SCOTS would be offered tailored passports as part of a radical proposal to allow them to live and work on mainland Europe after Brexit.

Holyrood officials are currently studying a plan drawn up by academics to maintain decades-old freedom of movement between Scotland and the rest of the European Union, even if it is lost by England and Wales.

The passport plan has emerged on the first day of a new Herald series which will examine the central hazards resulting from UK's European divorce while identifying solutions that will enable Scotland to benefit in an entirely new constitutional landscape.

In one key plan, experts believe a devolved Scotland could issue its own national insurance (NI) numbers and that these could be used to apply for jobs on the continent.

Academics also believe that the Scottish Government could grant special Scottish-only NI numbers to citizens from other EU nations who already live in Scotland or who wish to take up posts north of the border.

Professors Damian Chalmers of the London School of Economics and Anand Menon of King's College believe such NI numbers, combined with address information from the electoral roll, would form the basis of "documents additional to their passports which could serve to secure them free movement in the rest of the EU".

The two London professors believe that such arrangements could be transitional, either helping Scotland to a soft landing from Brexit or tiding the nation over to a referendum for independence within the EU.

Their idea is being considered by ministers looking for options both to enable Scots to continue to enjoy freedom of movement rights for which they voted in last June's election - and to keep Scotland in the EU single market, for goods, services and labour.

Insiders stress that the Scottish Government, desperate to mitigate against the predicted economic and social costs of leaving the EU, has an open mind and is ready to think about all sorts of different scenarios.

Speaking ahead of a major Holyrood debate on keeping Scotland in the single market, a Scottish Government spokeswoman said: "This is one of a number of valuable contributions to the debate, and the specific recognition that Scotland will need a close continuing relationship with the EU is a welcome one."

She added: "This and the other similar contributions illustrate the range of options potentially open to Scotland and the UK as a whole, and will inform our thinking as we prepare to publish specific proposals on maintaining Scotland’s place in Europe, including our continued place in the single market."

The Chalmers-Menon proposal was detailed in a position paper, widely shared in government circles, by two Scottish experts, Nina Miller Westoby of Glasgow University and Jo Shaw of Edinburgh.

The experts described continued free movement in Scotland after Brexit as "more plausible than at first blush".

They wrote: "Increasingly immigration control is taking place within the UK, in situ, for example by landlords obliged to confirm residence status before renting property, rather than traditional immigration control at the border, and this may be a means in which a differentiated immigration approach is developed.

"An example that has been mooted by Chalmers and Menon amongst others proposes that the Scottish Parliament become responsible for the issue of NI numbers and thereby develop a system where NI numbers are granted to EU and European Economic Area citizens which are only valid in Scotland."

Such a scheme may mean devolving control over wider migration from London to Edinburgh. UK ministers, including Scottish Secretary David Mundell, have already said they would rule this out.

Such a stance, however, comes long before the start of what are likely to be multi-layer talks between London, Brussels and Edinburgh.

Business leaders and economists are looking for any way to keep a supply of foreign workers for the economy.

David Bell, of Stirling University, has warned that cutting off Scottish access to overseas labour would hurt key industries such as fishing, agriculture and higher education.

He said: "Scotland’s economy does not have a particularly strong export record: reducing its access to foreign workers and their expertise will make it even more difficult to expand its external trade."

Some experts are sceptical about the chances of the British Government giving up control of immigration, even though such powers are devolved in other states, such as Canada.

Kirsty Hughes is the EU expert who first mooted ways for Scotland to keep some of the advantages of EU membership after Brexit without pursuing independence.

However, she now believes that a separate deal on migration and freedom of movement is "highly unlikely" within the union. She said: "If Scotland wants either just migration policy and free movement or the whole single market shebang, how could Prime Minister Theresa May agree to that before knowing what the UK-EU deal was?"

She added: "And if by any chance the EU was ready to let Scotland be in the single market, it would want too to understand how that would mesh with the rest of the UK having a different deal when it has no border with Scotland."

So any Scottish deal, she said, would have to wait for the London-Brussels one. </s> SCOTS would be offered tailored passports as part of a radical proposal to allow them to live and work on mainland Europe after Brexit.

Holyrood officials are currently studying a plan drawn up by academics to maintain decades-old freedom of movement between Scotland and the rest of the European Union, even if it is lost by England and Wales.

