35 min read

Not Yet. Not Never. Just Not Yet. The word that has held Scotland as an English colony for 300 years and the international law that outlawed it in 1960. Engaging with Liberation Scotland's Colonial Markers [Ref: SCM–CM0c]

Abstract. This is the third and final post engaging Liberation Scotland’s Colonial Marker 0, Postcolonial Theory Applying to the Scottish Situation, closing the trilogy where the marker itself begins, with the act of naming. The first post established, through the francophone anticolonial writers and the Latin American decolonial school, that the structure of the colonial relationship describes Scotland without adjustment. The second showed what was done to the two languages in which Scotland might have named itself. This post takes up four thinkers who have tried to name the condition directly. Michael Hechter gave the Scottish case its first rigorous social science and then filed it under a term, internal colonialism, which this series retires because the concept was built in Latin America to describe something structurally different. Its adjective concedes the precise constitutional claim in dispute and its author's own title reduces Scotland to a fringe of somebody else's national development. Robbie McVeigh moves the object of analysis decisively, exposing the Union not as the neutral container within which colonisation may or may not have occurred but as itself a racialised colonial construction and the necessary condition of colonialism and empire. Alfred Baird inverts Hechter's method entirely, building his framework from the Scottish evidence outward and naming the condition in the language the colonisation tried to kill; doun-hauden, meaning “held down” in Scots. Paulo Freire supplies the turn from analysis to action. Between them the post opens onto a body of work rarely brought to bear on Scotland at all; the subaltern historians of South Asia. Ranajit Guha showed that the colonial archive records a subject people's resistance as crime rather than as politics, which is the grammar Scottish historiography inherited and has never audited. Partha Chatterjee showed that a nationalism which argues inside the coloniser's categories is a derivative discourse, which is the most exact available account of what Scotland's constitutional politics has been doing for fifty years. Dipesh Chakrabarty identified the manoeuvre this post takes as its centrepiece; historicism's waiting room of history, in which a colonised people is told not yet, not never, merely not yet, until the waiting itself becomes the government. That is the "too wee, too poor, not ready" argument in its theoretical form. It is, in terms, prohibited. Article 3 of United Nations General Assembly Resolution 1514 (XV) provides that inadequacy of political, economic, social or educational preparedness shall never serve as a pretext for delaying independence. The waiting room was outlawed in 1960. Scotland is still sitting in it.

A Nation With No Word for What Is Happening to It

Take an inventory of the vocabulary Scotland has been issued for its own situation.

The Union. The constitutional question. The national question. Devolution. The settled will. The reserved matters. Section 30. The independence debate. Separatism. Nationalism. Grievance. The referendum.

Now look at what those words are.

Some name a procedure with a mechanism, a schedule, a category of legislative competence. Some name an aspiration, a thing Scotland might one day seek. Others name a pathology, a disorder of the Scottish temperament requiring management. One names a document signed under coercion and bribery in 1707 against the will of the Scottish people.

Not one of them names a relationship. Not one describes a condition in which one nation governs another, holds its resources, decides its foreign policy and determines whether its people may vote on the arrangement. The entire lexicon that Scotland has been given for its own circumstances contains no term for the circumstances themselves.

That absence is the subject of this post, deserving to be recognised for what it is before anything else is said.

Every colonised people in modern history has had to fight to have its condition recognised. Scotland has to fight, first, to have its condition named. That’s a prior struggle and a harder one. A people cannot demand recognition of something for which no permitted word exists. You cannot lodge a claim in a category you are not allowed to enter. You cannot be heard denying a charge nobody has framed.

Consider how unusual this is. Ireland had a word long before independence; the argument in Ireland was about what should follow from the word, never about whether it applied. Algeria had a word, though France insisted the territory was three départements of the Republic. Kenya, India, Indonesia, Vietnam, Guam, Kanaky, Western Sahara; in every case the colonised knew what to call the thing being done to them. The fight was over the consequences.

Scotland is a nation of five and a half million people, with a continuous documented existence of more than a thousand years, whose situation has no agreed name inside its own political culture. A Scot who says colony is not contradicted with evidence. He is corrected on his choice of word, told the term is inflammatory, unhelpful, historically illiterate, a category error. The correction arrives most often from an English colonial propaganda bot run by the English state cyber armies, from a genuine “British” unionist or from another Scot, in good faith, as a courtesy. That is of course changing and faster than the corrections can keep up. The word is being said now, in the compendium of markers, at the United Nations, online, in Scots homes and Scots pubs and across the whole apparatus of ordinary conversation that no state has ever found a way to police. A people that has begun naming its own condition does not go back to the old vocabulary, which no longer describes anything it can recognise. The correction still arrives. It simply no longer lands.

The previous post established that the colonial state used two distinct weapons against Scotland's two languages. Gaelic was prohibited by statute, punished in the classroom, and legislated against by name. Scots was never banned at all but reclassified, redefined as bad English, abolished as a category while a million and a half people went on speaking it. The argument there was that reclassification is the more efficient of the two. A prohibition confers the status it denies whereas a category dissolved leaves nothing to revive and no martyrs to remember.

The same two weapons operate at the level of political vocabulary. Scotland got the second one.

Nobody in Britain has ever forbidden the word colony in relation to Scotland. There is no ban or proscription; a prohibition would confer standing. It would generate a controversy and produce a case. What was done instead was to ensure that the word never attached; that Scotland's situation was filed, in law, in scholarship, in journalism and in ordinary conversation, under headings from which the word could not follow. Union is not a relationship of domination that might or might not obtain. It’s a settled description that forecloses the question. Devolution presupposes a centre with powers to devolve. Separatism presupposes a legitimate whole. Each of those words does its work before any evidence is examined. None of them can be argued with since none of them makes a claim. They simply occupy the ground where a claim would go.

