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After the United Kingdom’s decision to terminate its membership to the European Union (EU) with the Brexit referendum held in 2016, the execution process of the decision started in accordance with Article 50 of the Lisbon Treaty, and the United Kingdom officially left the EU with the “Withdrawal Agreement” on January 31, 2020. The United Kingdom has developed different visions in its post-Brexit strategies. It has re-organized bilateral or multilateral agreements in areas such as trade, service market, finance, banking, transportation, industrial production, in which it has become a partner within the EU. However, another issue that has surfaced for post-Brexit Britain is the fact that the states within the United Kingdom will not be able to find the economic benefits they found in a United Kingdom integrated with the EU after Brexit. Especially for the regions that are seeking political independence (Northern Ireland and Scotland), the satisfaction that has lasted throughout the UK’s EU membership has not continued after Brexit. Especially in Northern Ireland and Scotland, public opinion has developed more different perspectives on its relations with the post-Brexit United Kingdom. In this regard, it is necessary to briefly evaluate the situation of the countries regarding the process.
NORTHERN IRELAND
The most important issue to be mentioned in particular about Northern Ireland was the existence of a paramilitary organization called the Irish Republican Army (IRA), which has been fighting against the United Kingdom for many years on the Island of Ireland, part of the separatist movements that form the basis of the conflicts in the region. For many years, this organization has continued its activities with the ideal of separating Northern Ireland from the United Kingdom and uniting it with the Republic of Ireland. In particular, the so-called “Troubled Times”, which lasted from 1960 to 1998, were the most intense period of IRA activity. After the process, although the “Good Friday Agreement” of 1998 brought a significant end to the violence, the IRA tacitly continued to carry out its activities. The separatist influence and social movements created by this organization are still effective in Northern Ireland. So much so that the Sinn Fein Party, which can be seen as the political side of the IRA in the Northern Irish parliament today, is also influential in Northern Ireland politics.
Another issue that can be mentioned about Northern Ireland is the signing of the “Northern Ireland Protocol” between the EU and the United Kingdom in the post-Brexit period, which contains Decrees on the commercial status of Northern Ireland. Northern Ireland and the EU will continue to be in the single market according to this protocol; the process of control and processing of customs goods between the United Kingdom and the EU(the process of checks of compliance with the trade regulations and procedures of the EU and the United Kingdom) will take place at the ports of Northern Ireland. Together with this protocol, an implicit but de facto border was established between Northern Ireland and the United Kingdom, which created the public perception that Northern Ireland had achieved an independent appearance from the United Kingdom. Especially on the pro-British Northern Irish “Unionists” side, the issue has raised doubts that Northern Ireland’s bilateral relationship with the neighboring country of the island of Ireland, the Republic of Ireland, may develop more and this could lead to a possible separation from the United Kingdom.
Another thing that should be known about this issue is that the nationalist party Sinn Fein, which wants to unite with the Republic of Ireland, won the elections as the first party in the assembly elections held on May 5, 2022 in Northern Ireland. After this election, the Democratic Unionist Party (DUP), which defends the integrity of the United Kingdom, has become the second party. However, Northern Ireland’s special government model, created in accordance with the 1998 “Good Friday Agreement”, requires that the first and second party in the ranking as a result of the election govern the region together. Therefore, there are points where the two parties need to compromise and take joint decisions. The first party, Sinn Fein, wants to unite with the Republic of Ireland by a referendum by 2025, while the second party, the Democratic Unionist Party (DUP), is campaigning in favor of continuing within the United Kingdom. However, according to the laws of the United Kingdom, the approval of the Parliament of the United Kingdom will be required for such a referendum decision to be taken.
