the “Average Machine”?


The Government has a detailed, published system for certifying a new car’s fuel consumption. We could not find any notified dealer machine that makes a citizen’s mileage complaint “true.”


I am Vishal Singh Jain of VSJ Ventures LTD. By now, Minister, you know how thoroughly we examine the underlying record—and yes, we genuinely enjoy watching your interviews.


We are referring to ABP News’s exclusive interview with you, aired on 13 July 2026.


In that interview, a journalist told you that her 2023 petrol car had earlier delivered approximately 10–11 km/l in city driving but was now returning about 7 km/l. She described the road and traffic conditions as broadly the same and asked whether blended petrol had caused the reduction.


You told her to take the vehicle to an authorised company dealer because:

“वहाँ मशीन होती है… वह मशीन किसी के घर में नहीं होती है.”

When she again asked whether you would accept that blended petrol had reduced her mileage, you replied:

“…वो एवरेज मशीन में रिकॉर्ड आएगा तब सच है.”

The second quotation begins with an ellipsis because it is a mid-sentence excerpt. The operative portion of the exchange is nevertheless clear: her reported mileage reduction would become “true” when it appeared on an authorised dealer’s “average machine.”


That is not merely a suggestion to have the car checked for a mechanical fault. It presents an unidentified machine at an authorised dealership as the evidentiary threshold by which a citizen’s mileage complaint is to be accepted or rejected.


So we went looking for the machine—and, more importantly, for the Government standard governing it.


A short reader’s map before we begin


This article uses several regulatory abbreviations. None of them should be left unexplained:


  • M1 is the regulatory category for ordinary passenger cars: vehicles used to carry passengers, with no more than eight passenger seats in addition to the driver’s seat.
  • CMVR means the Central Motor Vehicles Rules, 1989, the rules under which vehicle type approval and many technical requirements are enforced in India.
  • AIS means Automotive Industry Standard. AIS-137 is the principal BS-VI testing standard discussed in this article.
  • ARAI is the Automotive Research Association of India; ICAT is the International Centre for Automotive Technology; and NATRAX is the National Automotive Test Tracks facility. These are part of India’s notified vehicle-testing system.
  • MIDC means the Modified Indian Driving Cycle, the prescribed laboratory driving pattern used for the relevant certification test.
  • OBD-II means second-generation On-Board Diagnostics. It is the car’s diagnostic system, not by itself an independent fuel-consumption measurement system.
  • ECU means Electronic Control Unit, the computer that manages and records many engine and vehicle functions.
  • CAFE means Corporate Average Fuel Economy. It is a manufacturer-wide fleet average, not the mileage test of one customer’s car.
  • WLTP means the Worldwide Harmonised Light Vehicles Test Procedure, a newer laboratory procedure designed to better reflect real-world driving than older test cycles.

The basic distinction running through this article is simple: type approval certifies a vehicle model; OBD diagnoses a vehicle; CAFE evaluates a manufacturer’s fleet; none of these automatically establishes a Government-mandated dealer machine for deciding one owner’s mileage complaint.


PART 1: How does the Government of India actually certify a passenger car’s fuel consumption?


Before entering the rules and formulas, here is the entire process in plain English.


A manufacturer does not take a new model to a dealer and ask a workshop scanner to “check the average.” Before the model can be sold, a representative car is submitted to a Government-notified test agency under Rule 126 of the Central Motor Vehicles Rules. For the relevant passenger-car test, the vehicle is first run for at least 3,000 km. It is then placed on a laboratory chassis dynamometer—a machine that lets the car be driven through a fixed cycle while remaining inside a controlled test cell*. The laboratory measures hydrocarbons, carbon monoxide and carbon dioxide in the exhaust. AIS-137 then converts those measured emissions into fuel consumption through a published carbon-balance formula. The declared result is checked against the laboratory result, with repeat testing where the prescribed 4% margin is exceeded. Production vehicles may later be sampled for conformity.


