The Court of Appeal has dismissed Ryanair Limited’s appeal against a High Court decision refusing to order former pilot John Goss to provide further details in a defamation case. The appeal concerned particulars of the case Ryanair may have to meet at trial; it did not decide the underlying defamation claim.
Ryanair began proceedings after Channel 4 broadcast “Dispatches: Secrets from the Cockpit” in August 2013. Goss, who had been dismissed by Ryanair on 14 August 2013, appeared in the programme. The judgment records allegations in the broadcast that Ryanair’s fuel conservation policies could compromise passenger safety, and that pilots had concerns about raising safety issues through the airline’s internal systems and about responses from aviation authorities.
Ryanair’s claim included allegations that the programme said or implied that the Irish Aviation Authority (IAA) was turning a blind eye to safety issues at the airline. Goss pleaded that the allegations were true in fact and substance under section 16 of the Defamation Act 2009. He said he had made confidential reports to the IAA in 2006 and 2007, including concerns about aggressive management behaviour and simultaneous refuelling and boarding. He also pleaded that he and other Ryanair pilots had made reports to the IAA and received no substantive response. These are pleaded claims, not findings in this appeal.
Ryanair sought further particulars on two points. On the first, concerning alleged aggressive management behaviour, Goss’s counsel clarified that the incidents relied on were in reports already provided to Ryanair. Ryanair accepted that this point was adequately particularised, so the Court of Appeal did not consider it further.
The other request concerned details of similar complaints allegedly made by other Ryanair pilots to the IAA without substantive responses. Ryanair wanted information that could help identify complaints for discovery. The court held that Ryanair already knew the case in broad outline: that some pilots had filed confidential safety reports with the IAA and received no substantive response. It concluded that particulars need to give the general range of the case to be met, but do not ordinarily require a party to disclose specific evidence such as complaint dates or pilots’ identities.
The court therefore affirmed the High Court’s refusal to order answers to the disputed particulars and dismissed Ryanair’s appeal. The judgment addressed only the request for further particulars; it made no determination of the defamation claim itself.