The Aalands model

PRIME Minister Manmohan Singh's statement in both Houses of Parliament on December 21 defines India's policy on Kashmir in clearest terms: "While we are willing to look at various options, we would not agree to any redrawing of boundaries or another partition." He is fully aware of the importance of a settlement of the dispute with Pakistan: "This is stopping us realising our potential," he told Jonathan Power even before his Cabinet was sworn in.

The correspondent seized on the remark to probe further: "I pushed him on how far he himself would accept compromise with Pakistan over Kashmir. `Short of secession, short of re-drawing boundaries, the Indian establishment can live with anything'," (The Statesman, May 20, 2004). This fundamental, which he has reiterated since, represents the national consensus. Opinion will divide on the details when it is given concrete shape. It does not rule out, for instance, redrawing the Line of Control (LoC), drawn arbitrarily after armed conflict, by mutual agreement for sound political and military reasons. Obviously, that alone cannot suffice to ensure accord. A lot more will be required on India's part as well on Pakistan's.

President Pervez Musharraf declared in London on December 7 that "15 different options on Kashmir can be discussed and Pakistan is ready to open more land routes in Kashmir" (The Nation, December 8, 2004). But does any of the 15 meet the Prime Minister's criteria? More, does the President accept the parameters that the criteria set?

The onus is not on him alone. The Prime Minister himself told Power: "We have an obligation to ourselves to solve this problem." Musharraf has all but abandoned plebiscite and the United Nations' resolutions on it. In reciprocity, has India evolved any new creative proposal that it can fairly expect Pakistan to accept? If not, there is no difference between Manmohan Singh's criteria and Jawaharlal Nehru's note of August 25, 1952, in which he candidly told Sheikh Abdullah, in private, that repeated public pledges of plebiscite notwithstanding, he would offer no more than the status quo and that Pakistan was militarily too weak to challenge it.

Is there, indeed, no "room in the joints" of the Prime Minister's fundamental criteria which allow space for Pakistan's concerns? This is something that can be found only by the top leaders in quiet exploratory talks without any publicity whatever, and without aides. Once they begin to edge closer to each other, they will be able to evolve the rough outlines of an accord. Only if these are clearly understood between them should aides be asked to fill in the details. The deadlock that persists today can be broken only at the summit. To accomplish that, it is necessary for the top leadership to establish a relationship based on trust, shun publicity and make their meetings a matter of routine, as it existed in 1947-48. There need be no great excitement and, with it, high expectations when leaders of two close neighbouring states meet.

Kashmiri self-assertion on both sides of the LoC, in the last decade, is a heartening development. Their leaders as well as intellectuals should be allowed to meet freely to discuss new creative approaches.

In the past, thoughtful Indians proposed solutions. B. Shiva Rao suggested Kashmir's reunification and independence (The Hindu, May 29, 1963). Sir Mirza Ismail suggested in his memoir My Public Life (1964) that the Valley could be made "a compact autonomous State; self-governing in its internal affairs but having no responsibility for foreign policy or defence, as it would have no direct relations with any power outside the subcontinent" (page 131).

Of late, interest has centred on foreign models. The writer has discussed in Frontline four such models - "Irish lessons for Kashmir" (April 11, 2003); the Saar and Trieste in "Nehru and the Cold Wars" (February 27, 2004); and "The South Tyrol model" (December 17, 2004). Of them all, the Aaland Islands accord between Sweden and Finland in 1921 is the most apposite in the instruction it imparts for a solution to the Kashmir dispute. Like South Tyrol, it meets the Prime Minister's criteria. Finland's sovereignty over the overwhelmingly Swedish Aaland Islands was confirmed; but, subject to its grant of autonomy to the Aalands, both, constitutionally and with international guarantees to Sweden and to the League of Nations, the U.N.'s predecessor. Unlike South Tyrol, the Aaland Islands were demilitarised and neutralised. The principle of self-determination was adapted to meet the interests of both states as well as the aspirations of the people of the disputed territory.

In 1986, Sweden's Foreign Minister Sten Andersson visited the islands and remarked that they appeared to him to be more Swedish than Sweden itself. They have a "provincial citizenship" rather like Part III of the Constitution of Jammu and Kashmir on "permanent residents" who alone can hold land in Kashmir. In 1953, the Aalands acquired the right to fly their own flag; since 1984, to issue stamps bearing the sole word "{rsqb}land". From 1993 the word appeared in passports issued in the territory. Television and radio are matters assigned to it. Confident of its sovereignty, Finland has been increasingly liberal in its treatment of the province.

The Aaland Islands are located in the northern Baltic Sea, at the entrance of the Gulf of Bothnia between the Finnish and Swedish mainlands. In consequence of the Ice Age 10,000 years ago, some 6,500 islands and skerries continue to expand slowly as they gradually rise out of the sea.

