THE plane on which at least 21 people lost their lives yesterday would have been banned if the Indonesian Government had introduced new rules it has mooted in response to a string of crashes and accidents.
The Boeing 737-400 was built in 1992 and would have exceeded the 10-year age limit the Government has talked about placing on jetliners operated by local carriers.
The plan, announced last week, is being hotly contested by Indonesia's start-up airlines and is seen by industry experts as an over-reaction compared with beefing up the nation's aviation regulatory system.
The plan was hatched by the Government as it tried to grapple with the rapid expansion of the local industry and in the wake of the deaths of 102 people on an Adam Air jet in eastern Indonesia on January 1.
Last month, another plane operated by Adam Air landed so hard the fuselage buckled and broke near the wings. Authorities grounded the entire fleet.
And just before Christmas, a Boeing 737-400 operated by Lion Airlines bounced down a runway on Sulewesi, damaging the plane.
Yesterday's tragedy means Indonesian operators have suffered 10 accidents since the beginning of March last year, four of them involving fatalities.
This is despite the fact the nation is considered compliant with International Civil Aviation Organisation guidelines.
Much of problem is laid at the feet of the low-cost operators that have sprung up in recent years, often using cheaper, older planes.
''Indonesia does have a challenge, which is to cope with the massive growth that they've had in aviation over the past five or six years,'' said Nick Leonides, the Singapore-based regional manager for Flight International.
''They've grown very, very rapidly, the number of domestic airlines have ballooned, and that would put strain on any aviation system anywhere in the world.''
Mr Leonides said the Indonesian Government was aware it had transport safety issues and had admitted improvements were needed. ''They need to put that into action so I think everyone will be watching to see how they do,'' Mr Leonides said.
Indonesian transport officials concede there is a problem with enforcement and that the nation's regulator does not not have enough safety inspectors, although it has been boosting its accident investigation capabilities in recent years.
They say budget airlines also work their planes hard -- using up to 95 per cent of the fleet and making it hard to schedule inspections.
''The regulations are complete enough ... but the problem is, maybe, we have to improve law enforcement,'' National Transportation Safety Committee official Martono told Agence France-Presse recently. ''We have to enforce all the regulations if we are to change this situation.''
Garuda is not seen as being in the same risk category as its budget competitors, despite major financial difficulties that left it unable to pay its debts at the end of 2005 and the fact it is still negotiating with creditors.
Yesterday's accident was Garuda's 11th since 1982. Seven of those have involved fatalities.
However, the Indonesian flag carrier is considered to have ''a pretty decent safety record these days'', Mr Leonides said.
''There's no reason to believe at this stage that they have been skimping on maintenance or safety in any way whatsoever,'' he said. ''Their maintenance operation is called GMF Aero Asia and it's sort of a spun-off part of the business, it operates independently from Garuda itself. It carries out maintenance of Garuda aircraft but it also carries out maintenance for third-party customers and it has a decent reputation.''
Garuda's last fatal accident was in January 2002, when a Boeing 737-300 on a domestic flight had a dual-engine flame-out.
''With some brilliant piloting they brought the aircraft down and I think, except for one flight attendant, everyone survived almost unscathed,'' he said.
Saudi Arabia is considering banning Indonesian airlines from its airspace, but is first reviewing the flight safety record.
After the plane's front wheels broke off, fuel tanks in the right wing were ruptured, enabling the fire to spread.