Wright, Johnston & Mackenzie Solicitors

Volcanic Ash Flight Chaos: Can I get compensation for my cancelled flight?

The volcanic ash cloud caused by an erupting volcano in Iceland with an unpronounceable name has grounded aircraft across much of Europe. Thousands of frustrated passengers have had their flights cancelled and there are many passengers currently stranded not just in Europe but also globally, as far away as Sydney, Australia. 

When things go wrong for air passengers, it is not immediately clear to whom they should complain and what compensation they may be entitled to. Firstly, it should be made clear that the airlines have contracted with the passengers to take them to their destination and are under an obligation to either refund passengers or transfer them on to another flight. Unfortunately the volcanic ash cloud means for many people there are no transfer flights available and their return home is dependent on the Icelandic volcano’s activity. 

Secondly, in accordance with European law (EC 261/2004) if the flight (either one-way or return) has been cancelled within 14 days before departure then passengers are entitled to the following financial compensation (subject to the airline’s metaphorical “get out of jail free card” explained further below):

If journey length less than 1,500 kilometres and delay more than 2 hours:  250 Euros (less than 2 hours: 125 Euros)

If journey between 1,500-3500 kilometres and delay more than 3 hours: 400 Euros (less than 3 hours: 200 Euros)

If journey more than 3,500 kilometres and delay more than 4 hours: 600 Euros.
(less than 4 hours: 300 Euros)

All passengers who have their flights delayed longer than 5 hours should receive meals and refreshments and 2 free phone calls, emails or faxes. If the delay continues to the following day then hotel accommodation and related transfers should be provided. As stated earlier, if passengers decide not to travel they should be entitled to a refund. If passengers organise their own travel or hotel accommodation, they should apply to the airline for reimbursement on their return. However it should be remembered that an airline may only pay for reasonable costs so a taxi from Rome to Edinburgh is unlikely to be reimbursed!

Unfortunately where the flight has been cancelled more than 14 days before departure, no financial compensation is available. In addition, the airlines can rely on an exclusion clause. They are not obliged to pay compensation if they can prove that the cancellation was caused by “extraordinary circumstances, which could not have been avoided even if all reasonable measures had been taken”. The airline should still provide refreshments and hotel accommodation even if your cancellation was caused by extraordinary circumstances. Regrettably, given the present chaos, meteorological conditions incompatible with the operation of the flight concerned come within extraordinary circumstances (other examples might be strikes, political instability, security risks etc) and the airlines can argue the volcanic ash cloud is an extraordinary circumstance as a means of avoiding paying compensation to passengers for cancelled flights.

If your flight has been cancelled but not because of the volcanic ash cloud then you should contact your airline and request compensation. If the airline does not pay out then you should refer your claim to the Air Transport Users’ Council (ATUC) which is the consumer body for air passengers. If the airline is unable to prove that even if all reasonable measures had been taken, the cancellation would have been unavoidable then it should pay compensation. If negotiations between the ATUC and the airline fail to reach agreement on compensation despite the airline’s lack of proof, then the claim may be referred to the Civil Aviation Authority who can, as a last resort, proceed to prosecute the airline.

For those passengers affected by the volcanic ash cloud or another of the “extraordinary circumstances” then alternative ways of obtaining compensation should be pursued. Certain travel insurance policies may pay out if a holiday is cancelled due to flight problems however generally speaking “acts of god” like the volcanic ash cloud will be excluded; time to get the magnifying glass out and go through the small print!

Passengers who have booked package holidays should be refunded if their trips were cancelled preventing them from reaching their destination or be offered a suitable alternative holiday. A final option for the beleaguered passenger is to make a claim to their credit card provider under the Consumer Credit Act. However passengers may only be able to claim their money back if they booked their flights/holidays using their credit card direct with a company and not through a tour operator. 

For more information, contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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Online Defamation: If you can't say anything nice, don't say anything at all!

The growth of online auction sites such as eBay which allow users to post comments on other people’s profile feedback page had not prompted any defamation legal actions…until now that is. An American eBay buyer, Mr Steadman, was so enraged that he had received a broken clock from the seller, Mr Miller, that he wrote on the seller’s profile feedback page: “bad seller, he has the ethics of a used car salesman”.