Recently, a number of developments have taken place aimed at eliminating the controversial framework in the Northern Ireland Protocol signed after Brexit. The original protocol text has been updated together with the “Windsor Framework Agreement”[2] published after the meeting held in Windsor, England on February 27, 2023 under the leadership of Rishi Sunak, who was elected as the Prime Minister of the United Kingdom after the resignation of Liz Truss, and Ursula von der Leyen, the President of the European Commission. With this agreement, the “Green Line” and “Red Line” applications have been put forward. According to these updates, the green line will be used in the flow of goods through the Irish Sea from the United Kingdom to the Republic of Northern Ireland, and no trade restrictions will apply, but the red line will be used in the flow through Northern Ireland to another island country, the Republic of Ireland, and the necessary customs costs and trade taxes will be allocated in accordance with the regulations of the United Kingdom. In this way, the flow of goods between the Republic of Ireland, a member of the European Union, and the United Kingdom, customs costs and trade losses, as well as the disadvantages that Northern Ireland will experience due to Brexit, will be minimized. A mechanism called the “Stormont Brake” has also been developed with the agreement. With this mechanism, it gives Northern Ireland the right to unilaterally suspend the implementation of these decisions in its area of commercial activity against the decisions taken by the EU in order to prevent the damage that a decision taken by the European Union in the future may cause in Northern Ireland.
SCOTLAND
The independence debate against the United Kingdom is also on the agenda for Scotland. The last time the results of the independence referendum held in Scotland in 2014, the people of Scotland rejected the request to leave the United Kingdom by almost 55%. But after Brexit, dissenting views towards the United Kingdom have begun to rise in Scotland.
The most recent Scottish elections, held in 2021, were won by the Scottish National Party (SNP), also known for its pro-independence views and party campaigns. The SNP, which has carried out strong initiatives for this purpose under the leadership of SNP leader and former Prime Minister of Scotland Nicola Sturgeon, has gone to intra-party elections after Nicola Sturgeon’s resignation. After the elections held in March 2023, Yusuf Hamza, a Muslim of Pakistani descent, emerged as the leader from both the election for the party presidency and the prime ministerial elections in parliament. Yusuf Hamza, who started his political career as an SNP MP in the Scottish parliament in 2011, has also served as Minister of Transport and Minister of Justice under SNP leader Nicola Sturgeon and has gained a respected position within the party. Yusuf Hamza, who has been fighting against the racist discourses he has faced throughout his life, has a symbolic meaning by showing that this political success he has achieved as a citizen belonging to an ethnic minority and religion can be evaluated independently of ethnic and religious prejudices to lead a nation.
SNP leader Yusuf Hamza has often stressed the necessity of Scottish independence in his statements, just like former SNP leader Nicola Sturgeon, and has also held a series of meetings with UK prime minister Rishi Sunak on this issue. On the other hand, the United Kingdom has tried to prevent this situation with a series of laws passed during the preliminary preparation phase of Brexit against Scotland’s possible independence demands after Brexit. One of them is the “Sewel Contract”. In this agreement, it is emphasized that the Parliament of the United Kingdom must obtain approval from the legislatures of Scotland, Wales and Northern Ireland, where it has carried out the devolution prior to the decisions it will take on Scotland, Wales and Northern Ireland or the laws it will implement. In this way, it has been ensured that the parties have a say in the regions, despite the unilateral laws that may be submitted by the United Kingdom. Similarly, the “Section Order 30” of the supreme court of the United Kingdom can be given as an example of this. According to this article, which is stated in the “Scotland Act” [1] of 1998, the regulations on the articles containing Scotland’s adherence to the constitution of the United Kingdom are reserved by the United Kingdom. However, an amendment or bill requested by Scotland (such as a referendum) can come into force if it is deemed necessary by the UK Parliament. As a matter of fact, the 2014 Scottish Referendum was held in this way.
However, against Scotland’s recent independence referendum requests, the United Kingdom judiciary rejects these requests, the Scottish referendum held in 2014 as an example. the fact that the referendum in 2014 was called “once in a generation” by the then SNP leader Nicola Sturgeon leads the United Kingdom to use the concept of “generation” in its favor as a justification for its decision to reject referendum demands. At the heart of the matter lies the idea that such a profound referendum decision can be decided once in a generation, and such a right will be passed on to the next generation. However, there is no clear concrete law or explanation for this, and the statement is included in the discourses of the parties within a strategic framework.
