What is the UK? Is it the same as Britain, Great Britain or England?
By Don Aitken
DISCLAIMER: This description is confined to legal and other factual
issues which seem to be capable of "correct" answers. It does not deal
with psychological questions about "Englishness", "Britishness" etc.,
nor with issues of race. The question of whether there is an English
or a British race (or both) and if so how this should be defined is
just not a sensible question.
Preliminary: States and Nations
The British Isles are divided between two countries which are
independent states in international law, namely 1) the United Kingdom
of Great Britain and Northern Ireland (so called since 1927) and 2)
the Republic of Ireland. Unlike the states of the USA or Germany, or
the provinces of Canada, the constituent parts of the UK (England,
Scotland, Wales and Northern Ireland) do not have legislatures with
their own areas of exclusive jurisdiction, and England has no
legislature at all.
It is not possible to have a federation without a constitution
prescribing the powers of the different levels of government, and the
UK has no such instrument. The primary principle of our constitutional
law is that the UK Parliament can do anything. The legislation which
created the Scottish Parliament and the Welsh and Northern Ireland
Assemblies carefully reserved power to the UK Parliament to legislate
in all matters. The powers of the subordinate legislatures are
devolved powers. So the UK is not a federation; it is a unitary
England, Wales, Scotland and Ireland have all been regarded for
centuries as nations, and are still correctly referred to as such.
This has nothing to do with legal status. England, Scotland and
Ireland all were once Kingdoms, but no longer are (since 1707 in the
case of England and Scotland, 1800 in the case of Ireland). Wales was
not a Kingdom but a Principality, and is sometimes still referred to
If, like me, you live in England, you are part of all of the following
entities (listed in order of increasing size):
There is surprisingly little to say about England, except that it
contains about 80% of the population of the UK and hence is
overwhelmingly dominant in relation to all UK-wide political issues.
It is an important administrative unit, and many UK government
departments (such as the Department of Health) have jurisdiction only
2. England and Wales
This unit, which doesn't even have its own name, is important because
it defines the jurisdiction of the English courts, usually just called
"the jurisdiction" in legal terminology. It is the area of application
of English law (which strictly should be called the law of England and
Wales, but rarely is). There is no such thing as British or United
Kingdom law, because there are no British or United Kingdom courts.
Many statutes apply to the whole of the UK, but courts in Scotland or
Northern Ireland may (and frequently do) interpret them differently
from the English courts. This is why the Lockerbie trial took place in
a Scottish court. Many administrative bodies have jurisdiction over
England and Wales. The rule that the word "England" in a statute
includes Wales was introduced by the Wales and Berwick Act 1746 and
abolished by the Welsh Language Act 1967.
3. Great Britain
This is a both a geographical term referring to the island on which
the greater parts of England, Wales and Scotland are situated, and a
legal one referring to those three territories considered together.
The name originates from the Latin 'Britannia', the 'Great' being introduced to distinguish it from Little Britain, which was the French province later called Bretagne, or Brittany. The island of Rockall, several hundred miles out in the Atlantic, is
legally part of Scotland, although actually closer to Ireland; the
British claim to the island is disputed by the Irish Republic. Some,
though not many, administrative bodies have jurisdiction over Great
Britain. Great Britain was a Kingdom from 1707 to 1800, but no longer
4. The United Kingdom
Great Britain and Northern Ireland together make up the United
Kingdom, hence the full name ("The United Kingdom of Great Britain and
Northern Ireland"). I suspect that the UK is probably the only country
in the world whose average inhabitant has no idea what its legal name
actually is. This defines the area represented in the UK Parliament
and for which that Parliament normally makes laws. It is also a
citizenship unit (although only since 1981). It does not define the
area for which the UK government is responsible in international law -
5. The United Kingdom and Islands
This includes a further three jurisdictions which have never been part
of England, Wales, Scotland or Ireland and are not part of the UK but
over which the Queen is sovereign and for which the UK government is
internationally responsible. They are the Isle of Man, in the Irish
Sea between England, Scotland and Ireland, and the Bailiwicks of
Guernsey and Jersey, which are the two parts of the Channel Islands,
off the coast of France, and were part of the Duchy of Normandy before
William I conquered England in 1066. Alderney and Sark are subordinate
parts of the Bailiwick of Guernsey. All of these territories have their own representative institutions and laws (offshore banking and stamps looming large as in many
small territories). They are British Possessions, but not colonies,
and their inhabitants, unlike those of colonies, are British citizens
(except for EU purposes).
6. The British Isles
Another geographical term referring to the whole group of islands
adjoining Great Britain, including Ireland. Politically it includes
the United Kingdom, the Republic of Ireland, and the Isle of Man.