Mr Miller was furious about Mr Steadman’s feedback comment and sued him in a Florida Court, claiming defamation damages for ruining his 100% feedback rating and harming his “commercial reputation”.

The legal action of “defamation” is often bandied around in the media and is generally associated with high profile celebrity cases. Many people may be unaware of the precise definition of defamation and the grounds for raising an action.

Defamation is, in essence, an attack on another person’s honour, character and reputation by a derogatory or disparaging statement. The three essential elements that you need to raise an action for damages are:

1. A defamatory statement.
2. The defamatory statement is false. 
3. The defamatory statement was made with malice.

However once the first element is established then the second and third elements are presumed. It is no defence to show lack of malice except in limited circumstances where the presumption does not apply for e.g. qualified privilege.

Taking our American eBay case as an example, the method of communication in Scotland is irrelevant, so posting a feedback comment on an eBay website which millions of eBay users can see meets the legal requirement.

In Scotland even if the feedback has only been accessible by the buyer and seller then a defamation action could still be raised based on the hurt caused to the seller although the damages may only amount to a nominal figure. This position can be contrasted with England and the USA, where the defamatory remark must be made known to a third party before a court action can be raised.

How do you know whether a remark is defamatory or not? Well the test is whether the statement tends to lower the individual’s reputation in the minds of right thinking members of society generally. In Scotland, the alleged defamatory remark has to be looked at objectively: would the reasonable man think the statement was defamatory?

If we consider the American eBay scenario; to call into question someone’s honesty may, depending upon the facts, be defamatory. If the victim of the allegations has had his professional competence called into question, which affects his economic well being, then this might give rise to a larger award of damages.

The Court has to take into account all the surrounding circumstances in order to decide whether a statement is defamatory. Statements made clearly in jest or in anger are not actionable, on the grounds that those whom the statements are directed to will not take them seriously. In the American eBay dispute, if we acknowledge the importance placed on feedback comments by eBay users then it is arguable that on balance, Mr Steadman’s comment may not be viewed as being a flippant “heat of the moment” remark.

However we should also bear in mind how easy it is to send off an ill-advised, short, emotional comment online. The defence that the statement was made in anger may not apply if the buyer has had time to gather his thoughts and consider a reasoned response.

A person alleged to have made a defamatory remark could rely upon the absolute defence of veritas; if the statement is true. However the law presumes that the accusation is false until proved, so the onus of proof rests with the defender in the action. In order to prove veritas, it may only be necessary to show a single disreputable act but certain accusations may require a series of acts to prove the statement is true. For example, a person accusing someone of being a liar would need to show several instances of dishonesty, rather than one single instance. A lack of knowledge of the person defamed and the distance between online users may hamper attempts to provide evidence of veritas in the defamatory statement.

In the American eBay scenario, where the accusation was aimed at the seller’s character, the buyer will need to prove a number of instances which illustrate that he was dishonest, rather than only one instance. It seems that the buyer’s feedback was the first time the seller had received negative feedback and so it is unlikely that the buyer could prove the defence of veritas if the action was taking place in Scotland.

The American eBay buyer’s comment was: “bad seller, he has the ethics of a used car salesman”. To establish a defence, the buyer has to prove the truth of the statement and justify everything in the “sting” of their allegation. So the inference from the comment taken as a whole is that the seller is dishonest and corrupt; that is what the buyer must prove.

If the defamatory statement cannot be proved then the buyer may still have a defence if the allegation does not injure the seller’s reputation. However if the seller was able to show that fewer people were going to bid for his items due to his new feedback rating of 98.8% then the defence is unlikely to succeed.

The level of damages the seller could expect to be awarded in Scotland, if successful, would be determined firstly by assessing his injured feelings. Secondly, an assessment would be made of the seller’s economic loss caused by the loss of reputation. The exact amount of damages will depend upon the facts of each case but generally damages for injured feelings in defamation cases have been assessed at modest levels of a few hundred pounds. However damages for loss of reputation can be far more substantial, in the region of several hundred thousand pounds.