The passport plan has emerged on the first day of a new Herald series which will examine the central hazards resulting from UK's European divorce while identifying solutions that will enable Scotland to benefit in an entirely new constitutional landscape.

Read more: Uncertain future for Scotland's tourist industry

In one key plan, experts believe a devolved Scotland could issue its own national insurance (NI) numbers and that these could be used to apply for jobs on the continent.

Academics also believe that the Scottish Government could grant special Scottish-only NI numbers to citizens from other EU nations who already live in Scotland or who wish to take up posts north of the border.

Professors Damian Chalmers of the London School of Economics and Anand Menon of King's College believe such NI numbers, combined with address information from the electoral roll, would form the basis of "documents additional to their passports which could serve to secure them free movement in the rest of the EU".

The two London professors believe that such arrangements could be transitional, either helping Scotland to a soft landing from Brexit or tiding the nation over to a referendum for independence within the EU.

Their idea is being considered by ministers looking for options both to enable Scots to continue to enjoy freedom of movement rights for which they voted in last June's election - and to keep Scotland in the EU single market, for goods, services and labour.

Insiders stress that the Scottish Government, desperate to mitigate against the predicted economic and social costs of leaving the EU, has an open mind and is ready to think about all sorts of different scenarios.

Read more: Uncertain future for Scotland's tourist industry

Speaking ahead of a major Holyrood debate on keeping Scotland in the single market, a Scottish Government spokeswoman said: "This is one of a number of valuable contributions to the debate, and the specific recognition that Scotland will need a close continuing relationship with the EU is a welcome one."

She added: "This and the other similar contributions illustrate the range of options potentially open to Scotland and the UK as a whole, and will inform our thinking as we prepare to publish specific proposals on maintaining Scotland’s place in Europe, including our continued place in the single market."

The Chalmers-Menon proposal was detailed in a position paper, widely shared in government circles, by two Scottish experts, Nina Miller Westoby of Glasgow University and Jo Shaw of Edinburgh.

The experts described continued free movement in Scotland after Brexit as "more plausible than at first blush".

They wrote: "Increasingly immigration control is taking place within the UK, in situ, for example by landlords obliged to confirm residence status before renting property, rather than traditional immigration control at the border, and this may be a means in which a differentiated immigration approach is developed.

"An example that has been mooted by Chalmers and Menon amongst others proposes that the Scottish Parliament become responsible for the issue of NI numbers and thereby develop a system where NI numbers are granted to EU and European Economic Area citizens which are only valid in Scotland."

Such a scheme may mean devolving control over wider migration from London to Edinburgh. UK ministers, including Scottish Secretary David Mundell, have already said they would rule this out.

Read more: Uncertain future for Scotland's tourist industry

Such a stance, however, comes long before the start of what are likely to be multi-layer talks between London, Brussels and Edinburgh.

Business leaders and economists are looking for any way to keep a supply of foreign workers for the economy.

David Bell, of Stirling University, has warned that cutting off Scottish access to overseas labour would hurt key industries such as fishing, agriculture and higher education.

He said: "Scotland’s economy does not have a particularly strong export record: reducing its access to foreign workers and their expertise will make it even more difficult to expand its external trade."

Some experts are sceptical about the chances of the British Government giving up control of immigration, even though such powers are devolved in other states, such as Canada.

Kirsty Hughes is the EU expert who first mooted ways for Scotland to keep some of the advantages of EU membership after Brexit without pursuing independence.

However, she now believes that a separate deal on migration and freedom of movement is "highly unlikely" within the union. She said: "If Scotland wants either just migration policy and free movement or the whole single market shebang, how could Prime Minister Theresa May agree to that before knowing what the UK-EU deal was?"

She added: "And if by any chance the EU was ready to let Scotland be in the single market, it would want too to understand how that would mesh with the rest of the UK having a different deal when it has no border with Scotland."

So any Scottish deal, she said, would have to wait for the London-Brussels one. </s> Scotland's parliament has voted in favour of a call by First Minister Nicola Sturgeon for a second referendum on Scottish independence within two years, but the British government has refused to discuss it.

The motion passed 69 votes to 59 on Tuesday and paves the way for the opening of formal talks between Scotland and the British government on the new referendum, coming just three years after Scottish voters rejected independence.

