WHEN Theresa May laid out her priorities for Brexit last month, the underlying message was that immigration policy would be prioritised over membership of the single market. Hard, soft, grey or red-white-and-blue, the Prime Minister’s Brexit would be about controlling the number of migrants into the UK.

Seen solely from the PM’s point of view, this approach makes some sense. Immigration was clearly a driver of many of the votes for Brexit. The issue is also still a running sore in the Tory party and any indication of going soft on it would cause trouble in the ranks.

However, the fact that the UK Government has prioritised immigration should not necessarily mean that the same controls have to apply across the whole of the UK. The Brexit ministers appear to have already ruled out a different approach for Scotland, but the Scottish Government and others have been making a convincing case for a differentiated approach after Brexit that would allow Scotland to set its own priorities and rules.

The latest to make the argument is the European Committee at Holyrood, which has said a bespoke solution for immigration policy in Scotland should be considered. Highlighting the thousands of EU migrants who work in hotels, restaurants, education and health, the committee said a drop in immigration would pose a greater problem for Scotland because of its ageing population. EU migration, says the committee, has helped reverse a decline in the Scottish population, particularly amongst people of working age and a hard Brexit runs the risk of driving a valuable group of European citizens out of Scotland.

It is a convincing case supported by several other factors. Scotland has a lower life expectancy than many other comparable countries, we have lower fertility rates and the population is growing at a slower rate than the UK as a whole. All of these factors strengthen the case for a special approach in Scotland.

There would be practical problems to consider of course, but as the committee points out there are models from elsewhere in the world that demonstrate how the process could work, with Canada and Quebec particularly instructive. The Canadian government is responsible for determining the total number of immigrants admitted, but the government of Quebec can set its own conditions for residence and has recently set out a policy that seeks to attract migrants with particular talents. In other words, different policies can work within one state.

There is nothing to prevent a similar approach working in the UK, with the Home Office possibly retaining overall control and the Scottish Government or even local councils setting their own priorities on immigration to meet their economic needs. The Prime Minister may have already dismissed a special deal out of hand, with talk of facing the future as one United Kingdom, but if any kind of consensus is to emerge on our exit from the EU, the UK Government will have to show that it is prepared to think much more openly and constructively. It must also accept a simple principle: Brexit does not have to mean the same thing in every part of the UK.