There have been changes in the views of post-Brexit countries in the economic, social and political contexts of the UK administration. In the case of Northern Ireland, new trade barriers have emerged not only with the EU after Brexit, but also between Northern Ireland and the United Kingdom. Although Northern Ireland’s commitment to the EU internal market continues to a certain extent with the Northern Ireland Protocol, the new tariffs and customs imposed by separation have led to the formation of complex arrangements. In particular, with the protocol, Northern Ireland’s continued flow of goods and products through the EU has created a “de facto” EU customs union point for the United Kingdom. These are an example of the concept of “Soft Brexit” in order to prevent a hard transition after Brexit due to the reduction of border control between the Republic of Ireland and the United Kingdom during the years of union within the EU and the high internal market volume, this interim arrangement has been decided. However, despite this privilege, Northern Ireland’s inability to fully enjoy the rights of free movement of people and capital ultimately creates many negative economic consequences for Northern Ireland. It is an enigma how much Northern Ireland, with its weak economy and fragile political structure, can provide this continuity. On these issues, voters in Northern Ireland have begun to doubt about what Brexit means for Northern Ireland in general. In particular, the fact that supporters of the United Kingdom “Unionists” are also worried about Brexit is a development that should be taken into account. Especially as a result of the formation of such negative outcomes, it is likely that existing separatist movements will strengthen using populist strategies. An example of this is that the Sinn Féin Party came first in the 2022 elections.
For Scotland, on the other hand, the need to make a plausible decision about the costs and profitability of independence will determine voters’ awareness of the possible economic consequences of independence. Because in a possible post-independence situation, Scotland may not benefit as much as it integrates into the United Kingdom, especially in its economic restructuring. Especially for Scotland, which has a high volume of commercial exchange with the United Kingdom in land connection and maritime trade due to its location, a possible separation situation does not seem to bring a definite separation with the United Kingdom. In addition, according to the latest polls, apart from the undecided voter base between 10-14% in the Scottish public, there has also begun to be a decline in voters who are moderate to separation from the United Kingdom, this ratio is 46%-49% No to separation. [8] [9] Also, for the Scottish public, concerns about national health spending, social security and economic issues are at the center of concerns. In this regard, whether the cost of a possible Scottish independence is a debatable issue, but given that the difference between voters who have a difference of opinion on the issue can change quickly along with deciders, there may be a surprise decision that will come out as a result after a referendum that will develop with a possible UK approval.
The increasing separatist movements in Northern Ireland and Scotland within the United Kingdom after Brexit are the focus of concerns, especially due to the disappearance of the privileges brought by the European Union economically. If the parties are to be compared, the social and political state of division that Northern Ireland is in causes Northern Ireland separatists to have a more fanatical attitude than in Scotland. For Scotland, on the public eye, there is an assessment of whether it would be more beneficial for Scotland to gain an independent status than to be part of the United Kingdom. It can be said that a more rational attitude is seen in Scotland compared to Northern Ireland in this regard. On the one hand, the fact that the Pakistani-born Yusuf Hamza, the SNP leader in Scotland, continues to insist on independence, on the other hand, the Indian-born Rishi Sunak, the British Prime Minister, does not want to lose Scotland; the fact that the political integrity of the United Kingdom, which has an ethnically homogeneous political structure for many years, now can be determined by two leaders rising from the “Subcontinent”, has a symbolic meaning, showing that the identity of “Britishness”, an imperial legacy, is now part of the island’s culture.
Bibliography
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- Foreign, C. &. D. O. (2023, March 24). UK and EU to formally adopt the Windsor Framework. UK. www.gov.uk/government/news/uk-and-eu-to-formally-adopt-the-windsor-framework
- The Scottish Government. (2021). After Brexit: The UK Internal Market Act and devolution. The Scottish Government. www.gov.scot/publications/brexit-uk-internal-market-act-devolution/pages/5/
- Street, P. M. O. 1. D. (2023). The Windsor Framework. UK. www.gov.uk/government/publications/the-windsor-framework
- Impact of Brexit on Scottish communities and their advice needs now. (n.d.). Citizens Advice Scotland. cas.org.uk/publications/impact-brexit-scottish-communities-and-their-advice-needs-now-and-future
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- Peacock, J. (2023, January 25). Latest Scotland poll shows support for independence at 46% | Survation. Survation. www.survation.com/latest-scotland-poll-shows-support-for-independence-at-46/
