LORD Justice Leveson's report on press ethics has presented Alex Salmond's Government with a headache it could have done without.

It raises difficult questions about creating a system that strikes a balance between ensuring press freedom and protecting the public from unacceptable journalistic practices. Not only that, it will require delicate legislation to be passed in the face of a fierce political battle.

Few as yet will have read and digested all 2000 pages of the report. There are still many more questions than answers, and will be for some time.

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What we do know is that Mr Salmond favours the system used in Ireland, where a press council and press ombudsman were created four years ago to police a code of practice and handle complaints against newspapers. The Press Council of Ireland consists of seven independent members and six industry representatives. They are chosen by an appointments committee, which itself is appointed by the commission. The ombudsman handles complaints and appeals against his decisions are heard by the full council.

The system has proved popular since its inception. It is seen as genuinely independent by the newspaper industry – which created it– and enjoys public confidence.

It might be described as "Leveson-lite" – lite in that the Press Council of Ireland does not have a government quango breathing down its neck.

Under Lord Leveson's recommendations, the UK's broadcasting regulator Ofcom, which is funded by the Government and whose board is appointed by ministers, would monitor the new body to guarantee is "effectiveness".

In Ireland, the Press Council had to be signed off by a minister when it was recognised in law but there the Government's involvement ended. Many UK newspaper publishers have voiced support for Dublin's approach.

Mr Salmond may well have hoped to lift the Irish model straight off the peg and replicate it in Scotland without any great fuss but that's not likely to happen.

As long as David Cameron refuses to "cross the Rubicon" of legislating in any way to regulate the Press, the First Minister will face questions about why he wants a potentially tougher regime for Scotland where newspapers have not found themselves the dock. He will also come under pressure to explain why Scotland needs a different system from the rest of the UK.

Newspapers which publish on both sides of the Border are unlikely to welcome the prospect of paying to maintain two regulatory bodies (I'm sure managing editors will have noticed already that the Press Council of Ireland costs 700,000 euros per year to run).

On a practical level, some content on Scottish newspaper websites would continue to be regulated from London as broadcasting and the internet are matters for Westminster. Successive Scottish Governments have shown no appetite for exercising their powers over press regulations until now, and Scottish Labour leader Johann Lamont has already questioned the need for two regulatory systems.

The issue is far from clear cut, though. The impact of new-style regulation on the defamation laws and the key role of Ofcom – which is accountable to Westminster, not Holyrood – in Lord Justice Leveson's proposals have been cited as reasons for a distinctively Scottish approach.

These issues also highlight a third difficulty. The complexities of devolution mean the legislation required is far from straightforward and the Scottish Government's track record on creating new bodies to oversee independent entities isn't great, as the ongoing turf war between the heads of the Scottish Police Authority and the new national force, Police Scotland.

It took five years to get the Irish system up and running. Who would bet against a similarly lengthy process in Scotland?