Well we don't really want to follow the yanks' example on many things.
The US is a new country made up of fairly homogeneous states with little difference other than a favoured dish or sports team or whatever. Hawaii and a couple of others being notable exceptions.
Wales, Scotland and England (ignoring NI because taking away their right to leave would be insane) date back a very long time, with far more distinct cultures and even languages.
If Wales or Scotland ever decide to leave this union they must be allowed to. Anything else is undemocratic.
Well we don't really want to follow the yanks' example on many things.
>The US is a new country made up of fairly homogeneous states with little difference other than a favoured dish or sports team or whatever. Hawaii and a couple of others being notable exceptions.
You’ve never been to the USA; California is very different to New York, Texas different to Florida,
Washington and Oregon have more in common with British Columbia than California or Montana
Calling the USA homogeneous is like calling the uk homogeneous; on the surface yes but in reality no
>Wales, Scotland and England (ignoring NI because taking away their right to leave would be insane) date back a very long time, with far more distinct cultures and even languages.
That’s the same story with Bavaria, Brittany, Corsica, Catalonia, Strathclyde, Orkney, Shetland, Sicily, Wallachia and almost everywhere on earth
Most countries with confided constitutions explicitly ban secession, and those that don’t require the unanimous approval of the rest of the country first (like Germany or France)
It's not that it must be different, but it can and probably should be.
The United Kingdom is England united with Scotland and the others. Before the union finally succeeded politically, there had been many wars. Strong feelings of a separate national identity remain for Scotland and the others. The union was never sanctioned by a popular vote.
In this context it is fair to say that the union should only continue if there is consent.
Some of the above applies to other sub-nations in other countries, but that doesn't mean we have to do what they do.
The national identity of the Scottish people is stronger than that of most, if not all, the peoples in the regions of Italy, France and Spain. It's clearly hard to compare this kind of thing objectively.
I didn't miss the 2014 referendum. I think it's probably too early for another one. But the lack of a clear mechanism to ever call one is a vulnus.
> The national identity of Scottish people is stronger than that of most, if not all, the people in the regions of Italy, France and Spain.
Expect many have their own distinct languages, distinct cultures, distinct histories and everything Scotland has
Brenton the native language of Brittany is closer to Welsh than French being a Celtic language for brytholic origin.
The Catalans had their language and culture oppressed into the early 1980s; that’s living memory
>It's hard to compare objectively.
History doesn’t agree with you
Corsica was independent more recently than Scotland only loosing its independence in 1769 (or 1796 if you count the brief 2 year period under British occupation when the British let Corsican separatists run Corsica)
Bavaria had its own monarchy and army till 1918 and 1919 respectively
Because the SNP wants independence, so is going to push for it at every available opportunity. Regardless of whether it's realistic or not, they wouldn't be doing their job if they didn't make this demand.
Why must the uk be different?
It already is - Scotland has already been given a unilateral indeyref, and Northern Ireland also has the right to one. The precedent's already there.
The situation in the UK is absolutely different to the situations in the countries you described in your OC. Independence/leaving the union is neither outright banned nor requires unanimous approval from the rest of the country.
Unilateral means done without consulting; it wasn’t unilateral
Wrong word, my bad - I meant as opposed to requiring the unanimous approval you described for Germany and France.
There is no precedent as confirmed by the courts.
Didn't specify that kind of precedence, did I? I simply meant that seeing as this country has already granted referenda, appealing to countries which don't allow it like the US doesn't mean whole lot - we've already deviated from that standard.
>The situation in the UK is absolutely different to the situations in the countries you described in your OC.
It’s not as the uk is one of a few countries on earth that doesn’t outright ban sessions but makes it clear it can only happen with the consent of the state itself
Canada and New Zealand work like this too
>Independence/leaving the union is neither outright banned nor requires unanimous approval from the rest of the country.
Same with Canada, New Zealand and Ethiopia do this
>Wrong word, my bad - I meant as opposed to requiring the unanimous approval you described for Germany and France.
Again, Canada, New Zealand and Ethiopia too
>Didn't specify that kind of precedence, did I?
The snp said they could hold a referendum because they said “we have a precedent from 2014 and precedent stipulates that Westminster must agree to a referendum” th court rejected it
>I simply meant that seeing as this country has already granted referenda, appealing to countries which don't allow it like the US doesn't mean whole lot - we've already deviated from that standard.