In one line, the official chain is:


Manufacturer → notified test agency → 3,000-km run-in → chassis dynamometer and prescribed driving cycle → HC, CO and CO₂ measured → AIS-137 formula → verified type-approval result.


That is how the Government produces the certified fuel-consumption figure for a vehicle model. An On-Board Diagnostics scan and a manufacturer’s Corporate Average Fuel Economy calculation are separate regulatory exercises. Neither is a dealer-level test that decides whether one customer’s car is returning 7, 10 or 11 km/l.


The details below matter because they show exactly what the official system contains—and what the Minister’s unidentified “average machine” has not yet been shown to contain.


1. The process begins with type approval—not with a dealership


Rule 126 of the Central Motor Vehicles Rules requires a manufacturer or importer to submit the prototype of a motor vehicle to a Government-notified testing agency before that model is approved for manufacture or import. Agencies such as the Automotive Research Association of India (ARAI), the International Centre for Automotive Technology (ICAT) and National Automotive Test Tracks (NATRAX) operate within this notified testing system.


Rule 126A separately allows vehicles drawn from production to be tested for conformity with the approved type. In simple terms, Rule 126 approves the model; Rule 126A helps check whether vehicles coming off the production line continue to match what was approved.


The legal gateway is therefore a Government-notified test agency. It is not an ordinary authorised dealership connecting a diagnostic scanner to an already-sold customer car.


Central Motor Vehicles Rules, 1989, Rules 126 and 126A; printed pp. 147–148, consolidated PDF pp. 165–166.


2. The car is run in, placed on a dynamometer and driven through a fixed cycle


For the relevant M1 passenger-car category, AIS-137 Part 3 prescribes the BS-VI type-approval and conformity-of-production procedures. M1 means the ordinary passenger-car category: a vehicle used to carry passengers, with no more than eight passenger seats in addition to the driver’s seat.


The Type-I test vehicle must be in good mechanical condition and must have been:

“run-in and driven at least 3,000 km before the test.”

The car is then tested under controlled laboratory conditions on a chassis dynamometer. Think of it as a road inside a laboratory: the wheels turn on rollers while the vehicle follows a fixed speed-versus-time programme.


Under the present AIS-137 framework, that programme is the Modified Indian Driving Cycle (MIDC)—a fixed laboratory sequence intended to simulate a combination of urban and extra-urban driving. It contains defined urban and extra-urban phases, accelerations, steady speeds, decelerations, gear use and timing. The test cell is also controlled; AIS-137 specifies a temperature range of 20°C to 30°C for the relevant test.


This is why the certified figure is not produced by taking a factory-fresh customer car, connecting a workshop tool and reading whatever number its Electronic Control Unit (ECU)—the computer managing and recording many engine functions—displays.


AIS-137 Part 3, Chapter 3, clauses 2.1.1 and 2.2.1, printed p. 40/296, combined PDF p. 220; driving-cycle provisions in Chapter 3 and its appendices, printed pp. 43–53/296, combined PDF pp. 223–233.


3. The laboratory measures exhaust gases and calculates fuel consumption


The official procedure does not simply read the dashboard’s average-fuel-economy display.


AIS-137 uses the carbon-balance method. The laboratory measures hydrocarbons (HC), carbon monoxide (CO) and carbon dioxide (CO₂) in grams per kilometre. Those measured values, together with the density of the test fuel (D), are inserted into a fuel-specific equation. The result is expressed in litres consumed per 100 kilometres.


For the technical record, AIS-137 prescribes the following petrol equations:


E5: FC = (0.118 ÷ D) × [(0.848 × HC) + (0.429 × CO) + (0.273 × CO₂)]

E10: FC = (0.120 ÷ D) × [(0.830 × HC) + (0.429 × CO) + (0.273 × CO₂)]

E20: FC = (0.126 ÷ D) × [(0.793 × HC) + (0.429 × CO) + (0.273 × CO₂)]


Here, FC means fuel consumption in litres per 100 km. For readers accustomed to kilometres per litre:


Mileage in km/l = 100 ÷ fuel consumption in L/100 km


AIS-137 Amendment No. 9 introduced the separate E20 composition and coefficients. That is significant: the official calculation itself does not treat E20 as compositionally identical to E5 or E10.


