Prince George’s Birth Stirs Up Anti-Monarchy Vitriol in Scottish Separatist Campaign

Some Scots nationalists are breaking ranks, vowing that no King George will ever rule Scotland again.

When the Duchess of Cambridge, the former Kate Middleton, began sporting a baby bump last year, one thing was certain: in approximately nine months’ time, the royal family would receive another bump—the bump in approval ratings that always accompanies a royal birth, wedding, or even death.  What no one predicted was the bumps the birth would create in the road to Scotland’s 2014 independence referendum.  Nothing unites Britons as much as royalty, and in the exuberance over the birth of Prince George last month Britons, at least in England, haven’t felt so united in their love of the institution of the monarchy since George’s paternal grandmother never came out of the other end of that French tunnel back in 1997.  So the royal birth was already a minefield for Scottish nationalists, whose relations with the throne have been at best ambivalent since the kingdoms of England and Scotland merged to become the Kingdom of Great Britain in 1707.  So far, they have tried to appeal to Scots that they can love, and keep, the royal family while still seeking independence.  But the head of the pro-independence “Yes Scotland” referendum campaign threw that strategy under the bus this week by launching a war of words on the British Crown.

Dennis Canavan, a former independent Labour Party M.S.P. (member of Scottish Parliament), heads Yes Scotland, charged by the ruling Scottish National Party (S.N.P.) with convincing Scots to vote for independence in a referendum planned for next year.  Canavan’s ostensible boss, Alex Salmond, who is S.N.P. leader and Scotland’s First Minister (i.e. premier), had been reassuring voters that much that they cherish will remain the same: an independent Scotland would use the British pound (at least until it makes sense to adopt the euro on its own), stay in the European Union (E.U.) (though precedent is unclear on this) and the North Atlantic Treaty Organization (NATO), and keep Queen Elizabeth II as its head of state.

Dennis Canavan says “yes!” to independence but not to the royal family.

But Canavan told a newspaper interviewer on July 29th that the monarchy was “an affront to democracy and a complete anachronism in modern 21st-century democracy,” adding, “As to the possibility of another King George, it is important to remember that true democracy is based on the sovereignty of the people rather than the sovereignty of any monarch.”  Canavan favors a second referendum, if the first is successful, to ask if Scots want to keep the monarchy.  This put a lot of daylight between him and Salmond.  But it also threatened to sow wariness among ordinary Scots who are motivated more by the desire for more home rule and prosperity than by any Irish-republican-type anti-English animosity and who would much rather become a fully independent Commonwealth realm, like Canada or New Zealand, than an ordinary, bland republic cast apart from the Commonwealth.

Her Majesty may live to see her dominions dwindle yet again.

In addition to the United Kingdom, whoever sits on the English throne is also head of state of the 15 other Commonwealth realms, which are mainly Canada, Australia, New Zealand, and a host of medium to small Caribbean and South Pacific nations, the most prominent of which are Papua New Guinea and Jamaica.  The Queen is on all their stamps and money, and their sovereignty, in theory, rests with her legitimacy and that of the throne on which she sits.  Though she rarely visits these dominions, their Parliaments need to be ceremonially opened and closed each year by a viceroy (called a governor-general).  (Even Australian states and Canadian provinces and territories use, as their heads of state, viceregal governors and lieutenant governors, respectively.)  The Queen also has certain constitutional powers, such as the ability to dissolve Dominion parliaments or tinker with other workings of government.  By an unwritten agreement among these actually very de facto independent democracies, she never will.  Her role is decorative only.  But it is a decoration that men and women of Canavan’s political stripe find ugly.

The British Commonwealth today

In the Scottish political landscape, the local, Scottish branches of the U.K.’s three main parties—the Conservatives, the Liberal Democrats, and Labour—are all pro-unionist (not counting a rogue Labour for Independence faction).  Scotland’s ruling S.N.P. has had to wrangle with its smaller uneasy pro-independence allies, the Scottish Socialist Party (S.S.P.) and Scottish Green Party, which are republican—just as he has had to wrangle with them over questions like NATO and the euro (the pacifist, decentralist Greens dislike both).  Now it seems he can’t even keep his inner circle on message.