The defender can mitigate the damages by issuing an immediate retraction of the defamation and offer an apology. Also if the circumstances are such that few people will become aware of the defamatory remark then that may reduce the damages awarded. In the American eBay scenario, damages will be greater if the seller can show that the profile feedback page containing the defamatory remark has been accessed by thousands of people. If the seller has provoked the statement by the buyer through his actions then the damages may be mitigated. Furthermore if the seller has little or no reputation then the damages for loss of reputation will clearly be significantly less, for example, the seller had only received two feedbacks and was a relatively recent Ebay user.

Taking into account all the circumstances of the American eBay defamation action, it does seem that if the circumstances arose in Scotland, the test for defamation under Scots law would be satisfied. Firstly, a reasonable man would likely find the comment to be defamatory, secondly the defence of veritas would be unlikely to succeed as this was the only instance of alleged dishonesty and thirdly, it would be difficult for the buyer to overcome the legal presumption that the feedback comment was false and made with malice to deliberately injure the seller’s commercial reputation.  However a Scottish Court would be less likely to award damages of £10,000; the amount sought by Mr Miller in the American Courts.

So the moral of the story is to be conscious of your own actions on the Internet and keep your eBay feedback accurate and factual rather than making any insulting or disparaging remarks. If Mr Steadman had simply posted: “Received broken clock, got a refund” then he would probably not be facing a defamation action from a livid seller.

For more information, contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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Can you sell a cow and sup its milk?

The seller of a business in the absence of a restrictive covenant could set up business in direct competition with the purchaser and adversely affect the purchaser’s financial interests. In addition, the competition reduces the value of the good will element of the business sold to the purchaser. If a restrictive covenant exists, prohibiting the seller from carrying on the same business within a defined area for a limited period of time, then the value of the business being sold increases.

Clearly, a restrictive covenant can be equally beneficial to both the seller and the buyer. The seller receives more for his or her business and the buyer’s new investment is protected. The sale of a business is freely entered into with competent legal advice and the Courts will be less inclined to hold the clause is unenforceable. However the restrictive covenant must be reasonable in the interests of the parties and in the public interest.

The Court will look at all the circumstances of the case: for example, the nature of the seller’s business and the character of the buyer’s business. Having taken into account all the relevant circumstances, the Court will then decide whether the restrictive covenant is reasonably required for the protection of the buyer’s business. The covenant must not be wider than necessary for the protection of the buyer’s business; it cannot amount to a general restraint of trading by either party. If the restrictive covenant is oppressive and greatly in excess of those required to protect the legitimate interests of the buyer, then in they eyes of the law, it is unreasonable. 

In considering whether a restrictive covenant is reasonable, two interests must be looked at: the interests of the parties and the interests of the public. What is reasonable will change with the shifting nature of commerce and society. For example customers can be approached via the Internet or mobile phone and delivery of a product can be made within hours or days. In order to determine what is reasonable, the character of a business must be looked at and also what the parties had in their contemplation at the time of making the contract. Standard form contracts negotiated between the parties are far likelier to be found reasonable than a standard form contract drafted by just one party.

Public policy is that trading should be encouraged and that it should be free. However if a restriction is placed upon a person’s trade, this is not in the public interest. However if the person’s restriction is restricted to a certain location then the public outside the restricted area will benefit and this will offset the disadvantage to the public within the limited area.

The person seeking to rely on the restrictive covenant will generally be required to show evidence but in many cases this may not be of importance; whether a restrictive covenant is reasonable is a question of law. The Court will place emphasis on the wording of the restrictive covenant so the greater the restraint in time, area, or business affected, the more the buyer must justify it with some detailed specification. The reasonableness of a period of time will depend on the circumstances of the trade involved. A seller of a hotel business in Glasgow was restricted from carrying on a competing hotel business within a one mile radius of the sold hotel for five years. The Sheriff in Randev v Pattar held that two years was reasonable but a five year period was too oppressive and rendered the restrictive covenant of doubtful validity.

A restrictive covenant usually states that the seller is prohibited from carrying on business “directly or indirectly”. A clause in such terms will usually prevent competition arising in other ways such as preventing financial assistance to another business or engagement as an employee or agent of another business.

So back to the title of the article; can a person sell a cow and sup its milk? Well, so long as the restrictive covenant is limited in time and space, and those limitations (neither too wide nor too oppressive) are reasonable for that particular trade then the seller is unlikely to be able to sell the cow and sup the milk too. 

For more information, contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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Have you “waived” goodbye to your claim?