The declared CO₂ result is also subject to a defined verification process. At the first stage, the manufacturer-declared value may be accepted where:


Measured CO₂ ≤ 1.04 × declared CO₂


If the laboratory result exceeds the declaration by more than 4%, another test is required. Depending on the average of the results, a third test may follow.


That 4% is a laboratory type-approval tolerance. It is not a Government declaration that an individual customer must accept a 4%, 10%, 20% or 30% shortfall from the brochure figure. We could locate no universal Government rule fixing an acceptable real-world mileage shortfall for an individual owner.


AIS-137 Part 3, Chapter 3, clause 7.0, printed pp. 60–62/296, combined PDF pp. 240–242; Amendment No. 9, August 2024, amendment p. 12 of 17; Chapter 19, clauses 7.2–7.7, printed pp. 255–256/296, combined PDF pp. 435–436.


4. OBD-II is a diagnostic system—not the Government’s fuel-consumption test


OBD-II means second-generation On-Board Diagnostics. It is the vehicle’s diagnostic system: a technician can connect a scan tool and read fault codes, sensor information, fuel trims and other data generated or modelled by the car’s own electronic systems.


That can be extremely useful for finding a faulty sensor, an ignition problem, an abnormal fuel trim or another mechanical or emissions-related issue. But a diagnostic window into the car’s ECU is not automatically an independent measurement of the physical litres consumed.


The regulatory structure itself keeps the two functions separate. ICAT’s official M1-category CMVR Type Approval Ready Reckoner lists:


  • OBD-II at item 28 against Rule 115(18)(i) and AIS-137 Part 3; and
  • the Fuel Consumption Standard separately at item 31 against Rule 115G(1) and (2) and AIS-137 Part 3.

This wording reports ICAT’s published regulatory mapping; it does not claim that the consolidated text of Rule 115(18)(i) is formally titled “OBD-II.” The point is simpler: ICAT does not list OBD-II and the Fuel Consumption Standard as the same requirement.


An OBD scan may help diagnose why a car is performing badly. It is not, merely by being connected, the Government’s official fuel-consumption test.


(ICAT, M1 Category CMVR Type Approval Ready Reckoner 2025, PDF p. 2, items 28 and 31.)


5. CAFE is the average of a manufacturer’s fleet—not the mileage of one car


CAFE stands for Corporate Average Fuel Economy. In India’s technical framework, AIS-137 also uses Corporate Average Fuel Consumption for the numerical compliance calculation. Both refer to a manufacturer-level fleet average, not to the mileage of one individual vehicle.


The easiest way to understand CAFE is this: the Government looks at the sales-weighted fuel-efficiency performance of all the passenger vehicles sold by a manufacturer during the reporting period. A highly efficient small car can partly offset a less-efficient larger vehicle in the company’s overall average.


For an individual model, AIS-137 expresses the petrol-equivalent fuel-consumption figure as:


FCᵢ = pᵢ ÷ 23.7135


Here, pᵢ is the manufacturer-declared CO₂ value in g/km verified during type approval. For petrol, this is numerically equivalent to multiplying CO₂ by approximately 0.04217.


ICAT, Manesar, acts as the designated agency for examining and reporting the manufacturers’ corporate-average data. The Bureau of Energy Efficiency also explains that CAFE applies to the corporate average of vehicles sold by a manufacturer—not to the fuel consumption of an individual model.


