Massa v FIA - Unlawful Means Conspiracy Appeal
Summary
The FIA has sought permission to appeal to the UK Supreme Court against a High Court decision declining to strike out Mr Filipe Massa's claim in the tort of unlawful means conspiracy. The underlying dispute concerns the 2008 Singapore Grand Prix, where Mr Massa alleges that a deliberately caused crash by Renault driver Nelson Piquet Jr cost him the F1 World Championship by one point. Jay J struck out claims for breach of contract, inducing breach of contract, and tort against the FIA, but allowed the unlawful means conspiracy claim to proceed. The Supreme Court will consider four novel questions on the elements of unlawful means conspiracy.
“The appellants now appeal directly to the Supreme Court against Jay J's decision not to strike out the respondent's unlawful means conspiracy claim.”
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GovPing monitors UK Supreme Court Decisions for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 9 changes logged to date.
What changed
The UK Supreme Court will hear the FIA's permission to appeal against Jay J's decision not to strike out the unlawful means conspiracy claim. The appeal raises four distinct legal questions: whether the tort can be founded on a civil wrong not independently actionable by the claimant, a breach of contract to which the claimant is not a party, a breach of foreign law, and conduct the defendant did not know to be unlawful.\n\nFor legal practitioners and sports organisations, this case could significantly reshape the scope of unlawful means conspiracy in English law. The issues extend beyond Formula One to any commercial arrangement where a claimant without contractual privity seeks to hold multiple defendants liable for an alleged wrongful act. Sports governing bodies, team operators, and their advisers should monitor this case closely given its potential to expand or restrict access to conspiracy claims in commercial and sporting contexts.
Archived snapshot
Apr 24, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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TORT
Massa and others (Respondents) v Fédération Internationale de l'Automobile (Appellant)
Permission to Appeal application lodged
Contents
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Case summary
Case ID
UKSC/2026/0037
Parties
Appellant(s)
Fédération Internationale de l'Automobile
Respondent(s)
Filipe Massa
Bernard Charles Ecclestone
Formula One Management Limited
Issue
Can the tort of unlawful means conspiracy be founded on:
- a civil wrong that is not independently actionable by the claimant?
- a breach of contract to which the claimant is not a party?
- a breach of foreign law?
- conduct that the defendant did not know to be unlawful?
Facts
Mr Massa is a retired Formula One (F1) driver who raced for various F1 teams between 2002 and 2017. In 2008 his team was Ferrari and he was their lead driver. The inaugural Singapore Grand Prix took place on 28 September 2008. On lap 14, one of the Renault drivers, Nelson Piquet Jr, deliberately crashed his car in order to aid his colleague, Fernando Alonso. Mr Hamilton won the 2008 Grand Prix season as F1 World Driver’s Champion one point ahead of Mr Massa. Mr Massa alleges that had the crash been investigated and acted upon in 2008, the Singapore result would have been annulled, and he would have been the F1 World Driver’s Champion for the 2008 season.
On 24 March 2024, Mr Massa issued proceedings against the appellants. Mr Massa advanced the following claims: (1) a claim in breach of contract against the Fédération Internationale de l'Automobile (“FIA”), (2) a claim in the tort of inducing breach of contract against Formula One Management Limited (“FOM”) and Mr Ecclestone, (3) a claim in the tort of unlawful means conspiracy against all three respondents and (4) a claim in tort against the FIA founded on alleged breaches of a duty owed by the FIA under its Statutes. Mr Massa contended that he was entitled to both damages and declaratory relief.
On 17 January 2025, the appellants applied to have Mr Massa’s claims struck out and/or for reverse summary judgment. By Orders dated 20 November 2025 and 5 March 2026, Mr Justice Jay struck out claims (1), (2), (4) and the claim for declaratory relief. He declined, however, to strike out the claim in the tort of unlawful means conspiracy.
The appellants now appeal directly to the Supreme Court against Jay J’s decision not to strike out the respondent’s unlawful means conspiracy claim.
Date of issue
27 March 2026
Case origin
PTA
Linked cases
UKSC/2026/0034 Massa and others (Respondents) v Ecclestone (Appellant) Related case
UKSC/2026/0035 Massa and others (Respondents) v Formula One Management Limited (Appellant) Related case
Previous proceedings
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