The main island, the "Aland mainland", is surrounded by "the archipelago". The combined land and sea area of Aaland totals 6,784 sq km. Almost 80 per cent of the area consists of water, while the remaining 1,550 sq km consists of islands and skerries, of which about 80 are inhabited throughout the year.

There are at present about 25,000 inhabitants in the Aaland Islands. Nearly 95 per cent of them speak Swedish as their mother tongue; the rest speak Finnish and other languages. The only town, Mariehamn, has 10,000 inhabitants and is located on the Aaland mainland.

Since 1921 the Aaland zone has been delineated by a system of coordinates enumerated in a convention of 1921 on the demilitarisation and neutralisation of the Aaland Islands. An international strait, South Quarken, between the Aaland Islands and Sweden forms the passageway between the Baltic Sea proper and the Gulf of Bothnia. The shipping route passes through Swedish territorial waters between two small islets: Understen, on the Swedish side, and Marketrock, which is divided between the Aalands (Finland) and Sweden. Like Kashmir the islands are of strategic importance to both its neighbours.

It is a remarkable success story. On March 15, 2001, the governments of Finland and the Provincial government of the Aalands jointly organised a seminar at the United Nations headquarters in New York to discuss "the applicability of the Aaland case to other conflict situations throughout the world". Its report is published under an apt title: "Autonomy - an alternative to secession". A former President of Finland and famous international statesman Martti Ahtissari noted that the autonomy goes beyond linguistic or cultural matters, sets up a real and effective provincial government that has a say in all important matters affecting the islands and ensures real self-government. Martti Koskenniemi, Professor in International Law at the University of Helsinki, said that "the Aaland regime consists of three elements" - Finnish sovereignty, autonomy of the Aalands and their demilitarisation and neutralisation. However, he pointed out "Finnish sovereignty was given international recognition in exchange for an internationally guaranteed autonomy and preservation of the islands' Swedish character".

These are, also, the minimum requirements of a Kashmir solution acceptable to its people, to India and Pakistan, and, indeed, to world opinion. Those "international guarantees" can, surely, be grafted on the Prime Minister's precondition - no secession. They do not affect India's sovereignty, only the hubris of some in New Delhi. As Koskenniemi said "the permanent lesson here of the settlement is about the need for imagination and rejection of dogmatism in conceiving solutions for self-determination disputes".

Gunnar Jansson, who represented the Aalands in Finland's Parliament, recalled that for 600 years they had been "subjected to the rule of external powers. The outsiders decided what was best for the Aalanders". Until 1809, Sweden wielded sovereignty over Finland and Aaland, which for administrative purposes was part of Finland. Now "the Aalanders in general are satisfied with their Islands... . Today they are proud of being Aalanders, living in an autonomous region in Finland... it is with a sense of pride that Aalanders call their Islands `The Island of Peace'".

How did this come about? From 1157 to 1809 the Aalands were under Swedish control. From at least 1634 to 1809 they were governed by Sweden as part of the Finnish provinces of Abo and Bjorneborg. In 1808 Russia attacked Sweden. During the negotiations, it demanded Finland as well as the Aalands. The Russian emissary Roumiantzoff told Sweden's representative "to keep Finland without the Aaland Islands was the same thing as taking a safe of which one had thrown away the keys." By the Peace Treaty, signed at Fredrikshamn on September 17, 1809, Sweden ceded to Russia Finland as well as the Aalands. Russia governed them as part of an autonomous Grand Duchy of Finland until 1917. It imposed sheer despotic rule.

The Russian Revolution of March 1917 put an end to it. On November 7, 1917, came the Bolshevik Revolution. On November 15, the Soviet government published a Declaration on the right of foreign peoples to self-determination. Events moved at a breathless pace in those revolutionary times. Finland's Senate declared the country an independent Republic on December 6. The Soviet regime promptly recognised it on January 2, 1918.

Aalanders did not watch these events as passive spectators. On August 20, 1917, representatives of all the districts of Aland held a secret meeting at the Aland Folk High School at Finstrom where they decided to work for a reunion of Aland with Sweden. The wish was conveyed to the King and Government of Sweden by four elected Aland representatives by a petition signed by 96 per cent of Alanders of legally competent age. They also elected an unofficial legislature in 1918, to pursue the goal of reunion with Sweden.

It was an impressive demonstration of the popular will. In all 7,135 persons signed the address between December 20-25, 1917, which was presented to the King of Sweden on February 3, 1918. In June 1919 in an unofficial plebiscite around 95 per cent of the people voted for unification with Sweden. Finland pin-pointed procedural flaws in both the exercises, but the nature of the popular verdict was unmistakable. Aalanders appealed to the U.S., Britain and France; sent a delegation to the Peace Conference at Versailles; and to the League of Nations in July 1920. They set up a legislature "the Landsting", comprising delegates from the municipal councils.

