Thousands of flights were cancelled or delayed in the summer when pilots and cabin crew walked out.
The Civil Aviation Authority says passengers are entitled to compensation under EU law.
But Ryanair, run by Michael O’Leary, claims it doesn’t have to pay since the strikes were “extraordinary circumstances”.
Passengers flying to or from an EU airport get compensation if the flight is delayed for three hours or more — or if it’s cancelled and the airline is to blame. Payouts for short haul flights are £229.
Some reports say 100,000 passengers, or around 600 flights, were affected.
Rory Boland, editor of Which? Travel, said: “Customers would have been outraged Ryanair attempted to shirk its responsibilities.”
The CAA said passengers will now have to wait until the outcome of its action.
“Extraordinary circumstances”, normally involve bad weather or air traffic controller strikes.
But the CAA said the strikes by Ryanair’s staff were not in that category.
Ryanair warned over profits in October after it was stung by strikes and higher oil prices.
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