Alex Salmond

And he needs to: support for Scottish independence hovers around 35-36%, a four-point drop from Ocober 2012.  (Ironically, Scottish independence is a more popular idea in England than in Scotland itself.)  Unless he can push those numbers up, it will make a mockery of his avowed plan to follow the strategy used in Quebec in the mid-1990s, when a separatist campaign raised poll numbers from less than a third to a near-victory in 1995, with those wanting to stay in Canada prevailing with only 50.58%.  Right now, Britons are baby-mad, and the baby they’re mad over is, inconveniently for Salmond, English.  (Well, a mix of German and Greek, actually, but never mind all that.)

In Wales, separatists face a similar problem.  The leading Welsh independentist party, Plaid Cymru, formed a coalition government there in 2007 but was turfed out by Labour in the 2011 elections.  Its attempts at a comeback have been hobbled by the accession to the party leadership the following year by Leanne Wood, an ardent pacifist, socialist, and republican who was once ejected from the Welsh Assembly chamber when she referred to Queen Elizabeth II as “Mrs. Windsor.”  And her equally republican party president, Jillian Evans, has raised eyebrows by appearing at events alongside violent radicals like Byddin Rhyddid Cymru, the Free Wales Army.

Jillian Evans speaking last September while the Free Wales Army wave their flags nearby.

Meanwhile, back north of Hadrian’s Wall, it should be noted that while the Windsors’ doings can affect politicking in Edinburgh, Scottish politics can influence royal matters as well.  In the weeks and months leading up to Prince George’s birth, and in the days of waiting afterward when his name had not yet been announced, odds-makers in London’s betting shops were—correctly, as it turned out—giving best odds to George, the name of the current monarch’s father (George VI) and grandfather (George V).  The next most likely names, according to the bookies, were James and Arthur.  Though it is one of the current Prince of Wales’s middle names, Arthur is a tricky one, since deciding whether a new monarch would be Arthur I or Arthur II would mean taking a position on whether the first King Arthur was mythical.  But James was even dicier.  Recall that James II of England, who was also James VII of Scotland, was deposed by his daughter Mary and her husband William of Orange in the anti-Catholic “Glorious Revolution” of 1688.  This ushered in a long period of “Jacobite” rebellion in the Scottish Highlands to try to get James and his House of Stuart restored to the throne—if not of England, at least of Scotland.  This unrest paved the way for the merger of the two kingdoms as the (United) Kingdom of Great Britain under James II’s daughter Queen Anne, who was raised Protestant, unlike her father, and whom Scots remember as the last reigning Stuart.  Childless, Anne was succeeded upon her death by a newly installed House of Hanover in 1714 with the accession, through parliamentary fiat and palace intrigue, of—wait for it—George I.  This is surely what Dennis Canavan had in mind when he swore bitterly last week that no “King George” would ever again rule Scotland.  And the Windsors are smart enough, as a referendum on Scottish independence looms, to dwell more on the glories of the first George than the bitter fall of the last James.

Who ever said the past was past?

James II ... or was it James VII?  Well, James the Last, that’s for sure.

[Also, for those who are wondering, yes, this blog is tied in with a forthcoming book, a sort of encyclopedic atlas to be published by Auslander and Fox under the title Let’s Split! A Complete Guide to Separatist Movements, Independence Struggles, Breakaway Republics, Rebel Provinces, Pseudostates, Puppet States, Tribal Fiefdoms, Micronations, and Do-It-Yourself Countries, from Chiapas to Chechnya and Tibet to Texas.  Look for it in spring 2013.  I will be keeping readers posted of further publication news.]

[This article modified on Aug. 5, 2013, to correct misstatements regarding Canadian viceroys and the role of Queen Anne.  Thanks to Brian Cowan for alerting me to these points.  Any remaining errors are my own.]

Orkney—the Next Dubai? Further Reflections on Scottish Independence

Recently in this blog I discussed the political machinations surrounding the fate of a group of godforsaken, windswept, rocky islands in the South Atlantic, the Falkland Islands.  Today I’ll turn my attention to a group of godforsaken, windswept, rocky islands in the North Atlantic, the northern, sub-Arctic fringe of the ex-kingdom of Scotland, which has of late been trying to find its way free of the United Kingdom.