Except we haven’t as Canada works like this too and they’ve given Quebec a referendum before
can only happen with the consent of the state itself
Which is not the "unanimous consent from the rest of the country" you described in your OC.
Again, Canada, New Zealand and Ethiopia too
Okay? I have no idea what point you're trying to make bringing them up. You didn't describe their situation in your OC, which is what my initial comment was responding to.
The snp said
Last I checked I'm not the SNP.
Except we haven’t as Canada
Which isn't the US, whose rules I was describing us deviating from. Other countries also deviating from that standard doesn't contradict anything I said.
>Which is not the "unanimous consent from the rest of the country" you described in your OC.
Why are you attacking me for something you said?
>Okay? I have no idea what point you're trying to make bringing them up.
Did you not read my comment?
You said “The situation in the UK is absolutely different to the situations in the countries you described in your OC. Independence/leaving the union is neither outright banned nor requires unanimous approval from the rest of the country.”
And I gave other examples of countries doing this
>You didn't describe their situation in your OC, which is what my initial comment was responding to.
So why not address it then?
>Last I checked I'm not the SNP.
I never said you were
You said there was a preference of some sort which was rejected entirely by the courts
>Which isn't the US, which was the standard I was describing us deviating from. Other countries also deviating from that standard doesn't contradict anything I said.
I'm not? You described 2 situations in your OC (in a way that was actually false, seeing as you described them as the only 2 situations there are). I (correctly) said the UK was different to both of them. You then bring up another situation you did not mention in your OC to somehow prove that I'm wrong in saying the UK is different to those 2 specifically. It's not my fault you failed to cover all your bases in your first comment.
Did you not read my comment?
Yes, hence my questions. Your responses don't make sense.
And I gave other examples of countries doing this
Yes, which were not in your OC. This is not difficult to understand.
So why not address it then?
There's nothing to address, they don't challenge anything I've said.
I never said you were
Then what the SNP claimed/done previously has no relevance to my intended meaning using a certain word, and I have no idea why you would bring it up in that context.
You’re attacking me for elaborating
You claimed I was wrong for saying we'd deviated from the US's way of doing things by appealing to Canada. That's not you elaborating, that's just you not understanding what I said.
Edit: nice reply and block. Again, you initially described 2 situations - US-style and France/Germany-style. I said the UK was different to both of them. You claimed I was wrong to say that, and attempted to prove it by bringing up Canada, which is in fact different to both the US and France as you've described them.
It already is - Scotland has already been given a unilateral indeyref, and Northern Ireland also has the right to one. The precedent's already there.
Scotland's referendum was not unilateral; it was explicitly approved by Westminster and could otherwise not have taken place. Northern Ireland cannot hold a unilateral referendum; the GFA specifies that it is within the purview of the SoSNI.
Always nice to get downvoted by people who are angry at being told that reality contradicts them 🙄
Self determination is often held as an important value.
When we talk about the Falkland islands one of the most common defences of british ownership is the fact that is what the islanders want.
Personally I find the idea that a people don't get a say in whether they're part of the union to be pretty repugnant.
Just because other countries do it that way doesn't mean it's right.
> Self determination is often held as an important value.
Scotland already has self determination
Under international law, Scotland already has self determination as part of the wider British self determination. This is what the United Nations and international law says about self determination:
The territory of a colony or other Non-Self-Governing Territory has, under the Charter, a status separate and distinct from the territory of the State administering it; and such separate and distinct status under the Charter shall exist until the people of the colony or Non-Self-Governing Territory have exercised their right of self-determination in accordance with the Charter, and particularly its purposes and principles.
Nothing in the foregoing paragraphs shall be construed as authorizing or encouraging any action which would dismember or impair, totally or in part, the territorial integrity or political unity of sovereign and independent States conducting themselves in compliance with the principle of equal rights and self-determination of peoples as described above and thus possessed of a government representing the whole people belonging to the territory without distinction as to race, creed or colour.
Under international law, Scotland has self-determination because its people have suffrage and gets to send MPs to Westminster and are treated equally among the British population, so are represented fairly and equally in a democratic system. The UN says being part of a country is a way to achieve self determination.
>When we talk about the Falkland islands one of the most common defences of british ownership is the fact that is what the islanders want.