Why is CAFE relevant to this article? Because it is another Government fuel-efficiency framework that can sound authoritative while answering a completely different question. CAFE tells us whether a manufacturer’s annual fleet meets a corporate target. It does not tell a dealer whether one already-sold car is returning 7, 10 or 11 km/l, and it does not identify the Minister’s “average machine.”


AIS-137 Part 3, Chapter 19, clauses 3.9, 3.10 and 3.14, printed p. 251/296, combined PDF p. 431; Chapter 19 Appendix 4, printed p. 266/296, combined PDF p. 446; Bureau of Energy Efficiency, “Fuel Efficiency.”


6. Vehicles can be examined after sale—but that still does not establish a dealer machine


AIS-137 contains in-service-conformity provisions. It would therefore be inaccurate to suggest that the regulatory system never examines vehicles after they enter service.


But those provisions concern formal emissions and OBD conformity. They involve manufacturer-supplied information, vehicle selection, sampling, prescribed procedures and action by a designated test agency. They are not a universal customer-mileage test conducted by an unidentified machine at every authorised dealership.


The Government’s newer test framework also recognises that laboratory and road performance are not automatically identical. AIS-175’s Introduction identifies one of the Worldwide Harmonised Light Vehicles Test Procedure (WLTP) primary goals as reducing variation between laboratory and road results—particularly for CO₂—through a more realistic driving cycle. The BEE draft CAFE-2027 framework discusses reporting under MIDC and, when separately notified by the Ministry of Road Transport and Highways, WLTP.


That is the institutional reality: laboratory certification, corporate fleet compliance, emissions conformity and a citizen’s mileage in real traffic are related subjects, but they are not the same test.


AIS-137 Part 3, Chapter 1, clauses 9.2–9.4, printed pp. 32–37/296, combined PDF pp. 212–217; Chapter 18 Appendix 3, printed pp. 248–249/296, combined PDF pp. 428–429; AIS-175, Introduction, printed p. II, PDF p. 2; BEE draft CAFE-2027 framework, paragraphs 4(3) and 4(8), PDF pp. 6 and 8.


PART 2: The Government’s system is named and documented. So where is the dealer’s “average machine”?


By this point, the contrast should be clear.


The official system has named test agencies, named rules, a named driving cycle, controlled laboratory conditions, measured exhaust constituents, published formulas, a declared tolerance and a conformity process.


The “average machine” described in the interview has not been given a name, a standard, a procedure or a legal status.


We examined the relevant Central Motor Vehicles Rules, AIS-137, AIS-175, ICAT’s M1 type-approval ready reckoner, the fuel-consumption and CAFE procedures, the provisions dealing with OBD and in-service conformity, and the relevant E20 fuel standards.


To the best of our knowledge, there is no machine that the Government of India has specified or mandated authorised dealers must carry for this purpose.


More specifically, we could locate no Government notification, AIS, BIS or CMVR provision that:


  1. identifies an authorised-dealer “average machine”;
  2. prescribes equipment that every authorised dealer must possess for independently measuring actual fuel consumption;
  3. specifies its calibration or metrological traceability;
  4. prescribes the test route, driving cycle or minimum test distance;
  5. standardises tyre pressure, passenger load, luggage load, air-conditioner use or ambient conditions;
  6. establishes a permissible measurement tolerance;
  7. requires the actual ethanol content of the test fuel to be verified;
  8. explains how the procedure separates a fuel-blend effect from traffic, driving behaviour, maintenance, tyre condition or a mechanical fault;
  9. treats the machine’s reading as decisive evidence in an individual consumer complaint; or
  10. certifies the equipment or procedure to determine whether E20 caused a particular mileage reduction.

This does not mean that no manufacturer has an internal workshop procedure.


A manufacturer may tell its dealers to inspect tyre pressures, scan for faults, review fuel trims, conduct a supervised road test, use a temporary fuel-measurement arrangement or follow a manufacturer-specific refill test.


But the distinction is fundamental:

An automobile manufacturer’s internal workshop procedure is not automatically a Government of India standard.