The U.K. has agreed in principle that, as with the Falklands or Gibraltar, if the majority of Scots vote for independence, then the process of secession will be set in motion.  Recently the U.K.’s prime minister, David Cameron, visited Edinburgh to meet with Alex Salmond, Scotland’s First Minister and the head of the nation’s separatist Scottish National Party, to plead for unity.  The vote is pencilled in for some time in 2014, but Cameron would like it held sooner, so as to give less time for Salmond to try to rally Scottish support for independence above the current one third or so.  Ironically, there is more support in England for Scottish independence than there is in Scotland, but the English won’t be voting on it.  (There is also a very marginal English independence movement.)  Salmond would also like the voting age for the poll to be lowered to sixteen, since separatism is more popular among the young.

Alex Salmond

Details to be worked out before the vote include who would get which part of the British military, whether an independent Scotland would stay in the North Atlantic Treaty Organization or the European Union or both or neither (a complicated legal issue which I discussed in detail last month), and who would get all that oil in the North Sea.  Much of the U.K.’s natural-gas reserves lie off of England’s coast, but if conventions on marine boundaries are applied to a partitioned Great Britain, Scotland would get most of the oil, which is farther north in the North Sea.  This would make it, economically speaking, a very viable state indeed.

The U.K.’s marine boundaries, with an independent Scotland’s boundaries shown in dark blue

Understandably, this aspect of the independence issue has the Conservative Party and others who represent British business interests in a tizzy.  And it has prompted the right-wing Spectator magazine to muse, in a recent article, how far the principles of right to self-government enunciated by the Scottish National Party would apply if parts of Scotland itself were to vote for independence.  The article’s author, Laurance Reed, a Scottish former Conservative member of (British) Parliament (who once proposed deporting all Irish citizens out of the U.K.), asks, rhetorically, why the Orkney Islands or Shetland Islands to the north of the Scottish mainland should not seek independence from Scotland itself and take with them vast oil reserves—or even Reed’s native Hebrides islands, which are closer, off Scotland’s western coast.  Reed asks, apocalyptically, “If oil and its riches can transform the fortunes of the Scottish National Party and destabilise the United Kingdom just a few decades after its discovery, what makes us think that the people of the Hebrides will not be changed by the black stuff?  Wait until the oil price goes through the roof as the result of demand in Asia, making the exploitation of the Hatton/Rockall Basin profitable.  The Icelanders and the Faroese may soon scramble for the riches.”

The marine boundaries of a hypothetical independent Scotland,

with the marine boundaries of a far more hypothetical

independent Shetland, Orkney, and Hebrides shown in darkest blue

In fact, there is more nascent separatism in Scotland than Reed may realize.  Some of these questions have been asked in recent years from an unlikely place, the so-called Crown Dependency of Forvik, one of many more or less frivolous micronation projects which the British Crown quietly tolerates within its boundaries.  (See my recent blog post on another British micronation, Sealand.)  Unlike others, Forvik’s cause has intersected with serious regionalist politics.  The nation was founded by Stuart “Captain Calamity” Hill, an English eccentric whose attempt to circumnavigate the British Isles in a private craft ended in 2001 when he was shipwrecked on Forewick Holm, a 2.5-acre islet in the Shetland Islands.  In 2008, after purchasing the island, he renamed it with the Norn name Forvik (Norn is the Scandinavian language spoken in the Orkneys and Shetlands until about a hundred years ago) and unilaterally declared it a Crown Dependency—like the Isle of Man and the Channel Islands—and thus not fully a part of the U.K. and not at all a part of the E.U.

Although Hill swears allegiance to Queen Elizabeth II, his arguments include his claim that the Shetlands’ and Orkneys’ transference in 1469, when King Christian I of Denmark essentially “pawned” the archipelago to King James III of Scotland to raise money for his daughter’s dowry, is illegitimate (a legal tangle that Reed also raises).  Christian never paid up, which is why the islands remain Scottish, but what if the Danish Crown suddenly paid its bill?  Hill told one journalist, “It’s all jolly good fun.  Every pensioner should do something like this.”  Still, it is not all a lark: some of Hill’s invocations of ancient Norse law were lauded by some in the Shetland Islands Council—the archipelago’s semi-autonomous government—during a recent legal challenge to the Crown for seabed resource rights, invoking ancient Norse law.  Orcadians (as people of the Orkney Islands are known) and Shetlanders have always been fiercely independent, and have always had a streak of Viking in their culture that is not found in Edinburgh or Glasgow or even the Isle of Skye.