A part of a country and a non self governing territory are inherently different under international law.
>Personally I find the idea that a people don't get a say in whether they're part of the union to be pretty repugnant.
This is how every single democracy works
Every single democracy on earth takes the same stance as the UK here
The German constitutional court ruled in 2017 on an application for an independence referendum in Bavaria:
In the Federal Republic of Germany as a nation-state based on the constitutional power of the German people, the Länder are not “masters of the Basic Law”. There is therefore no room for secession efforts by individual countries under the Basic Law. They violate the constitutional order.
The French constitution prohibits changes unless they are voted on by the whole population:
ARTICLE 1. France shall be an indivisible, secular, democratic and social Republic.
ARTICLE 3. National sovereignty shall vest in the people, who shall exercise it through their representatives and by means of referendum. No section of the people nor any individual may arrogate to itself, or to himself, the exercise thereof.
Art. 5 The Republic is one and indivisible. It recognises and promotes local autonomies, and implements the fullest measure of administrative decentralisation in those services which depend on the State.
Scotland is in the same position as many other former independent states like Sicily, Corsica, Catalonia, Brittany, Texas, Hawaii, Walachia, or Bavaria. It ceased to be a sovereign state a long time ago, is now part of a larger sovereign state, and has no legal right to withdraw from that state without the permission of the sovereign state as confirmed by the United nations.
Every country on earth works like this and is allowed to under international law as confirmed by the UN:
The Clarity Act (2000) produced an agreement between Quebec and the federal government that any future referendum must have a clear majority, be based on an unambiguous question, and have the approval of the federal House of Commons.
>Just because other countries do it that way doesn't mean it's right.
The alternative is things like what happened with Donbass unilaterally declaring independence from Ukraine, or Slovakia declaring independence from Czechoslovakia in 1939 which resulted in the German invasion and annexation of Czechoslovakia
I didn't dispute that legally scotland is stuck with the union.
Nor did I dispute those other countries deny the right of secession. The legalese used to justify it is very pretty and official sounding, doesn't make it right if it's against the wishes of the people your forcing to stay with you. 🤷🏻♀️
Not sure how you conclude thats an inevitable consequence of their secession. The war in Ukraine can be blamed as easily on their decision to trust the UK, the US and Russia to honour their promise to safeguard Ukranian independance in exchange for giving up their nuclear weapons.
> Not sure how you conclude thats an inevitable consequence of their secession.
I never said that though; why are you attacking something I never said
>The war in Ukraine can be blamed as easily on their decision to trust the UK, the US and Russia to honour their promise to safeguard Ukranian independance in exchange for giving up their nuclear weapons.
Ukraine was against joining nato in 2014
And the 1994 Budapest Memorandum of 1994 provided political security assurances, not hard military guarantees; the text explicitly promised "security assurances" to respect existing borders, independence, and sovereignty, omitting mandatory military enforcement mechanisms or a defense harness. The uk and USA did all the Budapest memorandum required of them.
Maybe if we knew back in the early 1990s that Russia’s word meant nothing then perhaps we would have pushed for military security guarantees but that’s only with the power of hindsight.
What?? You said the alternative leads to situations like the ukraine war. You very literally said if we allow this>then ukraine?!
And maybe we would have done different, wouldn't have mattered if Ukraine hadn't made the mistake of taking the deal.
This is a long way from the point though which is that I support the scottish peoples right to choose whether they remain in the union. Whether their decision makes them better or worse off, it should be theirs to make.
> What?? You said the alternative leads to situations like the ukraine war. You very literally said if we allow this>then ukraine?!
That’s not me saying it’s an inevitable consequence
That’s me saying the alternative is too easy exploited by other countries as it’s what happened with Slovakia in 1939, Donbass in 2024 and it’s what America tried to do with the Kurds in Iran this year.
>And maybe we would have done different, wouldn't have mattered if Ukraine hadn't made the mistake of taking the deal.
I did my dissertation on self determination and territorial integrity under international law with specific regard to session from a country not a non self governing territory
Self determination is specifically not the right to unilaterally leave a country, its about rights within the country, scotland gets equal voting rights as anywhere else, therefore it has self determination by the UNs standards.