This is why Liberation Scotland numbered theory at zero rather than at eight, and why this trilogy exists. The evidence assembled under the other seven markers is not in serious dispute; the garrisons, the clearances, the statutes against the languages, the reserved powers, the extraction, the suppressed report, the franchise of 2014; most of it is a matter of public record, much of it in the coloniser's own archive. What has been missing is not evidence; or not only evidence. It’s the name that makes the evidence add up to something. The name has been kept out of reach by the simplest method available; by leaving the space where it should be occupied by words that sound like descriptions and are in fact rulings.

The word exists in every dictionary in every language. It’s the subject of Chapter XI of the Charter of the United Nations, appearing in the title of a committee of the General Assembly which has met every year since 1961 to consider territories to which it applies.

It has simply never been permitted to attach to Scotland.

This post is about four people who tried to make it attach; one who came close and slipped, one who redirected the question so sharply that the whole field moved, one who built the name upward from the Scottish evidence in the Scottish tongue, and one who explained why the naming is not the preface to liberation but the first act of it. It’s also about a body of work from colonial South Asia, which explains with uncomfortable precision how a people's resistance gets recorded as crime and its politics becomes a borrowed argument. The colonised people is held indefinitely in a waiting room by a word that never says no.

The word that never says no is yet.

The Politics of a Word

So consider what changes when the word attaches.

Call Scotland's situation a voluntary union and the governing framework is domestic constitutional law, in which the remedy is persuasion and the arbiter is the other party to the dispute. Call it devolution and the framework is administrative. Call it colonisation and the framework becomes the international law of decolonisation.

If we call it colonisation, the framework becomes the international law of decolonisation with United Nations General Assembly Resolution 1514 (XV) of 1960, the Declaration on the Granting of Independence to Colonial Countries and Peoples, which holds the subjection of any people to alien domination to be a denial of fundamental human rights and contrary to the Charter; the erga omnes obligations attaching to self-determination, a Latin term meaning towards all, denoting a duty owed not to one state but to the international community as a whole, so that every state has a legal interest in its observance and no single state can waive it; and the jurisprudence the International Court of Justice has built on it. In Namibia (1971), the Court held South Africa's continued administration unlawful, requiring every state to withhold recognition from it. In East Timor (1995), it affirmed that the right of peoples to self-determination has that erga omnes character. In Chagos (2019), it held, against this specific coloniser, that the decolonisation of Mauritius had never been lawfully completed and that continued “British” administration of the archipelago was a continuing internationally wrongful act.

Most decisively, in its Advisory Opinion of 19 July 2024 on the Legal Consequences arising from the Policies and Practices of Israel in the Occupied Palestinian Territory, including East Jerusalem, the Court held for the first time in its history that the right to self-determination constitutes a peremptory norm of international law (jus cogens), from which no derogation is permitted. It identified the breach of that right and of the prohibition on the acquisition of territory by force, as obligations owed erga omnes; and it held that all states are under an obligation not to recognise as lawful the situation so created, not to render aid or assistance in maintaining it, and to cooperate with the United Nations in bringing it to an end. The Court framed the peremptory holding in the context of foreign occupation and it will be said that Scotland is not that (it is). But the second holding needs no such qualification. It’s the one that fits. The prohibition on acquiring territory by force is peremptory; prolonged administration converted into annexation produces an illegal situation which every state must refuse to recognise. Annexation is the Court's own category. Annexation procured by economic coercion, military intimidation and documented bribery is precisely what Professor Robert Black KC established of 1707.

All member states are obliged to cooperate with the United Nations in bringing that decolonisation to an end. The arbiter is then the international community while the colonial party holds no veto.

Paulo Freire, evoked later, put the principle in a form worth carrying throughout. To exist humanly is to name the world and to name the world is to begin changing it. The corollary, which he drew explicitly, is that a people prevented from naming its own condition is held in a state of prescribed silence, in which its situation appears to it not as a structure imposed by identifiable others but as the natural order of things, or as its own failure.

Hechter: The Half-Name

The contribution, stated fairly

Michael Hechter's Internal Colonialism: The Celtic Fringe in British National Development, 1536-1966, published in 1975, was the first work of rigorous comparative social science to treat Scotland, Wales and Ireland as a single analytical problem of core-periphery domination within a state. The achievement was real. This series uses his data throughout.

Hechter demonstrated quantitatively, across four centuries, that the peripheries of the Anglo-British state exhibited the characteristic features of colonial economies; specialisation in raw materials and cheap labour directed to the needs of the metropolitan core; investment capital concentrated at that core; industrial structures that were dependent, narrow and consequently fragile; persistent differentials in employment, income and life chances; and a core that remained diversified and insulated while the periphery absorbed every shock.

He supplied two concepts that remain indispensable. The cultural division of labour names the systematic allocation of occupational roles along cultural and linguistic lines. The dominant group's language becomes the passport to the professions and the administration while the subordinate group's speech marks its speakers for the lower rungs. Hechter observed that to be English-speaking within the periphery was to be culturally privileged. He drew the comparison himself to the neo-colonial cities of West Africa. The co-opted peripheral elite names the mechanism by which a native gentry secures its standing by shedding its own culture and language, deliberately maximising the distance between itself and the mass of its countrymen; Memmi's mimic elite, arrived at independently through British data.

He went further than his reputation now suggests. He wrote of the colonial incursion of England into the Celtic lands; arguing that where long-term differentials in development track ethnic stereotypes, the appropriate term is institutional racism. Liberation Scotland's compendium rightly quotes these passages.

And yet the name is wrong

The problem is the phrase under which all of it was filed, which fails at three levels.

The genealogy. "Internal colonialism" did not originate with Hechter or in “Britain”. Its lineage runs through Lenin on capitalist development in Russia and Gramsci on the Italian Mezzogiorno; through Harry Haywood's Negro Liberation (1948), which advanced the internal-colony thesis for Black America; through C. Wright Mills; and it was systematised in Latin America by Roberto Cardoso de Oliveira in Brazil and, decisively, by Pablo González Casanova and Rodolfo Stavenhagen. González Casanova advanced it in 1963, systematised it in La Democracia en México; completed in 1963, held from publication until 1965 by censorship; and gave it its canonical English statement in "Internal Colonialism and National Development" the same year. Stavenhagen developed it in parallel, notably in his "Seven Wrong Theses on Latin America" (1965).