“Captain Calamity” Hill, a one-man secessionist movement that has raised deep legal issues

Jurists and statesman have already begun studying the legalities of the Acts of Union of 1706-07 which created the United Kingdom out of the kingdoms of England and Scotland.  Organizations representing culturally distinct groups within Scotland such as the Shetland and Orkney councils may see independence as the chance to claim their own, probably more limited autonomy (which tends to be the pattern, as we continue to see in the Soviet Successor States).  So far, a political party called the Orkney and Shetland Movement is demanding devolution and its own parliament, but not outright separation, and so far the S.N.P. is tolerating the O.S.M. as uneasy allies.  But, depending on how far these questions are pushed, the very basis of Scotland’s original claims over its own territory may be called into question.  Indeed, if Orcadians and Shetlandes tried to push for their own separate states—which right now they have no plan to do—then it would probably make the S.N.P. pull back.  A Scotland without much of its North Sea oil would be far less viable economically.  But if those archipelagoes became independent, then their tiny population would have a mathematical relationship to their nations’ natural-resource wealth that would make them as rich as the emirs of Dubai and Kuwait.

King Christian I of Denmark, who pawned the Orkneys and Shetlands

to Scotland to pay for his daughter’s marriage.

See, doesn’t it look like he regrets it already?

Scotland, it should be noted, also administers, within the United Kingdom, the tiny rocky islet called Rockall (also mentioned sarcastically in Reed’s article), about equidistant between Ireland and Iceland.  Both Dublin and Reykjavík claim Rockall—and, by extension, the vast resource-rich seas around it—while the Danish government insists it is part of their self-governing Faroe Islands territory (which itself has its own separatist movement, the inspiration for the Icelandic singer Björk’s 2008 hit “Declare Independence”).

In 1972, the British parliament, which claims Rockall by right of possession, asserted the rock was not just part of Scotland but was specifically part of the Scottish county of Inverness-shire (which also, by the way, includes the Inner Hebrides).  (Rockall, though uninhabited, did have its own brush with independence, in 1997, when Greenpeace occupied the island as a publicity stunt and declared it an independent “global state” called Waveland.  It lasted only a matter of days, though the Crown made a point not to interfere.)

Waveland

What all of this reminds us is that the legal basis of marine and land boundaries in the North Sea and western Scandinavian region are far from settled.  Scottish independence has the capacity to reopen cans of worms like that of Rockall.  Suddenly, an independent Scotland would find itself responsible for a dormant territorial dispute with Ireland and Denmark, one which further resource exploration could reawaken.  This is to say nothing of what will happen as the Arctic Ocean continues to melt.  Already countries around the Arctic rim are positioning themselves for a race for the polar seas’ wealth of natural gas and who knows what else.  An independent Scotland would be well positioned to take part in that mad scramble as well. 

Map showing different nations’ maritimes claims in the Arctic Ocean

(see a larger map showing this complex issue here)

Could Scotland go the way of Ukraine with its Crimean and Trans-Carpathian Ruthenian separatists? or Georgia with its Abkhazian and Ossetian ones?—breaking free of an empire only to find itself fracturing within (a phenomenon of nested identities I like to call matrioshka nationalism)?  Not likely, since an independent, oil-rich Scotland would be a mighty comfortable, prosperous, progressive place to live.  But we can expect the Shetlands and Orkneys and maybe the Outer Hebrides to demand status as special autonomous regions, and, now that the legal experts have questioned our assumptions about marine territories and about the legal basis of sovereignty in the British Isles, the legal field may be wide open and the economic stakes for that might be fairly high.

Succession or Accession: Could Scotland Leave Britain but Stay in Europe?

[Please see these related articles from this blog: “Orkney—the Next Dubai? Further Reflections on Scottish Independence,” “The World’s 21 Sexiest Separatists” (featuring Sean Connery), and “What Is a Colony? The United Nations’ Definition Needs an Overhaul,” “Happy Dependence Day, Hong Kong! 400,000 Protest Chinese Rule—but Secession Is Not on the Table,” “Celts, Cypriots, Aborigines Raise Stink at Olympics: Ethnonationalist Protest Update.”]

