F-1 VISA India Vacation - NIE Approval Required to Return US

Hi,

My brother-in-law is currently in US on F-1 VISA doing his MS studies.
He has to travel India next month on some important personal work.

Should he apply for NIE approval to return back to US ? Can he travel India and come back without NIE ?

Regards,
Vijaya Kumar B

F-1 are exempt from NIE.

https://in.usembassy.gov/visas/national-interest-exception-frequently-asked-questions/