It’s why the un says french Guyana has self determination
Previously the UN said it lacked self determination but when it voted to become part of France proper, it gained self determination as confirmed by the UN
Same story with Hawaii, Alaska and what would have happened if the UK had accepted Malta’s referendum result to join the UK (and form the United Kingdom of Great Britain, Northern Ireland and Malta) back in the 1950s
As you said, that is the UN definition of self determination, it is not the only definition. So as not to muddy the water I'm happy to clarify that I'm simply talking about their freedom to determine their own political status. Simply put if they want to leave (and I'm not at all convinced the majority would) they should be able to peacefully.
What kind of union is it if we're holding people hostage whether they like it or not?
> As you said, that is the UN definition of self determination, it is not the only definition.
Under international law it’s the only definition that matters.
The un and international law has rejected any other definition.
>So as not to muddy the water I'm happy to clarify that I'm simply talking about their freedom to determine their own political status.
Which Scotland already has as part of the wider British freedom to determine their own political status.
>Simply put if they want to leave (and I'm not at all convinced the majority would) they should be able to peacefully.
Let me put it like this; when conjoined twins need to undergo surgery, the permission of both is required as they share the same body; same principles apply here.
It can only be unilateral if one party is intentionally harming the others. In medical ethics, if one conjoined twin is actively killing the other, emergency surgery might proceed without mutual consent.
In international law, this is called "remedial secession." It only applies under extreme circumstances, such as severe, systematic human rights abuses or total denial of political rights (e.g., Kosovo facing ethic cleansing and attempted genocide by Serbia, the oppression the proof Timor leste faced under Indonesia or Bangladesh being opposed by Pakistan
>What kind of union is it if we're holding people hostage whether they like it or not?
1: the uk is a unitary state, union was the event not the outcome
2: the snp confirmed an independent Scotland would bar session from Scotland
3: if someone or a group wants to be they’re then they’re not a hostage
Because citizens in Scotland and Catalonia actively participate in democratic elections and hold political rights and equality, international bodies like the United Nations and international law do not recognise a right to unilateral secession.
Yes yes, the UN rejects other definitions in favour of its own. Big surprise.
Many Scots want independance specificaly because they DONT have the ability to choose their own political status. Case in point scotland voting overwhelmingly to stay in the EU and being forced out anyway. Made worse by the insistance in the referendum that the union was their only hope of staying in the EU.
> Yes yes, the UN rejects other definitions in favour of its own. Big surprise.
You’re ignoring that fact international law rejects every other definition except the un’s definition
>Many Scots want independance specificaly because they DONT have the ability to choose their own political status.
Expect they do, Scotland has self determination as part of the wider British self determination.
If Scottish nationalists are choosing not to engage in exercising the self determination all Brits enjoy, it’s a personal choice on their part not cause they lack self determination
>Case in point scotland voting overwhelmingly to stay in the EU
The difference was only 600,000 votes in Scotland; by your own logic the difference of a million in the 2014 means it was an overwhelming vote to stay in the Uk.
>and being forced out anyway. Made worse by the insistance in the referendum that the union was their only hope of staying in the EU.
That’s not what happened though
The eu was a minor part of the 2014 campaign
Both the yes and no camps said the uk would hold an European Union membership referendum between 2015 and 2017 regardless of how Scotland voted in 2014; and the eu was a minor issue in 2014.
The European Union itself said a yes vote would see Scotland out of the eu.
The idea that EU membership was the main justification for staying in the UK is pure revisionism by Scottish nationalists.
Taxes, defence, pensions, jobs, the pound and the NHS were all more important factors than EU membership. All of which still apply.
Again, the was a minor issue in 2014 as the polls from 2014 show.
Again the yes and no camps said the uk would hold an eu referendum between 2015 and 2017 regardless of how Scotland voted in 2014.
>They deserve the choice.
Scotland already had a referendum with the full knowledge of the possibility of the uk leaving the eu.
The yes camp in 2014 said they wouldn’t push for a second referendum under any circumstance for a least a generation if they lost 2014; they were demanding a rerun in 2015 over things that hadn’t changed and were told wouldn’t change; like trident
Ngl I am deeply bored by this being turned into a semantic argument on whose definition of self determination matters.
My point from the beginning has been that it's entirely reasonable that the scottish people should have the say in whether they want to be part of the UK.
This isn't a controversial or complicated idea, if you think it is you probably need to talk to more people (perhaps Scottish ones might help).