If such a procedure exists, the manufacturer should identify it, disclose what it measures, state its limitations and make clear whether it is merely an internal diagnostic method or a Government-notified test.


What if the Minister meant an OBD-II or proprietary scanner?


An OBD-II or proprietary workshop scanner is best understood as a diagnostic window into the vehicle. It can report what the car’s sensors and ECU have detected or calculated. Depending on the vehicle and software, it may show:


  • diagnostic trouble codes;
  • short-term and long-term fuel trims;
  • oxygen-sensor or air-fuel-sensor data;
  • airflow and manifold-pressure information;
  • injector-related parameters;
  • distance and operating information; and
  • ECU-calculated fuel-consumption data.

That information can help determine whether the car has a mechanical or electronic problem.


But diagnostic usefulness is not the same as independent fuel measurement. Unless the system uses a separately calibrated physical fuel-flow or gravimetric measurement device, it is generally reading or processing information generated by the car itself.


Connecting a scanner does not, merely by itself:


  • measure the physical litres dispensed into and consumed from the tank;
  • reproduce the AIS-137 chassis-dynamometer procedure;
  • establish the actual ethanol percentage of the petrol;
  • control the route, traffic, load, tyres and air-conditioning; or
  • prove whether E20 caused—or did not cause—the mileage reduction.

Even a genuine fuel-measurement device would not automatically prove E20 causation


Suppose a dealer possesses calibrated equipment capable of independently measuring the fuel consumed during a road or dynamometer test. That could establish fuel consumption under those particular conditions.


It would still not, by itself, prove that E20 caused the difference.


A credible E10-versus-E20 comparison would require verified fuels, the same vehicle in the same mechanical condition, adequate management of residual fuel, the same driver and load, matched tyre pressures and air-conditioning settings, comparable traffic and ambient conditions, repeated tests and a disclosed method of calculation.


An E10–E20–E10 sequence would be stronger because it would help show whether the effect repeats when the fuel changes and reverses when the original fuel is restored.


This is why “there is a machine” cannot be the complete answer. The machine, its measurement principle, the test procedure, the fuel and the test conditions all matter.


The question now goes directly to the manufacturers


Since this should not remain a rhetorical question, we are putting it directly to ten major passenger-vehicle manufacturers operating in India:


@Maruti_Corp

@TataMotors_Cars

@18002096006 — Mahindra

@HyundaiIndia

@Toyota_India

@KiaInd

@MGMotorIn

@SkodaIndia

@HondaCarIndia

@RenaultIndia


Does your authorised service network possess any equipment—beyond an OBD-II or proprietary diagnostic tool accessing the vehicle’s own ECU data—that independently measures actual fuel consumption and is capable of determining whether a mileage reduction is attributable to the ethanol blend?


If the answer is yes, please identify:


  • the equipment’s name, make and model;
  • what it physically measures;
  • its measurement principle;
  • its calibration and traceability requirements;
  • the test procedure and minimum distance or duration;
  • the accepted measurement tolerance;
  • whether the fuel’s actual ethanol content is verified;
  • the Government, AIS, BIS or CMVR standard certifying it; and
  • how the procedure separates fuel-blend effects from mechanical condition, traffic, tyres, load, air-conditioning and driving behaviour.

If no such equipment exists in your authorised network, that is a perfectly acceptable answer.


Just say so clearly.

Questions for the Minister


Mr Minister Sir, please identify the machine you referred to.


  • What is it called?
  • Who manufactures it?
  • What does it directly measure?
  • Does it physically measure fuel consumed, or does it read or model data generated by the vehicle’s ECU?

Under which AIS, BIS or CMVR standard is it certified?


  • What is its calibration procedure and accepted tolerance?
  • What route, test distance or driving cycle must be followed?
  • Must the ethanol content of the fuel be independently established?

Is the customer entitled to receive a signed test report containing the raw measurements?