The United Kingdom of Great Britain and Northern Ireland now faces the inevitability of a referendum on Scotland’s independence.  Alex Salmond, who became Scotland’s First Minister when the Scottish National Party (SNP) took charge of the 14-years-young devolved Scottish parliament last year, announced the referendum plans this month and thus embarked upon a war of words with anti-independence parties in the U.K. (that is, all the rest of them).  This scrapping over legal and political details may well drag on until the vote itself, which Scottish nationalists would like to hold in late 2014, on the 700th anniversary of the Scottish victory over the English at the Battle of Bannockburn in 1314.

What the Union Jack would look like

without the St. Andrew’s Cross that represents Scotland

And speaking of battles, just this week, Philip Hammond, the Defense Secretary in David Cameron’s U.K. government, responded to Salmond’s assumption that an independent Scotland could be defended by the U.K.’s current Scottish regiments by saying that “The idea that you can sort of break off a little bit [of the British Army], like a square on a chocolate bar and that would be the bit that went north of the Border, is frankly laughable.”  And he warned that the U.K. might not want to foot the bill for the expulsion of nuclear submarines from its waters that an independent Scotland would demand—since Scotland would probably stay out of the North Atlantic Treaty Organization (NATO).  Clearly, defense is one of many areas where innumerable details would still need to be worked out if Scotland seceded.  The SNP is being reminded that their parent country will have a say in what the new state would end up with.

Anti-nuclear protesters at a NATO base in Scotland

And now the question of whether Scotland could stay in the European Union after independence has been called into question from an unexpected quarter: Spain.  The Spanish government has said this week that if Scotland applies for membership in the E.U., it will veto the move.  Under E.U. rules, any new members must be approved unanimously by all existing member states.  Spain has separatist movements of its own—in Catalonia, the Basque Country, and Galicia, specifically—that it would not like to encourage.  So the government in Madrid was alarmed to hear Artur Mas, Catalonia’s premier, point to Scotland’s referendum as a positive example of peaceful secession.  Madrid fears that a successful Scottish referendum would encourage Catalans and other nationalists to break up Spain.  Thus their threat to block Scotland’s E.U. status.

In fact, continuing E.U. membership is a crucial talking point when separatists in western Europe make their case, reassuring the public that secession would not be politically or economically disruptive, and may in fact change little.  I made such an argument in this blog discussing the prospects of a Belgian partition, and it was implicit in my more recent discussion of the movement for northern Italy secede as “Padania.”

The SNP responded to the Spanish announcement by calling Madrid’s interpretation of E.U. rules “preposterous,” adding, “Scotland has been an integral part of the E.U. for almost forty years.  An independent Scotland would be a succession state, not an accession state, and there is no provision for citizens of the E.U. to be expelled.”

Scotland’s First Minister, Alex Salmond

The SNP is probably right on the last point, but that doesn’t mean a mechanism couldn’t be found.  More important, from a legal perspective, is his point about succession and accession.

The European Common Market (later renamed the European Economic Community, the European Community, then the European Union) was founded in 1957 by six states: Belgium, France, the Federal Republic of Germany (west), Italy, Luxembourg, and the Netherlands.  The twenty-one subsequent member-states—including the U.K. and Ireland, which both joined in 1973—became members through accession—a fancy word for “joining.”  No member-state has yet joined by the mechanism of succession, which would mean, for example, that a member-state dissolved and was automatically replaced by two or more newly formed states.

So where should we look for possible precedents to the situation the E.U. would face if Scotland seceded?  Let’s look at three examples with respect to United Nations membership: the Union of Soviet Socialist Republics (U.S.S.R.), the United Arab Republic, Czechoslovakia, and Yugoslavia.