Usage is not consistent as to whether the Channel Islands are included
- geographically they should not be, politically they should. Irish
people may detect political implications in this term, and it tends to
be avoided, although there is no obvious alternative. The term used in
connection with the Northern Irish peace process is just "the Isles",
which could be anywhere. One obvious alternative, "Great Britain and
Ireland", is also avoided because it used to be part of the title of
the British monarch (1801-1927). See next paragraph for "British
7. The Common Travel Area
This is the area from which people can enter UK ports without being
subject to routine immigration control. Same as the previous, but
includes the Channel Islands. The legal term "British Islands" meant
this area up to 1978, but now excludes the Republic (Interpretation
Act 1978) so means the same as 5 above (including the Channel
Islands). Immigration control has never been applied to Republic of
Ireland citizens, who are also entitled to vote if resident in the UK
and in general are not treated as aliens. The Irish Republic has
recently, as part of the peace process, extended the same treatment to
8. The European Territories of the United Kingdom
This means the United Kingdom and Islands, plus Gibraltar, which is a
British Colony with its own citizenship. Citizens of all parts of this
area are UK Nationals in European Union law.
9. The European Union
The UK and Republic of Ireland are among the 15 members of the EU,
which is an international organisation, not a state, although it has
its own law, which is directly applicable in all member states through
their own courts. Citizens of all of these states are EU citizens and
have the right to settle in any member state, and in the UK can vote
in local but not national elections. The Isle of Man and the Channel
Islands are not strictly part of the EU, their relationship with it
being governed by special ad hoc arrangements.
10. The United Kingdom and Colonies
This is the total area for which the UK government has international
responsibility. The remaining colonies (none of which has a population
of more than 70,000) are mainly in the Caribbean and Pacific. The full
title, rarely used, is "The United Kingdom, Islands, and Colonies".
The alternative term "British Empire" is no longer used, and 'colony' is falling out of favour and being replaced with 'dependent territory'. The extension of full British
citizenship to these territories is under way.
11. The Commonwealth
The Commonwealth (known until 1950 as the British Commonwealth, or the
British Commonwealth of Nations) is an international organisation
most, though not all, of whose members were once British colonies.
Most Commonwealth countries are republics, although some (such as
Canada) have Queen Elizabeth II as their head of state. She is also
Head of the Commonwealth, a role which involves no constitutional
functions. These positions are entirely separate from each other; no
other member of the Commonwealth is in any way subordinate to the
United Kingdom. Commonwealth countries are not "foreign"; their
citizens are not aliens in the UK, and can vote, although they are now
subject to the same immigration controls as aliens. The Republic of
Ireland is not a member of the Commonwealth, although it is also not a
"foreign" country (Ireland Act 1949).
"British" and "Britain"
Like the USA, the UK suffers from having no convenient adjective to
describe the country or its people. The best thing that can be said
for "British" is that it is not quite as misleading as "American", but
it is nevertheless the established term for "relating to the UK". So
"British citizen" is correct (though only since 1981 - see below).
This causes endless confusion and a fair amount of ill-will when
applied to the people of Northern Ireland. They are British citizens,
and so "British" in that sense (although they can also be citizens of
the Republic of Ireland if they wish, as many do). They are not from
Great Britain, so they are not "British" in that sense (i.e. as
distinct from Irish).
There is no satisfactory noun for "British person", either. "Briton"
is too formal, "Brit" too informal, and "Britisher" just foreign. All
are best avoided.
The term "British subject", in its original sense, is obsolete. It
used to mean anyone who owed allegiance to the British sovereign, and
therefore included citizens of independent Commonwealth countries as
well as the UK. The modern equivalent is "Commonwealth citizen".
"British subject" is now used as shorthand for a Commonwealth citizen
who is not a citizen of any country. Such a person, who would
otherwise be entirely stateless, is entitled to a passport issued by
the British government.
There was no separate UK citizenship until 1948, when the term
"citizen of the United Kingdom and Colonies" was used. Since 1981 it
has been "British citizen" (the first use of the term "British" in
this context). "UK national" is a technical term of EU law with a
slightly different meaning (see 8 above).
So what about "Britain"? This is not a term with any legal meaning,
but if you ask the English person in the street what country they live
in surveys show that more will answer "Britain" than anything else. So
it should probably be taken as a back-formation from "British", and
therefore to mean "United Kingdom".
Most people probably encounter foreign countries through their sports
teams more often than in any other way. We create even greater
confusion here, since practice varies between different sports. In
most older sports (e.g. rugby) there are teams representing the
historic nations of England, Wales, Scotland and Ireland. In others
(e.g. soccer) there are separate teams for Northern Ireland and the
Republic of Ireland. There may also be teams representing the whole of
the British Isles (rugby again). It is only in the Olympic Games,
where participation is strictly on the basis of nationality, and in
sports focussed on the Olympics, such as track and field athletics,
that a UK or "British" team is likely to feature. As a final
curiosity, our leading cricket team, although always called "England",
actually represents England and Wales. Scotland and Ireland have their
Historical and foreign usages
The correct and careful use of such terms as "United Kingdom" in any
context other than the strictly legal is a recent development, dating
from about the 1930s, when modern Scottish nationalism became a live
political issue. Anything written before that date, even by
historians, is likely to use "England". Disraeli famously signed the
1878 Treaty of Berlin as "Prime Minister of England", to the dismay of
his Foreign Office advisers. And A.J.P. Taylor, in the preface to his
volume of the "Oxford History of England", published in 1965, had to
point out that "when the Oxford History was launched a generation ago
'England' was still an all-embracing word. It meant indiscriminately
England and Wales, Great Britain, the United Kingdom, and even the
British Empire." As a result of this, the usual term in most foreign
languages has always been "England", and will probably continue to be
so for some time yet.