And what is the statutory or regulatory basis for saying that a citizen’s mileage complaint becomes “true” only when this machine records it?


Name the machine. Name the standard.


If we have overlooked a notified Government protocol, VSJ Ventures LTD will publish the correction prominently ourselves.


If no such notified machine or protocol exists, please correct the public record.


The precise conclusion


The journalist’s personal account does not, by itself, scientifically establish that E20 caused the entire reported reduction from approximately 10–11 km/l to 7 km/l.


But an unidentified dealer machine does not scientifically disprove that causation either.


A citizen’s reported mileage experience does not become false merely because an undefined machine—operated under a procedure that has not been named, published or independently examined—has not yet pronounced upon it.


Until the machine and its governing standard are identified:


“There is a machine” is not a regulatory answer. It is an appeal to an undefined authority.


— Vishal Singh Jain

VSJ Ventures LTD




Primary references


  1. ABP Live, “‘Petrol And Ethanol Deliver Equal Mileage In Cities, Less On Highways’: Nitin Gadkari | EXCLUSIVE,” 13 July 2026.

https://news.abplive.com/business/e20-e10-petrol-row-nitin-gadkari-responds-executive-editor-megha-prasad-exclusive-interview-abp-news-english-live-updates-1856201

  1. ABP News official interview clip, 13 July 2026.

https://x.com/ABPNews/status/2076616398370173028

  1. Transcript of the relevant exchange, timestamps 0:00–1:21, supplied to and reviewed by VSJ Ventures LTD.
  2. Central Motor Vehicles Rules, 1989, Rules 126 and 126A; printed pp. 147–148, consolidated PDF pp. 165–166.

https://upload.indiacode.nic.in/showfile?actid=AC_CG_61_1084_00001_00001_1554966634246&filename=the_central_motor_vehicles_rules%2C_1989.pdf&type=rule

  1. AIS-137 Part 3, 2019, with Amendments 1–9: Chapter 1, clauses 9.2–9.4; Chapter 3, clauses 2.1.1, 2.2.1 and 7.0; Chapter 19, clauses 3.9, 3.10, 3.14 and 7.2–7.7; Chapter 18 Appendix 3; Amendment No. 9, p. 12 of 17.

https://icat.in/wp-content/uploads/2026/04/AIS_137_Part_and_Amd_1_to_9_9fc0babe-be9e-4d76-98d3-e5dd6f3e87f0.pdf

  1. ICAT, M1 Category CMVR Type Approval Ready Reckoner 2025, PDF p. 2, items 28 and 31.

https://www.icat.in/wp-content/uploads/2026/02/Final-Ready-Reckoner-M1-2025.pdf

  1. Bureau of Energy Efficiency, “Fuel Efficiency,” Corporate Average Fuel Economy Norms for Passenger Cars.

https://beeindia.gov.in/show_content.php?lang=1&level=2&lid=71&ls_id=346

  1. Bureau of Energy Efficiency, revised draft CAFE-2027 framework, paragraphs 4(3) and 4(8).

https://beeindia.gov.in/WriteReadData/L45218/9313987284299285.pdf

  1. AIS-175, March 2026, Introduction, printed p. II, PDF p. 2.

https://icat.in/wp-content/uploads/2026/05/1774512757_AIS-175_F.pdf

  1. Bureau of Indian Standards, IS 17021:2018 (E20 market-fuel specification) and IS 17943:2022 (E20 reference-fuel specification for type approval and conformity of production).

https://standardsbis.bsbedge.com/BIS_Preview.aspx?id=17021

https://standardsbis.bsbedge.com/BIS_Preview.aspx?id=17943_2022




The complete calculation methodology, equation sheet and clause-by-clause citation map can be supplied separately by VSJ Ventures LTD as a PDF or Word technical note.


VSJ Ventures LTD Strategic Intelligence Series — Independent Analysis Based on Publicly Available Information