U.S.S.R.  When the U.N. was founded in 1945, the U.S.S.R. was a founding member.  Plus, Josef Stalin succeeded in getting two more member-state votes for himself by rather disingenuously sliding in the Ukrainian Soviet Socialist Republic and the Byelorussian Soviet Socialist Republic as members alongside the U.S.S.R., though they were clearly governed by the party dictatorship in Moscow.  As for other S.S.R.s, the U.N. never recognized the Soviet annexation of the Baltic states of Estonia, Latvia, and Lithuania at the close of the Second World War but did not want to antagonize Stalin by seating delegations from Baltic governments-in-exile in the General Assembly, so those three states were in actuality treated by the U.N. as part of the U.S.S.R.  In late 1991, after the collapse of Soviet Communism, Russia’s president, Boris Yeltsin, requested and got recognition of the Russian Federation as successor to the U.S.S.R.’s seat both in the General Assembly and on the Security Council.  The Ukrainian and Byelorussian S.S.R.s kept their seats as the renamed Ukraine and Belarus, respectively, but for the first time their legal status as sovereign states was not fictional.  Nevertheless, the other nine members of the so-called Commonwealth of Independent States—Moldova, the southern Caucasus republics, and the Central Asian “-stans,” as well as the Baltic States, who refused membership in the Commonwealth—had to apply separately to the U.N. as new members.  So, although all these are now considered “Soviet Successor States,” only Russia, Ukraine, and Belarus were members by succession; the rest acceded to the U.N.

Some Soviet successor states had to reapply for U.N. membership, but some didn’t

The United Arab Republic (U.A.R.) was a short-lived merger between Egypt and Syria in the early Cold War period.  Both were founding U.N. members, and they merged their seat in 1957 as the U.A.R.  When the union dissolved in 1961, Syria resumed its former membership seamlessly, and Egypt, which retained the name United Arab Republic itself for a few more years, was the successor state to the formerly unified U.A.R.

Czechoslovakia was a founding U.N. member-state but with the fall of Communism changed its name in 1990 to the Czech and Slovak Federative Republic, to reflect the loosening of central government control over its two constituent countries.  In late 1992, it dissolved in the so-called Velvet Divorce and was succeeded by the Czech Republic and the Slovak Republic.  Both were recognized by the U.N. as successor states, and neither had to apply for admission.

Neither the Czechs nor the Slovaks had to reapply to the U.N. when Czechoslovakia dissolved

The Socialist Federal Republic of Yugoslavia had also been a founding U.N. member-state, but after the fall of Communism its constituent republics began declaring independence one by one, beginning in the north.  The northern republics of Slovenia, Croatia, and Bosnia and Herzegovina applied for admission to the U.N. and were admitted together in May 1992 as three new states, although in the case of Croatia and especially Bosnia, their wars of secession were ongoing, with Serbian regions of those two states fighting vainly to be recognized by anyone other than the Yugoslavian central government and each other as independent states themselves.  Later, in 1993, Macedonia applied for admission and was admitted.  The two remaining republics, Serbia and Montenegro, calling themselves the Federal Republic of Yugoslavia, petitioned to be recognized as a successor state to the old Socialist Federal Republic of Yugoslavia, but the U.N. General Assembly erased Yugoslavia’s membership and told the government in Belgrade that it had to reapply.  They did, and the U.N. promptly refused, citing the barbaric behavior of Serbian forces in still-ongoing Yugoslav Wars of Succession.  Yugoslavia was not admitted until 2000, after Slobodan Milošević was removed from power.  In 2003, the state changed its name to the State Union of Serbia and Montenegro.  In 2006, Montenegro seceded peacefully and quickly was admitted as a new U.N. member-state, while Serbia succeeded the former State Union as the Republic of Serbia.  So here was an odd situation where Serbia, the core republic (analogous to Russia in the U.S.S.R.), seen by the other republics as a kind of colonizer, not only was denied the right of automatic succession but was nearly the last to join the U.N. again by accession.

Serbia, the country the others seceded from, ironically had

the least luck in getting treated as a Yugoslav successor state

(The Organization for Security and Cooperation in Europe and other similar organizations for the most part followed the U.N.’s lead in the sequence and mechanisms for seating these new delegations.)

So, back to Scotland: is the U.K. more like the U.S.S.R. and Yugoslavia or more like Czechoslovakia and the U.A.R.?  The pivotal questions seem to be whether Scotland is a dependent territory of the central government in London, in a way that England perhaps is not, or whether it is a co-partner with England (and perhaps with Wales and Northern Ireland) in a union, like Czechoslovakia.  (Serbia-and-Montenegro, if the wars had gone differently, would probably have been allowed to join through succession rather than accession.)  Surely, other constituent parts of the U.K. that were unambiguously dependent territories—such as the former colonies in Africa, Asia, and elsewhere—joined the U.N. by accession, not succession, but Scotland hardly has the dependent legal status of Zambia, despite what some Scottish nationalists would have us think.