What were those thinkers describing? González Casanova's subject was the newly independent post-colonial state; a country that had won formal sovereignty from a foreign empire, in which domination by the departed power had been replaced by domination exercised by domestic elites over indigenous peoples inside the same national territory. Internal colonialism named the persistence of colonial social relations after independence, conducted by a state over its own indigenous minorities. That’s what the term was built for, describing Mexico, Peru and Brazil with precision.

It does not describe Scotland. The mismatch is categorical rather than marginal. Scotland is not an indigenous minority inside a state that is itself a former colony. Scotland is a formerly sovereign European kingdom, internationally recognised for centuries, annexed by a neighbouring state through an instrument procured by economic coercion, military intimidation and documented bribery; void, as Professor Robert Black KC established before the United Nations in September 2025, from the outset. The colonial, dominating power is not a domestic elite of Scotland's own state; although there are colonial collaborators and traitors like in all colonies. It’s a foreign state that absorbed Scotland's. To apply to that situation a concept designed for indigenous peoples within post-colonial republics is to import a structure that does not fit and, in importing it, to concede that Scotland is a minority within a legitimate whole rather than an annexed nation within an illegitimate one.

Aníbal Quijano, whose concept of coloniality the first post of this trilogy deploys, saw the limitation from the other direction. Internal colonialism, he observed, addresses problems of coloniality that in fact run far beyond questions of nation and state. The term is too small for what it is asked to carry.

The adjective. "Internal" presupposes an interior while an interior presupposes a legitimate container. The word locates Scotland inside a lawful Anglo-British state and thereby smuggles the coloniser's principal constitutional claim into the analytical vocabulary before the analysis has begun. It performs a second injury as well by implying a domesticated, lesser, more metaphorical variety of the real colonialism practised overseas. Internal colonialism sounds like colonialism in inverted commas. There is no such thing.

The title. The Celtic Fringe in British National Development. Scotland appears as a fringe (an edge, a trim, a decorative margin) of a British national development whose existence as a nation is assumed rather than argued. A book advancing the colonial reading of Scotland's condition announces on its cover the two premises the colonial state most needs conceded; that there is a British nation and that Scotland is its periphery.

It should be recorded, in fairness, that Hechter did not remain fixed on the thesis. His later work moved substantially towards rational-choice explanations of ethnic solidarity. The 1999 reissue carries his own reconsiderations. This series treats Internal Colonialism as a body of evidence with excellent concepts, gratefully used, under a name that must go.

The correction: contiguous colonialism

In its place we propose a threefold vocabulary, set out in the opening post of the whole series and restated here because everything downstream depends on it.

Contiguous (or adjacent) colonialism denotes colonisation conducted across a shared land border. Scotland is the paradigm case. Proximate colonialism denotes colonisation across a narrow sea, near enough for continuous administration, settlement and reinforcement; Ireland, England's oldest colony and this series' senior comparator throughout. Oceanic colonialism denotes colonisation across open ocean.

Three things need saying at once. All three are colonialism, without qualification. These are not grades ranked from lesser to greater, nor degrees of suffering ranked from milder to worse. They name three geographies of delivery for one crime. The adjective marks only the road the coloniser travelled, saying nothing whatever about what was done on arrival.

Unlike "internal", none of the three concedes anything. Contiguity is a fact about a border. It carries no implication that two territories form a single legitimate polity, which is exactly the implication "internal" cannot avoid.

If the three differ in intensity at all, the relationship runs opposite to what the salt-water assumption predicts. Contiguity tightened the grip through institutional assimilation, with a garrison network resupplied overland, an administrative apparatus staffed across an open border, a settler stream requiring no ships, a shared linguistic interface through which assimilation could proceed at a speed no oceanic colony experienced, and a capacity for real-time narrative control and propaganda that distance denied the maritime, colonial empires. Proximity is not mitigation but often aggravation. It also explains why the colonisation has been so much harder for outside observers to see.

McVeigh: The Union Is Not the Container

The move

Robbie McVeigh, who has published on Ireland and racism across several decades, much of it with Bill Rolston, performs, in work Liberation Scotland's compendium draws on directly, a manoeuvre of considerable analytical violence; resolving everything Hechter left unresolved.

Hechter asked whether colonialism was occurring within the Anglo-British state. McVeigh asks what the Anglo-British state is. His answer is that the Union was not a neutral constitutional container within which colonial relations happened to develop, but was itself, from its inception, a racialised colonial construction; a settler-colonial formation which established English majoritarianism as the operative logic of the whole arrangement, which functioned not as an alternative to colonial empire but as the necessary condition for English colonialism and empire's consolidation. In that framework, Ireland is of course an English colony; and there’s no way Scotland isn’t too.

Once that is stated, Hechter's adjective collapses under its own weight. There is no interior to be internal to. The container is the thing under examination.

The race agenda

McVeigh's central finding, developed on the Irish material, is that the Union constituted a race agenda from the first; building an internal racialised hierarchy around language, race and religion, designed specifically to subalternise its subjects within the new state. Ireland was thereby locked inside a double-lock of union and empire, colonised twice over, once as a possession and once as a constituent, with the second lock disguised as membership. He insists on a point too easily passed over. For many colonised and subalternised people, race is not one dimension of experience among others but the modality through which life is lived.

The Scottish application follows without strain. The compendium makes it; the same race agenda, the same subalternisation through language, culture and generalised Scotophobia, the same double-lock. What was imposed on Ireland in 1801 had been imposed on Scotland in 1707. The ordering matters. The Irish Union was the second application of an instrument whose first full deployment had been against Scotland. Remember that the first phrase of the supposed Treaty of Union with Ireland says the “English parliament” not “Great Britain” first.

