A proposal which could allow England and Wales to withdraw from the European Union and allow Scotland to retain its membership has been hailed by Nicola Sturgeon.
Denmark-based academic Ulrik Pram Gad has suggested the UK could seek inspiration from Greenland, which withdrew from the EEC in 1985 while the rest of the Kingdom of Denmark remained.
Read more: Citizens or bargaining chips? Scotland's Europeans on their Brexit fears
England and Wales could do a "reverse Greenland" by seeking a territorial exemption from the continuing UK member state, allowing Scotland, Northern Ireland and Gibraltar to retain their EU membership, Mr Gad said in an article for the London School of Economics.
Ms Sturgeon, Scotland's First Minister, has pledged to explore all options to keep Scotland in the EU after its citizens voted overwhelmingly to Remain.
Writing on Twitter, she said: "Interesting piece by a Denmark based academic - Could a 'reverse Greenland' arrangement keep Scotland in the EU?"
The "reverse Greenland" option was suggested by other academics in the days following the Brexit vote.
Theresa May described some of the suggestions to keep Scotland in the EU as "fanciful" in her first visit to Scotland after being appointed Prime Minister, and senior Cabinet ministers have said the whole of the UK will leave the EU.
Mr Gad said: "The Brexit referendum results in England and Wales contrasted sharply with those in Scotland, Northern Ireland, and Gibraltar.
"Taking these differences into account - and combining them with prospects of Scottish independence, renewed troubles in Northern Ireland, and potentially severe isolation in Gibraltar - the UK could refrain from activating Article 50.
Read more: Iain Macwhirter: On the economy, Sturgeon is fighting a tank war with a pea-shooter
"Instead, negotiations could aim at a territorial exemption of England and Wales from UK membership.
"The UK would still be a member state - voting rights reasonably reduced to match the population of Scotland and Northern Ireland.
"The question of who would represent this member state, on what mandate, and following what procedures of coordination would have to be solved within the UK.
"Possibly, the role of Scottish ministers and bureaucrats from Northern Ireland would have to be central.
"The 'reverse Greenland' arrangement sketched above might solve the issue for Scotland, Northern Ireland and Gibraltar, but it would, of course, leave another problem on the table: namely the relationship England and Wales would have with the EU and the single market.
"Inspiration for this relationship would have to be found elsewhere as there is little guidance that can be offered by the Greenland case.
"But while the EU might appear to be a rigid legal community, the political processes that generate EU agreements are based chiefly on pragmatism.
"There is therefore scope to create unique arrangements and the formalities of the process will hardly act as an obstacle in achieving this.
Read more: Nicola Sturgeon to unveil post-Brexit 'economic stimulus' package
"Greenland's experience illustrates that it can be necessary to play games with a state's formal sovereignty in order to uphold it. Copenhagen seems to have learned that lesson - now the question is whether London will too."
Why are you making commenting on The Herald only available to subscribers?
It should have been a safe space for informed debate, somewhere for readers to discuss issues around the biggest stories of the day, but all too often the below the line comments on most websites have become bogged down by off-topic discussions and abuse.
heraldscotland.com is tackling this problem by allowing only subscribers to comment.
We are doing this to improve the experience for our loyal readers and we believe it will reduce the ability of trolls and troublemakers, who occasionally find their way onto our site, to abuse our journalists and readers. We also hope it will help the comments section fulfil its promise as a part of Scotland's conversation with itself.
We are lucky at The Herald. We are read by an informed, educated readership who can add their knowledge and insights to our stories.
That is invaluable.
We are making the subscriber-only change to support our valued readers, who tell us they don't want the site cluttered up with irrelevant comments, untruths and abuse.
In the past, the journalist’s job was to collect and distribute information to the audience. Technology means that readers can shape a discussion. We look forward to hearing from you on heraldscotland.com
Comments & Moderation
Readers’ comments: You are personally liable for the content of any comments you upload to this website, so please act responsibly. We do not pre-moderate or monitor readers’ comments appearing on our websites, but we do post-moderate in response to complaints we receive or otherwise when a potential problem comes to our attention. You can make a complaint by using the ‘report this post’ link . We may then apply our discretion under the user terms to amend or delete comments.
Post moderation is undertaken full-time 9am-6pm on weekdays, and on a part-time basis outwith those hours.
Read the rules hereLast Updated:
Report this comment Cancel