In the heat of the moment we are all liable to do or say something we later regret. However when these actions may weaken our legal position in a case; knowing what amounts to waiver takes on greater importance. 

The famous Scottish legal textbook author, Gloag, back in the 1920s stated that a person can waive their right to a claim if they say or do something which suggests that they do not wish to insist on a contractual clause. Alternatively the person alleging waiver may have decided not to take steps to insist upon the contractual clause due to the the other person’s actions.

To waive a contractual clause, the action or statement not to claim a right or raise an objection must be voluntary, informed and unequivocal. Whether someone has abandoned their right is a question of fact and the person relying on the action or statement doesn’t have to have suffered any inconvenience, or prejudice for waiver to exist.

Clearly a person can waive their right expressly and this is quite straightforward, however problems may arise where an argument put forward that a person’s actions, impliedly waived their right. 

The true test was of whether someone has waived their right to a claim was stated in the case of D&J McDougall Ltd v Argyll and Bute District Council. Lord Weir said that you had to look at the particular circumstances of the case to see whether the person was in any sense abandoning their right and then ask whether their actions were what a normal person would do trying to claim their right to do something, such as go to an Arbitration Tribunal instead of a Sheriff Court.

It doesn’t matter if a person on the face of it abandons their right but actually does not intend to abandon their right “in their own mind”. The Court will not try and read the mind of the person alleged to have waived their right. The judge will instead decide whether the right was abandoned by looking at what the person alleging waiver was entitled to assume from the other person’s conduct.

Delay, even a lengthy delay, putting forward a claim cannot amount to evidence of waiver of the right to do so. However, that said, if the delay is entirely unnecessary and has caused the other party great expense, taking account of party’s actions causing the delay will entitle the Court to hold that the party has waived its right.

Once a dispute has arisen or is likely to arise, it is wise to consult a solicitor at an early stage to ensure that no statements or conduct take place that could unwittingly “waive” your right to claim.

For more information contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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Ask WJM!

QUESTION

Dear Sirs,
I have lived in Spain for 12 years and now wish to have Spanish nationality.
How do I go about doing this?
Also do I have to give up my UK passport?
Many thanks. 

WJM ANSWER

In order to apply for Spanish nationality, the general rule is that you must have lived there for at least 10 years. However if you are married to a Spaniard then the period of residence required will be reduced to 1 year. In your case, you are eligible to apply for nationality due to your long period of residence.

You must file an official application form with your local Spanish Civil Registry. You will need to provide the Civil Registry with your own birth certificate, a British Consular certificate, your Spanish registration number, and a police certificate stating the time of legal residence in Spain.

Any documents written in English such as your birth certificate will have to be translated into Spanish and legalised by the British Consulate or the UK Foreign & Commonwealth Office. Generally, you will have a decision from the Spanish authorities within 2 years.

Unfortunately, Spain does not recognize dual nationality (apart from citizens from former colonies such as Peru or Bolivia). If you do proceed with your application for Spanish nationality, you will have to formally renounce your British nationality before a Spanish judge, and swear an oath of allegiance to the Spanish Crown.

Ask WJM

If you have a question for WJM, we may publish the answer to your question in our “Ask WJM” section of our Lawsuit! E-zine; you can email your questions to .(JavaScript must be enabled to view this email address)

 

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Internet use in the workplace: a digital dilemma?

It is common for employees to use the internet at work for personal use, and most employers are content to allow their employees to do so during their lunch break or outside their working hours. However when the workload of an employee dips and they have no tasks to do, should they be disciplined or summarily dismissed for using the internet for personal use during working hours?

On the one hand, personal use would appear to affect employee productivity and time devoted to work related tasks, thereby increasing employers’ costs. However, on the other hand, if there are no work tasks to do, has any harm been done? Moreover, does policing the employee’s internet use amount to a breach of their right to a private life and correspondence, as illustrated in Copland v UK Government [2007] ECHR 253? These are not easy questions to answer, but the recent employment tribunal decision of Grant and Woods v Mitie Property Services (UK) Ltd (Cases S/113536/08 & S/113613/08) may have shed some light on the issue.