McVeigh's further observation reaches the heart of this series. The Union, he argues, was not constructed in the interests of the mass of the people it incorporated but was the mechanism that gave England's ruling elites the resources, the manpower and the fiscal-military base to expand and consolidate a colonial empire abroad. That’s precisely the argument advanced in the opening post of this whole series. The Anglo-British Empire was made from the annexation of Scotland, that 1707 constituted the colonial state rather than merely enlarging it; arriving from an entirely independent direction, through Irish sociology rather than Scottish constitutional history. When two arguments built from different evidence converge on the same conclusion, the convergence is itself a finding.

He draws the operative consequence, which is where this series is aimed; the Union is no more defensible than any other facet of English empire and colonialism. It too must be decolonised. With the United Nations now embarked on its Fourth International Decade for the Eradication of Colonialism, the time has come to situate the “United Kingdom” itself within that paradigm.

Why this reframes everything

The practical effect is to change the question a Scottish reader is being asked.

It’s not: is Scotland badly treated within the Union and would it do better outside? That question, which has organised Scottish constitutional debate for a generation, already concedes that the Union is a legitimate structure whose performance is under review. The question is: what is this structure, what was it built to do and to whom? The answer McVeigh supplies is that it was built as an instrument of racialised domination and imperial, colonial consolidation, that it did to Ireland and Scotland what colonial empires do and that its continuation is a colonial fact requiring a colonial remedy.

Baird: The Framework Built From Inside

The method and why it is Hechter's opposite

Alfred Baird's Doun-Hauden: The Socio-Political Determinants of Scottish Independence (2020), with his article in the Towson University Journal of International Affairs (2022), supplies the analytical spine of Liberation Scotland's entire evidentiary project. Its methodological orientation deserves as much attention as its findings.

Hechter's procedure was deductive. Take a concept developed elsewhere, apply it to British data, assess the fit. Baird's is inductive and grounded. The framework is built up from analysis of Scottish data on the question of independence. The postcolonial literature is brought in afterwards as illumination and confirmation rather than as an imported template. He describes the method himself as grounding out a theoretical framework from the data collected.

The difference is not merely procedural. It explains why Baird's framework carries no euphemism. A theory derived from the Scottish evidence outward has no reason to file that evidence under a borrowed adjective conceding the coloniser's premise since it never borrowed the adjective. This is what it means, in practice, for the colonised to write their own theory rather than be assessed against someone else's; the principle established in the first post of this trilogy, here executed at home.

The nine determinants

Baird identifies nine determinants of Scotland's condition. Because they organise so much of what follows in this series, they are worth walking through as a set. Together they constitute a complete map available of what is being done to Scotland.

Culture. Cultural imperialism and enforced assimilation, producing a hegemony in which the dominant culture is not Scotland's; the inferiorisation of native culture, the cringe, and what Baird identifies as a dislocated and clandestine culture; a national inheritance obstructed in its transmission.

Language. Linguistic imperialism and linguicide; the marginalisation and non-teaching of the indigenous languages; the deficit perspective applied to Scots speech; and, following the Sapir-Whorf tradition, the recognition that because language furnishes meaning, its subordination produces colonial alienation at the level of consciousness itself. This is the domain the previous post examined.

Demographics. The loss of between three and four million people since the colonial Union; proportionally the largest sustained out-migration in western Europe for a country of Scotland's size; inward movement dominated overwhelmingly by one country and concentrated in managerial and professional strata; a birth rate at record lows; and a population whose composition is managed in the interest of the administering power.

Colonialism. External control over language, political leadership, land and seas; the symbolic apparatus of one crown and one flag; an Anglophone elite producing colonial alienation and self-colonisation; the ethnic and cultural division of labour; and the recognition that independence is decolonisation, the only remedy the colonial condition admits.

Nationalism. The distinction, and this one repays slow reading, between the self-determination nationalism of a colonised people and the trans-national nationalism of the imposed Anglo-British identity, which is itself a form of force; and the observation that civic nationalism is only available after independence, since national citizenship cannot be conferred by a colony.

Institutions. Social institutions as the machinery of exclusion; ethnic discrimination running through them until racism becomes institutionalised; and the decisive constitutional point that where appointments and oaths bind institutional allegiance to an alien crown and to Westminster, the values that are sovereign in Scotland's institutions are the coloniser's values.

Constitution. The 1707 colonial Treaty procured by coercion and bribery; the Claim of Right and the sovereignty of the Scottish people ignored and thereby violated; the 2014 process conducted on an irregular franchise under external interference; and the demonstrated inability to withdraw, which confirms colonial status rather than voluntary partnership.

Ethnicity. The unequal distribution of power flowing from language oppression; the appropriated racial oppression and internalised racism extending to self-deprecation; and the recognition that a liberation movement rests on the solidarity of the oppressed group.

Self-determination. The refusal by the administering power to permit the exercise of an inalienable right; the criteria by which a people is defined in international law, which Scots plainly satisfy; Scotland's condition as a Non-Self-Governing Territory; and the need for United Nations oversight of a process the administering power has captured.

The title is the argument

Baird named the condition doun-hauden, held down. Not internal colonialism, not the national question, not the constitutional issue. A Scots compound, in the language that three centuries of statute, schooling and the punishment stick were deployed to eliminate.

Recall the arc of this trilogy. The first post established that the theory of colonialism was written by the colonised. The second established that the colonial state's deepest work was the destruction of a people's capacity to describe itself in its own tongue. Here, at the end, the framework that finally names Scotland's condition accurately does so in Scots. The naming and the language are one act of recovery. A people that can say doun-hauden about itself, in its own words, has already begun to stand up.

What South Asia Knows That Scotland Has Not Been Told

This series has travelled deliberately. The first post went from the francophone Caribbean and North Africa to the Latin American decolonial school. The second went from Said and Ngũgĩ to the Caribbean of Brathwaite and Glissant and the Oceania of Hau'ofa and Tuhiwai Smith. This one has to travel too. The destination completes the map.

