Last week the group’s administrator revealed that those who had booked with the failed company would likely receive just £7.50 each, as Lowcost had only a “very limited” bond of £1.09 million with the Spanish travel agency regulator.

But industry experts have now queried whether consumers might be able to challenge the Spanish government on this, based on rulings in other countries.

Consultant Andy Cooper, of Owens Cooper Consulting, said: “The Balearic authorities should have complied with the Package Travel Directive, so people who booked with the company they were responsible for, were protected. I don’t see why a claimant lawyer couldn’t put into action a claim on that basis.”

Cooper used the example of Dillenkofer V Federal Republic of Germany in 1996, which saw the European Court of Justice rule in favour of an individual who successfully challenged Germany’s failure to implement the PTD when a tour operator went bust and left him out of pocket. The court found in favour of Dillenkofer and held the German state liable to compensate him for the tour operator’s failure.

There is also another example of a similar case in Austria.

Matt Gatenby, partner at solicitors Travlaw, agreed that the precedent had been set. “The only difference is that in both cases it was the citizens of that country making the claims against the state. In this case, it would be UK citizens making a claim against Spanish authorities, but I can’t see any barrier to that.”

Gatenby stressed that it was currently still “early stages”, but said he believed lawyers “would at least have a good argument to make” against the Spanish body.

“PTD states that [EU] member states have an obligation,” he added. “The Balearics should have made sure that there were sufficient monies to fulfil that role.”