Summary dismissal

The backround to the case is that both the claimants worked as administrators for the respondents in the same office, mainly dealing with invoices and financial record keeping. They were both provided with a personal computer to allow them to carry out their duties. The PCs were linked up to the respondents’ area network and this enabled the claimants to access the internet.

The claimants were allowed to use the internet for personal use so long as it was outside “core working hours”. However their manager became suspicious of Internet misuse because on several occasions, when he approached their desks during working hours, the internet website windows would immediately be clicked out, leaving a blank desktop. The manager asked the IT department to produce a report showing all the websites they had been on with dates and times. A number of non-business related websites appeared on the report such as easyjet.com, boots.com, and virgin.net. Also many of these websites had been accessed during working hours.

The respondents decided that the claimants were in breach of their IT policy, which allowed personal use of the internet but “subject to it being outside core work times”, and promptly proceeded with disciplinary action. Following suspension and separate disciplinary hearings, the respondents summarily dismissed the claimants on the basis that their misuse of the internet amounted to gross misconduct and contravened the IT policy.

Both claimants appealed, arguing that the sanction imposed was excessive and that “unauthorised overuse of the internet” was not specifically mentioned in the list of examples of gross misconduct in the employee handbook. In addition, it became clear that both the claimants would only use the internet for personal use when they had completed their tasks and were “looking for work”. However the respondents, in rather crude terms, stated the claimants had committed fraud by taking wages when they had not been working.

One out of two

In establishing that the dismissals were fair, two hurdles had to be overcome by the employer. The first hurdle was whether at the time of taking the decision to dismiss, the employer had a genuine belief that the employee was guilty of the misconduct in question. Such belief must be based on reasonable grounds and after having carried out as much investigation into the matter as was reasonable in the circumstances.

The second hurdle that required to be overcome was whether the respondents had acted reasonably in terms of s 98(4) of the Employment Rights Act 1996, in treating use of the internet within working hours for non-business purposes as sufficient for dismissal. The claimants submitted that a reasonable employer would have warned them and given them an opportunity to improve. In deciding that the misconduct was sufficient for dismissal, the respondents’ decision must fall within the range of reasonable responses available to a reasonable employer. However the tribunal when judging the employer’s reasonableness must not substitute its own decision as to the right course to adopt for that of the employer.

The tribunal held that the respondents had overcome the first hurdle, as they had a prima facie genuine belief because during the investigation the claimants had admitted using the internet outwith working hours. However they failed to overcome the second hurdle because the tribunal decided that the decision to dismiss fell outside the range of reasonable responses available to a reasonable employer.

One of the reasons given for dismissing the claimants was that the misconduct in question was similar to one of the examples of gross misconduct given in the disciplinary policy. However the tribunal decided that simply because an example of misconduct had been listed as an example of gross misconduct did not mean that the misconduct was sufficient for dismissal, otherwise employers could list trivial misconduct to avoid unfair dismissal claims. Notably, there was no specific example of personal use of the internet within working hours constituting gross misconduct in the respondents’ disciplinary policy.

The tribunal also observed that mere use of the internet is not a serious offence. However if the websites visited had been illegal or had sexual content, such use would have been classed as gross misconduct, as established in Thompson v London Borough of Hillingdon (EAT/1317/01). In addition, both claimants had long periods of service with the respondents, and in light of the long service they should have been given a warning as a first disciplinary offence rather than dismissal. Moreover, the claimants’ conduct had not been detrimental to the respondents, who failed to show that the claimants had failed to carry out work while using the internet for personal use. Furthermore the IT report was found to be inaccurate in places and could not state the length of time the claimants had been on each site. There had also been a reported falling out between the claimants and their manager prior to the dismissal. Taking account of all the aforementioned circumstances, the tribunal decided that dismissal as a sanction fell outside the band of reasonable responses.

Preventative action

What should employers do to prevent a similar situation? First, employers should ensure they have a robust IT policy on acceptable internet use that establishes the boundaries of the uses that may be made. If the policy allows “reasonable” personal use, it should be made clear what amounts to “reasonable”. A strong well-defined policy will also enable employers to utilise the disciplinary measures if an employee falls foul of the policy. However the policy should seek to achieve a balance between business and personal use.

In addition to bolstering the IT policy, software can be installed in the PCs to limit the number of sites that may be viewed. However employers should consult employees in advance of installing the software to ensure it is not too restrictive, which could damage existing employment relations.