Al Jazeera's Neave Barker, reporting from London, said it was "a significant step forward for supporters of Scottish independence in bringing about something that was essentially scuppered back in 2014".

"For Brexit supporters, it means a massive headache," he said.

On Wednesday, British Prime Minister Theresa May is expected to trigger Article 50 of the European Union's Lisbon Treaty, the first formal step towards Brexit that Scotland opposes.

Sturgeon, who leads the Scottish National Party (SNP), has complained that her efforts to seek a compromise on Britain's exit from the EU met intransigence from May's Conservative government.

"Scotland's future should be in Scotland's hands," Sturgeon told lawmakers in the Edinburgh-based parliament.

She told Scottish legislators she would seek to negotiate with the British government "in good faith and with a willingness to compromise".

Should that fail, she promised to inform the parliament of the next steps next month.

London's response

Shortly after the parliament's approval, the British government said on Tuesday it would not be entering into negotiations on the referendum.

"It would be unfair to the people of Scotland to ask them to make a crucial decision without the necessary information about our future relationship with Europe, or what an independent Scotland would look like," it said.

Al Jazeera's Nadim Baba, reporting from Edinburgh, said the current public opinion in Scotland on the issue was divided in the middle.

"What people in Scotland want to know is what exactly the relationship with the EU would be in future and whether its worth prioritising staying in the EU over the trade union with the rest of the UK," he said.

The UK's vote last year to exit the EU has strained ties between its four constituent parts because England and Wales voted to leave while Scotland and Northern Ireland voted to remain. </s> LONDON (AP) — Scotland’s leader has again warned that a second referendum on Scottish independence is likely if British leaders pursue a radical break with the European Union.

First Minister Nicola Sturgeon closed the Scottish National Party conference in Glasgow on Saturday with a vow to take action to keep Scotland inside the EU’s enormous single market even if Britain leaves.

She said if the British government rejects those efforts and takes steps to hurt Scotland’s economy she would “make sure” that Scots get another chance to choose a better future.

The pro-independence Sturgeon had said Thursday that her government would shortly publish a bill laying the groundwork for a new independence referendum — the first step toward a new vote on whether Scotland should leave the U.K.

An earlier referendum in 2014 ended with Scottish voters opting to remain part of the United Kingdom.

Sturgeon says the UK that existed in 2014 will no longer be in existence if there is a so-called “hard Brexit” departure — one that severs economic ties to Europe’s markets and leads to a lowering of living standards and unemployment in Scotland.

She pointed out that Scottish voters had indicated a strong desire to remain in the EU in the June 23 referendum. They were joined in that view by residents of London and Northern Ireland, but a majority of British voters cast ballots in favor of leaving the 28-nation bloc.

British Prime Minister Theresa May has said she will start the formal process to withdraw from the EU by March 31, 2017. The complex process is expected to take at least two years.

In another sign that Sturgeon is determined to place Scotland on its own path, she said she plans to open a Scottish “trade and innovation” hub in Berlin, the German capital, and to set up a trade envoy system to pursue Scottish business links. </s> EU judges delivered a boost for Remainer rebels today by ruling that Britain can unilaterally cancel Brexit.

The European Court of Justice decided that Article 50 can be withdrawn by the UK without permission from other member states.

Britain would keep its current terms of membership if it quit the process - meaning keeping the rebate, the opt out from the Euro and exemptions from the Schengen passport-free zone.

The ruling by the 27 EU judges will fuel tensions ahead of the crunch vote on Theresa May's Brexit deal tomorrow.

It will encourage hopes from pro-EU MPs that a second referendum can be held to stop the UK from leaving the bloc altogether.

The case to decide whether an EU member state such as the UK can decide on its own to revoke the Article 50 withdrawal process was brought by a cross-party group of Scottish politicians.

They are Labour MEPs Catherine Stihler and David Martin, Joanna Cherry MP and Alyn Smith MEP of the SNP, and Green MSPs Andy Wightman and Ross Greer, together with lawyer Jolyon Maugham QC, director of the Good Law Project.

Ms Cherry said: 'I'm delighted that we now know definitively that there is an option to stay in the EU.

'The UK government has ignored Scotland's vote to remain and all compromises suggested by the Scottish Government.

'They also fought us every inch of the way in this case, so it's a particularly sweet irony that Scottish parliamentarians and the Scottish courts have provided this lifeline to the UK parliament at this moment of crisis.'