Between 1982 and 2005 a series of volumes appeared under the title Subaltern Studies, inspired and led by Ranajit Guha, working on colonial South Asia. The word subaltern they took from Gramsci who used it to mean the subordinated groups whose history is not written because they do not control the institutions that write history. Their project was to recover the history of colonial India from below, from the archives of the colonised rather than the accounts of the administrators. In doing so they produced four instruments Scotland has never been handed.

Guha: the prose of counter-insurgency

Guha's essay "The Prose of Counter-Insurgency" (1983) established that the colonial archive does not record a subject people's resistance as politics but as crime.

Peasant insurgency in colonial India appears in the official record as disorder, as instability, as banditry, as fanaticism, as the work of criminal tribes or deluded enthusiasts stirred up by outside agitators. The rebels have no politics in that archive, written by the people they are rebelling against. A coloniser who conceded that the colonised had political grievances would be conceding the whole argument. Guha's decisive point is that a historian who reads those documents without allowing for their grammar does not describe the insurgency. He reproduces the coloniser's judgement as historical fact, in good faith, using proper method, in a reputable institution.

Now apply that to Scotland, where it has never been applied, and watch what happens to the standard vocabulary.

Wallace is a traitor in the English record, convicted at Westminster Hall in 1305 of betraying an allegiance he had never given. The Jacobites are rebels, which is a term that presupposes the legitimacy of the authority rebelled against. The men of the Radical War in 1820 are treasonable, tried under an English treason law imposed on Scotland in 1708 in breach of the Treaty's own guarantees; three were hanged and beheaded, nineteen transported. Highland resistance is lawlessness, barbarity, incivility, primitiveness; the vocabulary of the 1616 statute the previous post examined. In the present tense, Scottish self-determination is separatism, a word that presupposes the legitimacy of the thing being separated from; which appears in the leaked memorandum of the Secretary of State who introduced Scotland's fiscal accounting as an instrument against it.

That is one continuous grammar, running from 1305 to last year's newspapers. Scottish historiography has largely inherited it without audit. Guha's contribution is to make the inheritance visible. These are not neutral descriptions that happen to be unflattering. They are the categories of counter-insurgency. Using them settles the question of legitimacy before any evidence is examined.

Chatterjee: the derivative discourse

Partha Chatterjee's Nationalist Thought and the Colonial World: A Derivative Discourse? (1986) poses a question that Scotland's constitutional politics has spent fifty years not asking.

Chatterjee observed that anticolonial nationalism in India was caught in a trap. To be taken seriously by the coloniser it had to argue in the coloniser's categories (rationality, progress, viability, readiness for self-government). In accepting those categories, it accepted the framework within which the colonised could only ever be found wanting. A nationalism that argues its case in the terms set by the power it opposes is, in his phrase, a derivative discourse. It may be sincere and effective within limits; but it has conceded the ground on which the argument is fought.

Set that beside the shape of Scottish constitutional argument since the 1970s. The case has been made in projections of fiscal balance computed on a methodology designed as a weapon against it. In currency arrangements assessed by former officials of the coloniser's central bank. In defence postures measured against the coloniser's alliance commitments. In a referendum conducted under a franchise the administering power designed, on a question the administering power approved, at a time the administering power permitted, with the result treated as advisory by the party that lost nothing by it.

Every one of those is a derivative discourse. Chatterjee's point is not that the answers are wrong. It’s that a people arguing inside somebody else's categories has already lost the argument it believes it is winning, which is why the movement Liberation Scotland argues status, in international law, before an institution the coloniser does not control and presents Scotland’s colonial markers, placing the Scottish case in international comparison with other colonies and former colonies.

Ashis Nandy supplies what Chatterjee's argument leaves out, which is why the trap is so hard to leave. In The Intimate Enemy (1983), he distinguished two colonialisms. The first takes territory and revenue; ending when the flag comes down. The second colonises minds, installs the coloniser's scale of value inside the colonised and survives the departure of the colonisers indefinitely, given there is no longer anyone to depart. Nandy's sharpest point concerns the resistance that second colonialism permits. The colonised who sets out to prove himself strong, rational, viable and worthy on the coloniser's chosen ground has accepted the coloniser's measure of worth; and cannot win on it since the scale was calibrated against him.

That is the Scottish constitutional argument since the 1970s described in a sentence. Fifty years spent demonstrating fiscal competence, monetary orthodoxy and strategic reliability to an audience whose approval is the thing being sought. Every demonstration confirming, by its own eagerness, that the standard belongs to somebody else.

Spivak and the problem of being heard

Gayatri Chakravorty Spivak's "Can the Subaltern Speak?" (1988) essay doesn’t question whether subordinated people are capable of speech but whether, within the discursive arrangements the colonial and post-colonial order provides, their speech can register; whether there exists any position from which it can be heard as speech rather than processed as data, ventriloquised by sympathetic intellectuals, or dismissed.

Scotland's situation is a precise instance; an instructive one since it inverts the usual reading. Scotland has never been silent. The record set out across this series is one of continuous articulation; risings in 1708, 1715, 1719 and 1745; the Radical War of 1820; the Scottish Covenant of 1949, signed by around two million people in a country of five million and dismissed by the government of the day; three parliamentary majorities elected on mandates that produced nothing. Scotland has spoken constantly for three hundred years; and before its colonisation and annexation, it fought the most vicious colonial power on earth for centuries.

What has been missing is not the speech or the facts. It’s the forum, the platform; a place where the speech is heard as a claim of status rather than as a domestic grievance to be managed by the party it is against. That is the whole of Spivak's point translated into Scottish conditions. It explains why the movement's turn to the United Nations is not a change of tactics but a change of venue, which in Spivak's terms is the only change that matters.

Chakrabarty: the waiting room and the law that outlaws it

Now let’s look at the instrument this post exists to place in Scottish hands.