Scotland’s former royal coat-of-arms

For one thing, one might argue, unlike the two constituent countries of Czechoslovakia, it would be possible for England, Wales, and Northern Ireland to retain their designation as the United Kingdom (though they probably would have to change something about its full name, the United Kingdom of Great Britain and Northern Ireland, since Scotland is a major chunk of the geographic island of Great Britain).  Or could it even do that?

The Kingdom of England and the Kingdom of Scotland were separate, sovereign states until 1706 and 1707 when the English and Scottish parliaments, respectively, passed the Acts of Union, dissolving the Scottish crown and creating the Kingdom of Great Britain, also called the United Kingdom of Great Britain.  Similar Acts of Union in 1800 incorporated the Kingdom of Ireland into what then became the United Kingdom of Great Britain and Ireland—which later, when most of the island of Ireland gained independence in 1922, inserted the word Northern before the word Ireland.  The whole idea, then, of a United Kingdom is predicated on the idea that England, Scotland, and (now just a bit of) Ireland were equal constituent parts of a kingdom.  (Wales today also has equal status with Scotland, England, and Northern Ireland, but historically it had been ruled directly from London for centuries by the time of English–Scottish union.)  A Scottish secession would mean legally undoing the Acts of Union of 1706 and 1707.  Whether this would automatically restore the House of Stuart to the throne is something legal scholars will need to tackle.  Likewise for the question of whether the incorporation of Ireland, and now Northern Ireland, in the Union would hold after Scotland’s departure—since Scotland, at least on paper, was an equal partner on the Great Britain side of the Acts of Union of 1801.

The Parliamentary Union of England and Scotland, 1707,

as painted by Walter Thomas Monnington

All of these are questions for jurists, legislators, and diplomats not just in London and Edinburgh but in Brussels and Strasbourg as well.  To claim that an independent Scotland has left the E.U. but that England has not might not withstand the legal conceit that the Crown which ceded some powers to Brussels in 1973 implicitly included the sovereignty of Scotland as well.  After all, Jersey, Guernsey, and the Isle of Man chose to stay out of the E.U. in 1973 and are still out of it, pursuing a special legal status which Scotland never insisted on and would have rejected if there had been an attempt to impose it.

How legal scholars and politicians end up defining the matter may well decide whether Salmond can galvanize enough of the two-thirds of Scots who oppose secession today to change their minds between now and 2014.  Independence will look a lot less attractive if it means that Scotland would no longer be in the E.U.

Or will it?  Despite the fact that Croatia has just voted to join, the E.U., with its currency and debt crisis, is increasingly looking like more trouble than it’s worth.  And, after all, Scotland’s neighbors across the water, Norway and Iceland, are, along with Switzerland, major western European states that never joined the E.U., though they enjoy many of its free-trade benefits under separate arrangements.  (The Swiss are not really joiners.  Not only is Switzerland, unlike Norway and Iceland, outside NATO, but it didn’t even join the U.N. until 2002.)  Switzerland’s mammoth financial sector has always made it feel as though it needed no help from a customs union.  The same goes for Iceland, in its case because of vast fishing territories that it is permitted in a singular exception to ordinary law on marine boundaries.  And Norway, of course, has all that North Sea oil.  But, wait, isn’t the U.K., when you look at a map, just as well positioned as Norway to enjoy the largesse of all that oil? ...

Oh, no, wait, I guess that’s mostly just Scotland.  You know, maybe they won’t need the European Union after all.


[For those who are wondering, yes, this blog is tied in with my new book, a sort of encyclopedic atlas just published by Litwin Books under the title Let’s Split! A Complete Guide to Separatist Movements and Aspirant Nations, from Abkhazia to Zanzibar.  The book, which contains 46 maps and 554 flags (or, more accurately, 554 flag images), is available for order now on Amazon.  Meanwhile, please “like” the book (even if you haven’t read it yet) on Facebook.]