First Minister Nicola Sturgeon tweeted: 'Important judgment from ECJ - Article 50 can be unilaterally revoked by UK.'

She added: 'So an extension of Article 50 to allow time for another vote, followed by revocation of Article 50 if the outcome is Remain seems to be an option that is now open to the House of Commons.'

People's Vote campaigner Dame Margaret Beckett said: 'This is confirmation that it is still up to us to decide whether we want to keep the existing deal we've got in the EU rather than accept a bad deal negotiated by the Government.

'What has happened in the last week is that any prospect of no deal has been removed by amendments allowing Parliament to take control, while we now all know beyond any doubt that we can stay in the EU - it's not too late.'

Liberal Democrat Tom Brake said: 'The ECJ has made clear that the UK can stop Brexit unilaterally. The Government can therefore prevent a chaotic no-deal.

'For the sake of people's livelihoods, the Prime Minister must end the uncertainty and rule out a no-deal.'

Best for Britain chief Eloise Todd said the court ruling meant 'our future is in our hands'.

She said: 'As the Prime Minister tries every desperate measure to get her deal through the Parliament, MPs need to recognise that when her deal is defeated they should move as quickly as possible to give the people of this country the final say on whether to stay in or leave the EU.'

The winners argued in court that unilateral revocation was possible. They believe it could pave the way for an alternative option to Brexit, such as a People's Vote to enable remaining in the EU.

However, legal representatives for the UK Government claimed the case is inadmissible as it deals with a hypothetical situation, since the Government's policy is not to revoke Article 50.

Lawyers representing the Council of the European Union and from the European Commission meanwhile argued that revocation is possible but would require unanimous agreement from all member states.

Last week the court's Advocate General rejected the idea that approval is needed from the European Council.

Instead, Manuel Campos Sanchez-Bordona said Article 50 allows the 'unilateral revocation of the notification of the intention to withdraw from the EU, until such time as the Withdrawal Agreement is formally concluded'.

The case was originally heard by the Court of Session in Edinburgh and two attempts by the UK Government to appeal against the referral to the European court were rejected.

Once the ECJ has delivered its ruling the case will be referred back to the Court of Session, where judges are expected to 'frank' the decision and declare the European Court's answer to be the law on the matter. </s> EDINBURGH (AFP) - Former Catalan minister Clara Ponsati, who is wanted by Spain for her role in last year's independence bid, surrendered to Scottish police on Wednesday (March 28) to face arrest under a European warrant.

Ponsati was later released after being granted bail, but was ordered to surrender her passport during a preliminary extradition hearing at a packed Edinburgh Sheriff Court, pending a full hearing.

Lawyers for Ponsati, a professor at the University of St Andrews, said they will "robustly" reject charges of violent rebellion and misappropriation of public funds for helping to organise last year's independence referendum in Catalonia, which the government in Madrid deemed illegal.

Supporters outside the court when she was released waved Catalan separatist flags and help up a banner reading: "We are with you".

She has received support from members of the Scottish National Party (SNP), which runs the devolved government in Edinburgh, which has condemned arrest warrants issued for the Catalan politicians.

However, Scottish First Minister Nicola Sturgeon has insisted she cannot intervene in an independent legal extradition process.

An online campaign to raise funds for Ponsati's extradition battle was launched earlier on Wednesday, and within three hours had raised more than £90,000 (S$160,000).

"My legal team is instructed to robustly defend Clara as she views these charges as 'political persecution' and a systematic attempt to crush the spirit of the Catalan people and their desire for freedom," her lawyer Aamer Anwar said in a statement.

"She does not believe that the Spanish courts can guarantee independence, human rights or justice. Clara remains defiant, resolute and is determined to fight back."

On her behalf, he thanked the staff at the university, the "many hundreds of thousands of ordinary people" who had backed her, as well as Sturgeon and the Scottish government.

"Scotland has been a true friend to Catalonia in her darkest hours," the lawyer said.

"However, it is absolutely right that the independence of the judiciary in Scotland is respected and that no government should ever interfere in that process. Clara accepts her fate now lies in the hands of the Scottish justice system."

A Spanish judge last week issued international and European arrest warrants for Ponsati and other separatist leaders, including former regional president Carles Puigdemont.

Puigdemont was arrested by German police on Sunday.