In Provincializing Europe (2000), Dipesh Chakrabarty anatomised the structure of historicism; the assumption, built into the modern social sciences, that history runs on a single track and that Europe went first; that everyone else is somewhere behind on the same line. (The Americans had their theory of “modernisation” applied during the Cold War.) The consequence for the colonised is what he called the imaginary waiting room of history. They are not told they may never govern themselves. They are told not yet. Not yet ready, not yet developed, not yet institutionally mature, not yet economically viable. The word is always yet. The effect of yet is that the waiting becomes the government.

Chakrabarty traced the device to its most “respectable” source; John Stuart Mill, who argued in the same breath for liberty as a universal principle and for the exclusion of Indians and Africans from self-rule until they had been civilised into readiness. The waiting room is not a vulgar prejudice. It’s a sophisticated liberal instrument; the more durable for it given it never says no.

Now hold that beside the vocabulary issued to Scotland. Too wee. Too poor. Not ready. No currency plan. No central bank. What about the deficit. What about the border. What about pensions. Come back when the questions are answered or come back when the new questions are answered. That’s the waiting room, furnished in Scottish tartan. It has held a nation in it for three centuries.

Here is what few appear to have noticed.

The waiting room is illegal. As we have regularly described, United Nations General Assembly Resolution 1514 (XV), the Declaration on the Granting of Independence to Colonial Countries and Peoples, adopted on 14 December 1960, provides at Article 3:

Inadequacy of political, economic, social or educational preparedness should never serve as a pretext for delaying independence.

There is a further turn here.

Look at Article 73 of the UN Charter itself, which defines the obligations of states administering dependent territories. It concerns territories whose peoples have not yet attained a full measure of self-government. Its second subsection requires administering powers to develop self-government according to the circumstances of each territory and its peoples and their varying stages of advancement.

Not yet. Stages of advancement. The waiting room is in the founding document and so is the ladder. The Charter was drafted in 1945 by an international community in which the colonial powers were still colonial powers, writing their grammar into the constitution of the new order. The colonised were not incapable, merely early; not refused, merely pending; arranged along a single line of advance whose far end somebody else had already reached.

Resolution 1514 is what happened when the colonised arrived in the General Assembly in numbers sufficient to amend the terms. Sponsored by forty-three Asian and African states, it was adopted on 14 December 1960 by eighty-nine votes to nil, with nine abstentions. The abstentions were the colonial powers, among them was, of course, the “United Kingdom” i.e. the English colonial state.

Read that against what has been said to Scotland ever since. The state administering Scotland declined to support the instrument prohibiting the readiness pretext and has deployed the readiness pretext against Scotland for the sixty-six years since.

Article 3 is a repair, carried out in 1960 by the formerly colonised, on a text their colonisers had written fifteen years earlier; closing the door the Charter left ajar. Which means that when Scotland is told it’s not ready, it’s not being met with an economic argument that might be answered with better figures. It’s being handed the 1945 language, past the 1960 prohibition, by the state that abstained on the prohibition

Read that against Chakrabarty and the fit is exact. Article 3 is a prohibition on historicism's not yet. It was written because every colonial power in history had used the readiness argument; the Dutch of Indonesia, the French of Algeria, the Portuguese of Angola and Mozambique, the English of India and Ghana and Kenya and every territory they ever relinquished. The international community, by 1960, had concluded that the argument was never made in good faith and never could be.

So, when the state administering Scotland argues that Scotland is too small/wee, too poor, or insufficiently prepared, it’s not making an economic argument that might be answered with better figures. The English colonial state is deploying, against a colonised people, precisely the pretext that the founding instrument of international decolonisation law names and forbids.

The irony completes itself when the comparison is made. Scotland possesses resources exceeding Norway's, institutions older than the state administering it, one of the most educated populations on earth, and a documented sovereign existence running back beyond the Declaration of Arbroath. It is more prepared for sovereignty than very nearly every one of the eighty-odd territories that have achieved independence under the United Nations framework since 1960. Yet, Scotland is the one still being asked to wait.

What Scotland returns

These are borrowings. The account should be settled.

Subaltern studies was built on a colonised people whose subordination the world had never doubted. Scotland offers the tradition its inverse. A case where the counter-insurgency grammar operated so successfully that the resistance it describes has been absorbed into the national self-image as rebellion by the descendants of the people who rose. Guha's Indian peasants were called criminals by their coloniser. Scotland's Jacobites are called rebels by Scots.

Chakrabarty's waiting room, developed to explain how Europe positioned everyone else in time, turns out to have been operating inside Europe, against a European nation, run by the European state most often held up as the model of constitutional propriety. (Well at least by its own propaganda apparatus.) The waiting room was never a device for managing the distant. It was built at home first, which is what this whole series has been arguing about every other instrument as well.

Freire: From Naming to Doing

The standpoint and a publication history that is itself the argument

Paulo Freire was born in Recife in 1921, in the impoverished Brazilian north-east. He made his life's work the literacy of adults whom the Brazilian state had left unable to read and, not coincidentally, since literacy was a condition of the franchise, unable to vote. He directed the Department of Cultural Extension at the University of Recife from 1961. After the military coup of 1964 he was jailed, then driven into an exile lasting fifteen years. Bolivia, Chile, a visiting year at Harvard, and a decade in Geneva advising the World Council of Churches, work that took him into the liberation struggles of Guinea-Bissau and Cape Verde and into collaboration with the movement Amílcar Cabral had built.

He wrote Pedagogia do Oprimido in Portuguese, in exile, in the late 1960s. It appeared first in Spanish, then in English in 1970. It reached Brazil, the country it was written about, in the language it was written in, for the people it was written for, only years later. The dictatorship would not permit it.

Sit with that. It’s not a biographical footnote. The book that taught the oppressed how to name their condition was itself withheld from the oppressed it was written for, by a state that understood exactly what would happen if they read it. The text about naming was un-named in its own country. There is no more complete demonstration of Freire's thesis than the publication history of the book advancing it.

The framework

The architecture is best read as a single movement rather than a set of terms. Each element produces the next.

