You can use a workflow property - it's the same trick as stopping people from editing closed issues.
https://confluence.atlassian.com/display/JIRA/Workflow+properties (it's for the most recent Jira, but the comment property has been there since at least v4, and the principles have not changed)
haha...happens. Alright, So the scenario goes as follows, we have a business user, who only communicates via email, so they add comments via email - these users typically don't even log into JIRA. So if they try comment on an issue that is closed, they will have no way of knowing their comment got ignored by JIRA email handler? Any advice?
Bother, via email, of course. I really have not had enough coffee this morning. Off the shelf, I can't think of a way to do this. Deep in my past though, this was one of two reasons I wrote an email handler for Jira - it would respond to incoming emails with "sorry, couldn't comment".
I haven't got a lot really, this was for Jira 3, and I just followed the developer guide at the time. The more recent one is at https://developer.atlassian.com/display/JIRADEV/Message+Handler+Plugin+Module
Just in case you dont fancy develop your own mail handler. This function is now available in latest version of EMH 1.5.4
Be aware this is a commercial plugin!
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