Spain's Supreme Court said it would prosecute 13 key separatists including Puigdemont and Ponsati for "rebellion", a crime which carries a maximum penalty of 30 years in jail.

Ponsati was a minister in the Catalan government when it declared independence from the rest of Spain following a referendum in October.

She fled later that month with Puigdemont and three other former ministers to Brussels, after Spain dismissed the Catalan executive and imposed direct rule.

Ponsati then returned to the University of St Andrews, north-east of Edinburgh, where she had formerly worked and is a professor in the school of economics and finance. </s> Support for independence remains higher than it was in 2014, a new poll has found, as Scotland today marks the second anniversary of the historic referendum.

Scots remain split down the middle on the issue of leaving the UK, the Panelbase poll for the Sunday Times finds with 48% saying they would vote Yes, while 52% want to remain in the union. This up from the 45% who voted Yes in the referendum two years ago today, while 55% said No.

But it finds that the post-Brexit spike in support for independence has fallen away, with about two-thirds of Scots opposed to another referendum being staged.

A series of events are being held around the country today, to mark the second anniversary, with pro-independence rallies being held in Glasgow and other cities, while pro-Union have stepped up their calls for a proposed second referendum to be abandoned.

First Minister Nicola Sturgeon today said that independence is more important than "oil, national wealth and balance sheets".

"Two years on from the historic vote of 2014, the fundamental case for Scotland's independence remains as it was," she wrote in an article for the Sunday herald newspaper.

"The case for full self-government ultimately transcends the issues of Brexit, of oil, of national wealth and balance sheets and of passing political fads and trends."

A rally of independence supporters is to be held at Glasgow Green. A relaunch will also take place in the city of the Scottish Independence Convention. Other events are taking place in Oban and Inverness, and a rally is also planned for Edinburgh later in the week.

Ms Sturgeon has said that a second referendum is "highly likely" in the aftermath of the Brexit vote and this month launched a "listening exercise" aimed at winning over wavering Scots to independence.

Opposition leader Ruth Davidson has responded by setting up her own taskforce to map out the possibilities for Scotland after Brexit - but as part of the UK. </s> EDINBURGH, Scotland (AP) — Scottish lawmakers voted Tuesday to seek a new referendum on independence, presenting the British government with an unwelcome distraction as it prepares to push the European Union exit button.

The Edinburgh-based legislature voted 69-59 to ask the U.K. government to sanction an independence vote that would be held within the next two years. Outside, several dozen independence supporters bearing Scottish and EU flags broke into cheers and tears of joy as they heard the news.

Scottish First Minister Nicola Sturgeon, who asked lawmakers to authorize her to request the referendum, says Scots must be given the chance to vote on their future before Britain leaves the European Union.

British Prime Minister Theresa May plans to launch the U.K’s two-year process of exiting the EU on Wednesday by triggering Article 50 of the bloc’s key treaty.

Britain as a whole voted to leave the bloc in a referendum last year, but Scots voted by a large margin to stay.

“Scotland’s future should be in Scotland’s hands,” Sturgeon told lawmakers before the vote.

Scottish voters rejected independence in a 2014 referendum that Sturgeon’s Scottish National Party called a once-in-a-generation vote. But Sturgeon says Brexit has altered conditions dramatically.

She says there should be a new plebiscite on independence between fall 2018 and spring 2019, when details of Britain’s divorce terms with the bloc are clear.

Sturgeon said that whatever the final terms, Brexit would mean “significant and profound” change for Scotland.

“That change should not be imposed upon us,” she said. “We should have the right to decide the nature of that change.”

May, whose government must approve the referendum for it to be legally binding, says the time is not right. She says all parts of the U.K. – England, Scotland, Wales and Northern Ireland – must pull together to get the best-possible deal with the EU.

Scottish Conservative leader Ruth Davidson agreed, saying Tuesday that Scots do not want “the division and rancor of another referendum campaign.”

The Scottish parliament had been due to vote on Sturgeon’s referendum demand last week, but the session was adjourned after Wednesday’s extremist attack in London.

Sturgeon’s referendum call was backed by the governing Scottish nationalists and the Greens, and opposed by the Conservative and Labour parties.

It’s unclear what could break the stalemate between Edinburgh and London. British officials have indicated they would not agree to another independence referendum until Britain’s EU exit is over and done with – a process that could take longer than two years.