It begins with a claim about schooling that turns out to be a claim about politics. Conventional education, Freire argued, treats the student as a receptacle into which the teacher deposits pre-formed knowledge; what he called the banking model. Its function is not to produce ignorance; the deposits may be perfectly accurate. Its function is domestication. It produces people who receive the world as given rather than as made. A people who cannot interrogate the world cannot change it. Against this he set problem-posing education, in which teacher and taught investigate reality together. The object of study is the students' own situation, which is to say, an education that begins where the learner actually stands rather than where the curriculum has decided he ought to be.

What such an education is for has a name, which is routinely misunderstood. Conscientização is usually rendered as critical consciousness and taken to mean a feeling; awareness, indignation, being awake. But it’s not a feeling. It represents a process with stages. It runs from experiencing one's condition as natural, inevitable or self-inflicted; to perceiving it as a structure produced by identifiable others acting in their own interest; to recognising that a structure produced by human action can be ended by human action and agency. Compressed into one line, conscientisation is the passage from my country is poor to my country is being extracted from. That passage is what Colonial Marker 0 exists to help accomplish. Everything in this trilogy has been an attempt to walk a reader across it.

But Freire refused to pretend the passage is welcome. This is where he becomes uncomfortable rather than merely useful. The oppressed, he observed, carry inside themselves an internalised image of the oppressor. Liberation is therefore frightening in a way outsiders consistently underestimate. It demands the ejection of something that has become part of the self; removing the shelter of a condition one has learned to inhabit and to survive. He called the resulting reluctance the fear of freedom. He warned of its sharpest consequence. The oppressed who have not undergone conscientisation tend, on obtaining power, to become sub-oppressors, reproducing the structure with themselves in the upper chair. Any liberation movement that treats this as somebody else's problem will discover that it has changed the personnel and left the machinery running. Scotland's own recent constitutional history is not short of illustrations.

From that fear Freire derived the mechanics of domination itself. The dominant maintain their position through four anti-dialogical instruments: conquest, divide and rule, manipulation, and cultural invasion. Against them he set four instruments of liberation: unity, cooperation, organisation, and cultural synthesis. The symmetry is not decorative. It constitutes a claim that domination and liberation operate on the same terrain and by opposed methods. A movement can be assessed by which of the eight it is actually practising.

That first quartet is worth setting directly against the record this series documents. Conquest is Marker 1 (Military Threat, Occupation, Subjugation) with the garrisons, the military roads, the suppression after 1746. Divide and rule is the hardening of a fluid society into loyal and rebel, Highland and Lowland, and every subsequent division of the Scottish polity against itself, including the one the previous post identified between the speakers of Scotland's two languages. Manipulation is Marker 5 (Colonial Exploitation); an accounting methodology introduced, in its own creator's leaked words, to make a powerful case against Scottish self-government, and a report on Scotland's oil wealth classified for thirty years because the truth in it was unaffordable. Cultural invasion is the whole of the previous post; the renaming, the survey, the syllabus, the stick.

Freire, in Brazil in the 1960s, named the four things that had been done to Scotland since 1707, in the order they were done.

Praxis and the turn

Everything in Freire rests finally on praxis; reflection and action upon the world in order to transform it, in which neither term can be sacrificed. Reflection without action he called verbalism; the endless analysis that changes nothing and comes, in time, to substitute for change. Action without reflection he called activism; motion without direction, which exhausts a movement and delivers it nowhere.

This is the sharpest instrument Freire hands a movement. It should be turned first on itself. A movement that has spent a generation analysing its condition without acting on it has fallen into verbalism. A movement that campaigns ceaselessly without an adequate analysis of what it is campaigning against has fallen into activism. Liberation Scotland's compendium reaches this judgement itself, following Fanon's account of the nationalist party that makes its accommodation with the colonial order and comes to prefer the management of a colonial administration to the risk of ending it; identifying in that failure the reason for the shift Scotland is now living through, from an independence movement operating inside the coloniser's constitutional framework to a liberation movement operating geopolitically and in international law.

That shift is not a change of tactics. In Freire's terms, it’s the arrival of praxis; analysis and action rejoined after a long period in which each was pursued without the other. In Chatterjee's terms, it’s the abandonment of a derivative discourse for one conducted in categories the colonised chose.

Freire adds a final, demanding requirement. The leadership of a liberation movement cannot act for the people. It must act with them, in continuous dialogue. A liberation handed down by a vanguard is not liberation but a change of proprietor. The people must be the authors of their own naming. Which is why a series like this one, or a compendium of markers, or a submission to a United Nations treaty body, is not an alternative to a popular movement but an instrument of one. Its purpose is not only to inform experts but to hand a nation the vocabulary of its own condition, and then get out of the way.

The Arc Complete

Colonial Marker 0 is now closed. Its shape can be seen whole.

In the first post, the founding theorists of colonialism, writing from Martinique, from Tunisia, from Algeria, and then from the Andes, described Scotland's condition with exactness, without ever naming Scotland because the state that colonised Scotland still substantially controlled the world's account of where colonialism happened.

In the second, that state's deepest work came into view; not the garrison but the un-naming. A nation rewritten as a compass bearing. One language declared by statute in 1616 to be a cause of a people's barbarity and ordered abolished. Another never banned at all, merely reclassified as error, and left to its speakers to suppress in themselves.

In this one, the naming has been done properly. Hechter's half-name retired, with the reasons set out in full. McVeigh's exposure of the colonial Union itself as the colonial instrument rather than the neutral container. Baird's nine determinants, built from the Scottish evidence outward and titled in Scots. The subaltern historians' account of how a colonised people's resistance is recorded as crime, how its nationalism becomes derivative and how its subordination is administered through an indefinite not yet that international law prohibited sixty-six years ago. Freire's demonstration that naming is not the preface to liberation but its opening move.