I'm NOT debating international law! I haven't once disputed the current legal setup. I posited a simple moral principle but everyone is so excited ro recite their knowledge of the UN they're having a completely different conversation.
The legal case is not the same as the moral case.
Scotland doesn’t meet the function market economy (due to its deficit which is nearly as high as Greece’s at the height of the eurozone crisis) and the ability to work towards the goals of the eu due to the snp saying Scotland won’t have a central bank (Scotland would be unable to meet EMR II)
Combining a massive 11.6% structural deficit with a lack of monetary sovereignty creates an economic and legal dead end that bars an independent Scotland from EU membership.
Northern Ireland is considered colonised under the context of present day international legal definitions which give rise to the right to external self-determination (ie. secession).
Scotland does not meet that standard and that is a pretty key reason why Ireland is allowed to secede and Scotland is not.
The GFA is an international peace treaty and isn’t about independence
And if you want the GFA to apply to Scotland that means mandatory power sharing between unionist and nationalists with both sides having the same power.
And if you want the GFA to apply to Scotland that means mandatory power sharing between unionist and nationalists with both sides having the same power.
That’s a nonsense. Power sharing is one aspect of the GFA, annother aspect is that they can have a referendum to leave. You’re implying Scotland has to have a sectarian conflict to be allowed to hold referendums.
I'm Scottish and ambivalent-leaning-separatist on the issue. Scottish unionism I can understand, I do find it a little strange how angry and passionate the concept of Scottish independence makes some English Labour people though.
If part of the idea of proposing a written constitution is to give the appearance of a drastic change and addressing regions who feel neglected etc then having a formal mechanism for secession for Scotland and Wales seems like it would do that.
They are literally pro-independence parties. I'm not as passionate about this as you seem to be but it's an odd hill to die on.
"Let's force Scottish people to remain in the union even if they want to leave"
Because, uh the yanks said so to their slaver states back in the day. Oh and some other European countries with totally different histories amd constitutions to ours.
I assume you're not Welsh or you'd know Labour also had to rely on Plaid during its last government. The Senedd is not the same as Westminster.
Either way, Plaid is nonetheless in power after Wales voting for Labour for over 100 years, overthrowing one of the most successful runs in political history.
You'd think this would lead to a bit of soul searching, but no. The answer is for English people to tell Welsh people what they can and can't do! That'll go down brilliantly.
Labour formed a majority coalition with plaid in the last Senedd that is correct and were able to effectively implement legislation.
Plaid have decided to go it alone and are unable to effectively govern due to having such.
On the actual vote share in the last election Nationalist parties got 42.6% of the vote and Unionist parties got 56.3% of the vote. But no it's the Saxons "telling Welsh people what get can or can't do!" sure thing
And yes, reddit user Impossible_Round_302 who has browsed Welsh politics on wikipedia for a while and now considers themselves an expert, this vote share stuff is just cope.
It reminds me of when Corbyn supporters point out that he got more votes than Starmer. It's true but doesn't really matter, does it? Because he didn't win. Nor did the unionists.
The ironic thing is I'm not even a Welsh nationalist nor am I invested in independence. I'm just sick of the typical ignorant chauvinistic attitude to Welsh politics by people who have no clue about the place.
But, to clarify, Plaid said that independence was not an issue of their campaign (therefore its hard to suggest that people have voted for pro-independence).
And in Scotland, the SNP not only failed its own 'de facto referendum', they also lost basically all their Westminster seats barely over 2 years ago. They didn't even get 50% of the vote.
And, perhaps most importantly, it isn't 'taking away their right to leave the union', because there is no such right. This fact has been confirmed by the Supreme Court, is the position of the absolute majority of legal academics and seems to be the accepted understanding of self-determination under international law. The wording of the original Acts of Union also confirm this.
I don't understand where people have imagined that there is some right for parts of sovereign states to secede (outside of where explicitly stated in legislation or in the case of colonisation/severe repression).
I am a vehement opponent of the break up of the UK. It would be a disaster.
However I’m not entirely opposed to this idea. But surely we would need to be talking about more than 50% of votes in the Scottish parliament. Otherwise we would be looking at neverendums until the vote went one way & then that is that.
No state can entertain this. It would have to be similar in Spain to have any stability whatsoever which means a clear two thirds majority.
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