David Mundell, the British government’s Scotland minister, said the U.K. government would not be “entering into negotiations on whether there should be another independence referendum during the Brexit process.”

“It’s not appropriate to have a referendum whilst people do now know what the future relationship between the U.K. and the EU will be,” he said.

Sturgeon said after the vote that she would “seek sensible and constructive discussion” with the British government later this week.

“I hope the United Kingdom government will respect the view of parliament,” she said. “This is simply about giving people in Scotland a choice.”

Should that fail, Sturgeon promised to inform the parliament of next steps after its Easter break next month.

In Edinburgh, supporters of Scottish independence urged Sturgeon to forge ahead.

Scott Murray, a 71-year-old music tutor, said the vote for Brexit had changed everything.

“I think we should have another referendum,” Murray said. “I feel that we are divorced from what happens in the south of England and we should be our own country and stand on our own two feet.”

But plumber Brian Hamilton, 45, said he’d be happier if members of the Scottish National Party government “got on with their day jobs” rather than focusing on Europe.

“They say they speak for the people of Scotland, but they don’t speak for the people of Scotland because they are not representing me whatsoever,” he said. </s> The voice of Remain voters in Scotland has been muted as political parties concentrate on protecting the devolution settlement or arguing for a soft Brexit, a think tank has warned.

The Scottish Centre on European Relations (SCER), which celebrates its first anniverary this week, claimed “all remains to be played for” ahead of Brexit despite there being an “untapped energy, anger, concern and passion” north of the Border on the issue of leaving the European Union.

“Given Theresa May’s stance on leaving the EU’s customs union and single market, the UK is heading, at best, for a ‘Canada-dry’ free trade deal with the EU,” said SCER director Dr Kirsty Hughes.

“That could cut UK-EU trade by almost half – and by more for services trade.

“So why is the Remain voice in Scotland so muted? Current polls show two-thirds or more of Scottish voters now support ‘remain’. The other third are split between those who want Brexit as part of the UK and the ‘yes leavers’ who want independence outside the EU. On top of the ‘power grab’ over devolved powers, a cross-party outcry and campaign against Brexit might not seem unreasonable.

“But we are a long way now from the 92-0 vote in the Scottish Parliament (with the Tories abstaining), a week after the Brexit vote in 2016, to explore ways to keep Scotland in the EU and its single market. The ambition fell rapidly from staying in the EU to a focus on the single market – and currently Scottish Labour isn’t even supporting that.”

READ MORE: Brexit ‘will not be constitutional game changer’ for SNP

The SCER was established in Edinburgh as a non-aligned independent think tank with the aim of informing the debate on Europe and providing high-quality research and analysis on EU developments.

It has launched an online fundraiser with a view to funding its work for another year.

Dr Hughes added: “It’s a year since Nicola Sturgeon’s abortive attempt to hold a second independence referendum on the back of Brexit. The Scottish Government continues to repeatedly express its ‘regret’ at the UK leaving the EU and to state that the best option would be to stay. But there is no strategy to back this up: how does the Scottish Government think this might happen and what is its role in pushing for a halt to Brexit?

“Instead, the Scottish Government’s main efforts are focused on two areas: protecting the devolution settlement including through its introduction of an EU ‘continuity’ bill at Holyrood; and linking up with Labour rebels, LibDem and Green MPs at Westminster to argue for a ‘soft’ Brexit of staying in the customs union and single market.”

Brexit minister Michael Russell said the Scottish Government was already working hard to mitigate any potential damage caused by the decision to leave the EU.

“The people of Scotland voted overwhelmingly – by a 24-point margin – to remain in the European Union,” he said. And, short of continued EU membership, the least damaging outcome for Scotland and the UK is continued membership of the single market, which is around eight times bigger than the UK’s alone, and customs union.

“The Scottish Government has set out both the significant impact of Brexit on Scotland and detailed practical policy proposals for how Scotland can retain a future relationship with the EU – indeed we were the first administration in the UK to do this in December 2016, with further information published in January this year. We will continue to work to mitigate the damage Brexit will cause to jobs, trade, investment, education and to our public services. In everything we do, we will continue to seek agreement in the best interests of the people of Scotland.”
Scotland is considering launching its own passports to maintain the decades-old freedom of movement between Scotland and the rest of the European Union, even if it is lost by England and Wales.