Monitoring employees by opening emails and checking websites visited is potentially a breach of the first data principle in the Data Protection Act 1998 (“the DPA”). It could also amount to a breach of article 8 of the ECHR relating to right to respect for private and family life. Employees have no absolute right to privacy. However where employers wish to undertake monitoring, they should always obtain consent prior to monitoring as that will help reduce that expectation of privacy that employees may have. The Halford and Copland cases confirm that employees are entitled to expect a degree of privacy even while at work. Providing some means of making personal communications that is not subject to monitoring will also mean that the monitoring of other communications is more likely to be considered a proportionate measure.

Employers should always weigh up the business need for the monitoring against the undesirable impact of monitoring. It should also be borne in mind that covert monitoring of employees should only be undertaken in very exceptional circumstances. An employee could in theory raise an action for damages in the sheriff court for a breach of the DPA, although awards have thus far only been made where the breach has led to serious harm.

If difficulties do arise and an employee is found to be misusing the internet then employers should ensure a thorough investigation has been carried out and there is adequate evidence of misconduct. In addition, any disciplinary action must be reasonable in the circumstances and an employee should not be dismissed for a first disciplinary offence unless it is a clear case of gross misconduct such as viewing websites with sexual content.

Employers should take heed of the following points. First, always think twice before summarily dismissing an employee who has had no previous disciplinary action and has a long period of service. Secondly, take note of the explanations given by the employee and take their comments into account when deciding whether the misconduct merits disciplinary action. Finally, a disciplinary hearing should be arranged and if the employee is found guilty, a letter in writing should be sent to him or her setting out the nature of the conduct and the change in behaviour required. The employer should maintain a repeated emphasis on improvement and providing the employee with clear, consistent notification of changes to the IT policy without resorting to needless alarmism. If the employer takes the necessary steps outlined above, the likelihood of the internet causing dilemmas in the workplace will be greatly reduced.

For more information contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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Two negatives don't make a positive!

You want someone to do something that they refuse to carry out. What legal remedy can help you? The remedy is specific implement; which is a court action raised to compel someone to do something. If you don’t want someone to do something then you can use the remedy of interdict. However sometimes the line between specific implement and interdict can become blurred as the case of Grosvenor Developments (Scotland) Plc v Argyll Stores Ltd illustrated.

Tenants of a supermarket gave notice to their landlords that they intended to stop trading from their premises in January 1987. However the lease stated that the tenants had to remain trading in the premises until January 2016. The terms of the lease prevented the tenants from assigning their lease to someone else. The landlords refused to consent to assignation of the lease. The landlords obtained a temporary interdict preventing the tenants from “ceasing to continue to occupy and use the supermarket premises trading as a supermarket”. The decision was challenged and ended up in the Court of Session in Edinburgh.

The judges found in favour of the tenants and decided that an interdict could not be obtained when it compels someone to do something because interdict is a remedy that can only prohibit or restrain someone from doing something. In addition they made the point that you cannot juggle words around to enable a positive order to be disguised in the form of a double negative. They also saw the interdict for what it was, a positive order for the tenants to continue to occupy the supermarket premises, which had been craftily disguised as a “negative” interdict.

The question arose: why not use specific implement instead of interdict? The landlords said they had no choice as their “anchor” tenants were going to leave the premises and by the time they had received an order for specific implement it would have been too late: the premises would have been empty. The other problem preventing specific implement was that the tenants had not yet formally rejected the lease so it was inappropriate for the landlords to implement provisions of the lease.

The judges ruled that the interdict was incompetent as the landlords were using it to try and enforce a positive obligation. They also made the point that even if it had been competent, the lease had clauses that allowed the tenants to escape the lease subject to various events arising – how could the Court foresee the next 28 years? Finally enforcement of interdict is imprisonment – how could a company be imprisoned? Although Scottish legislation allows Courts to impose fines on companies in place of imprisonment, fines are unlikely to dissuade tenants from breaching the terms of an interdict.

Distinguishing between positive and negative obligations can be problematic. So where circumstances arise where specific implement seems the best remedy, interdict may very likely be incompetent.

For more information contact Neil Morrison: .(JavaScript must be enabled to view this email address)

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