In this context, recent Spanish press reports to the effect that Ryanair has been threatening the Spanish Government in this same way if it does not turn a blind eye to Ryanair´s failure to date to pay a series of major fines levied by consumer authorities make me wonder
Can you provide examples of other countries where consumer bodies can levy fines where person getting hit with fine has not been charged nor evidence produced in a court of law.
Given Iberia and Spanirs performance over the years then a history of all the fines levied and paid by them would also be useful.
Otherwise it them comes down to an unelected Quango imposing fines on whoever it dislikes with a party unable to defend itself in any court of law or see the evidence the Quango has manufactured.