Which is why the colonial markers begin at zero. Everything that follows (the occupation, the clearances, the linguistic suppression, the administrative architecture, the extraction, the denial of self-determination, the marks left in the mind of a subjugated people) becomes legible only through the lens Colonial Marker 0 supplies. Without it, the evidence in Markers 1 through 7 reads as a catalogue of national misfortunes. With it, the same evidence reads as what it is; a structure, imposed by identifiable actors, in their interest and against Scotland's, over three centuries; and therefore endable.

A word remains about what is being claimed. Not the creation of a new state out of a colonial territory. Scotland was a sovereign kingdom with its own crown, its own parliament, its own law, its own church and its own languages of state for the better part of a thousand years before any of this began. What is claimed is state resumption; the recovery of a sovereignty suspended by an instrument void from the beginning, whose crown was never lawfully extinguished. Nor is the body that has sat in Edinburgh since 1999 that parliament restored as a devolved administration created by an Act of the Westminster parliament, holding only the competence that Act lends it, sitting beneath a provision expressly preserving Westminster's power to legislate for Scotland, and abolishable by the authority that made it. The old parliament has not been given back. Something else stands where it stood, wearing its name.

To exist humanly, Freire wrote, is to name the world. Scotland has now named its condition, in its own language, with the evidence attached, before the international community. What follows from a true naming is not a debate.

It’s a demand.

The next post in this series turns to Colonial Marker 1 focusing on Military Threat, Occupation, Subjugation.

Read Liberation Scotland's Colonial Markers documentation.

References

Baird, A. (2020). Doun-Hauden: The Socio-Political Determinants of Scottish Independence. Kindle Direct Publishing.

Baird, A. (2022). "The Socio-Political Determinants of Scottish Independence." Towson University Journal of International Affairs, 55(2).

Black, R. (2025). Presentation at the Liberation Scotland/IPLSA Conference, Palais des Nations, Geneva, 18 September 2025.

Cabral, A. (1973). Return to the Source: Selected Speeches of Amílcar Cabral. New York: Monthly Review Press.

Chakrabarty, D. (2000). Provincializing Europe: Postcolonial Thought and Historical Difference. Princeton: Princeton University Press. New edition, 2008.

Charter of the United Nations (1945), Chapter XI, Article 73.

Chatterjee, P. (1986). Nationalist Thought and the Colonial World: A Derivative Discourse? London: Zed Books.

Fanon, F. (1961). Les Damnés de la Terre. Paris: François Maspero. English edition: The Wretched of the Earth, trans. C. Farrington. New York: Grove Press, 1963.

Freire, P. Pedagogia do Oprimido. Written in exile, late 1960s. English edition: Pedagogy of the Oppressed, trans. M. Bergman Ramos. New York: Herder and Herder, 1970.

González Casanova, P. (1965). "Internal Colonialism and National Development." Studies in Comparative International Development, 1(4), pp. 27–37.

González Casanova, P. (1965). La Democracia en México. Mexico City: Ediciones Era.

Gramsci, A. (1926). Alcuni temi della quistione meridionale. English edition in The Modern Prince and Other Writings. New York: International Publishers, 1957.

Guha, R. (1983). "The Prose of Counter-Insurgency." In R. Guha (ed.), Subaltern Studies II. Delhi: Oxford University Press.

Guha, R. (1983). Elementary Aspects of Peasant Insurgency in Colonial India. Delhi: Oxford University Press.

Haywood, H. (1948). Negro Liberation. New York: International Publishers.

Hechter, M. (1975). Internal Colonialism: The Celtic Fringe in British National Development, 1536–1966. London: Routledge and Kegan Paul. Reissued with new introduction, New Brunswick: Transaction, 1999.

International Court of Justice (1971). Legal Consequences for States of the Continued Presence of South Africa in Namibia, Advisory Opinion. ICJ Reports 1971, p. 16.

International Court of Justice (1995). East Timor (Portugal v. Australia), Judgment. ICJ Reports 1995, p. 90.

International Court of Justice (2019). Legal Consequences of the Separation of the Chagos Archipelago from Mauritius in 1965, Advisory Opinion. ICJ Reports 2019, p. 95.

International Court of Justice (2024). Legal Consequences arising from the Policies and Practices of Israel in the Occupied Palestinian Territory, including East Jerusalem, Advisory Opinion of 19 July 2024.

Liberation Scotland Committee (2025). The Markers of a Colonized Nation: Scotland's Colonial Markers. Liberation Scotland.

McVeigh, R. [Mac an Bheatha, R.] (forthcoming). "'Dirty Work': Ireland, the Union, and the British 'Race Agenda'." In S. Papadakis, M. Tinsley and A. Meghji (eds), Postcolonial and Decolonial Transformations: Reimagining British Sociology. London: Routledge.

McVeigh, R. and Rolston, B. (2009). "Civilising the Irish." Race and Class, 51(1), pp. 2–28.

Memmi, A. (1957). Portrait du colonisé, précédé du Portrait du colonisateur. Paris: Buchet-Chastel. English edition: The Colonizer and the Colonized. Boston: Beacon Press, 1965/1967.

Mill, J.S. (1859). On Liberty. London: John W. Parker and Son.

Mill, J.S. (1861). Considerations on Representative Government. London: Parker, Son and Bourn.

Nandy, A. (1983). The Intimate Enemy: Loss and Recovery of Self Under Colonialism. Delhi: Oxford University Press.

Quijano, A. (2000). "Coloniality of Power, Eurocentrism, and Latin America." Nepantla: Views from South, 1(3), pp. 533–580.

Scotland Act 1998, c. 46 (UK).

Spivak, G.C. (1988). "Can the Subaltern Speak?" In C. Nelson and L. Grossberg (eds), Marxism and the Interpretation of Culture. Urbana: University of Illinois Press.

Stavenhagen, R. (1965). "Siete tesis equivocadas sobre América Latina." El Día, 25–26 June 1965.

UN General Assembly Resolution 1514 (XV) (1960). Declaration on the Granting of Independence to Colonial Countries and Peoples, 14 December 1960.