After unsuccessful exploratory soundings, Sweden formally took up the matter with Finland in November 1918, asking for a plebiscite. It received a snub in June 1919. Finland made two moves thereafter, one, adroit, the other, clumsy. Its Parliament enacted, on May 6, 1920, an Autonomy Law for the Aalands to fortify its case before world opinion. Prime Minister Rafael Erich, with two colleagues, went to the Aalands' capital, Mariehamn, to explain the law and persuade delegates of the communes to accept it. Their leader Julius Sundblom replied, on behalf of the Landsting, that they would not renounce their demand for a plebiscite. It was an angry encounter. On the following day, June 5, 1920, Sundblom and the President of the Landsting, Carl Bjorkman, were arrested for high treason and taken to Abo in Finland. They had been to Sweden earlier to seek its support. The arrests served only to enhance the standing of the Sheikh Abdullah and Mirza Afzal Beg of the Aalands.

The dispute, however, soon acquired a new shape and format that facilitated its solution. A fortnight later, on June 12, 1920, the acting British Foreign Secretary Lord Curzon, wrote to Sir Eric Drummond, the Secretary-General of the League of Nations "in exercise of the friendly right conferred by Article XI of the Covenant of the League of Nations to bring to the attention of the Council of the League the case of the Aaland Islands, as a matter affecting international relations which unfortunately threatens to disturb the good understanding between nations upon which peace depends." He had informed the Governments of Sweden and Finland of his intention to move the League. The Council had nine members; the Five Great Powers and four others elected by the Assembly as non-permanent members.

Does it not occur to those who pillory Jawaharlal Nehru for taking the Kashmir issue to the U.N. that Britain might well have made a similar "friendly" move in 1947 in order to avert a war between India and Pakistan? Its nationals served in high military and civilian positions in both countries that were members of the Commonwealth, besides and what if Pakistan had pipped India to the post? India's initiative made it a complainant; Pakistan would have made it a defendant.

Mountbatten mooted the idea to both, Nehru and Liaquat Ali Khan on December 8, 1947; doubtless, with London's backing. His proposal was to ask the U.N. "to send out observers or advisers" to help "solve the impasse" over a draft agreement which V.P. Menon and Mohammed Ali had drawn up. Why not "a joint approach to UNO"? he asked. Liaquat agreed. Nehru rejected it "entirely". He "asked under what section (sic.) of the Charter any reference to UNO could be made." The U.N. could come in only after the raiders were driven out, he said. By December 22, Nehru had decided to refer to the U.N. Pakistan's complicity in the tribesmen's raid into Kashmir. But the appeal was made, not under Chapter VII of the U.N. Charter ("acts of aggression") but under Chapter VI ("pacific settlement of disputes"). It was done deliberately.

The draft was thoroughly vetted by M.C. Setalvad, one of the foremost lawyers in India, Nehru's letter to him, on December 20, itself predicted that the Security Council might appoint a commission, which it did. Setalvad explicitly warned Nehru and others that "the whole scheme of the Charter was that the Security Council should try and bring about a solution of the disputes between nations by mediation and other measures" (My Life; page 134). Mountbatten feared that if Uri fell to the raiders, they would move towards Baramula and Srinagar, driving Nehru to attack West Punjab. It was a stark choice between the U.N.'s mediation and an all-out war. India opted for the former, consciously. If war had broken out, mediation would have followed under duress.

TO resume the Aalands story, the council of the League of Nations met in the glittering St. James Palace in London on July 9, 1920. Present were representatives of Britain, France, Italy and Japan - the permanent ones (the United States having opted out of the League) - Belgium, Brazil, Greece and Spain. Finland was represented by Enckall; Sweden by Branting. The latter began by tracing the history of the islands and concluded by urging that they be conceded "the right of self-determination".

Enckall countered by arguing that there was "no war or threat of war" to warrant the Council's intervention and it was, in any case, barred from doing so because the "dispute arises out of a matter which by international law is solely within the domestic jurisdiction" of Finland. The Aalands' Representative also submitted a statement to the Council. He pleaded for a plebiscite on "the question of joining Sweden to formulate "the conclusion", it wished the council to adopt. Branting responded thus: "The inhabitants of the Aaland islands shall be permitted to decide immediately by plebiscite whether the Aaland archipelago shall remain under Finnish sovereignty or be reunited with the Swedish Kingdom?"

On July 12, Balfour read a Declaration on behalf of the Council, which both sides accepted. Before trying to settle the dispute, the preliminary issue of domestic jurisdiction must be settled. Since the Permanent Court of International Justice had not yet been established at The Hague to give its advisory opinion, the Council sought an opinion from a Commission of three international jurists. It resolved unanimously, with the consent of both parties, to seek an advisory opinion from the jurists on two questions - on the domestic jurisdiction and on "the present state of the international obligations regarding the demilitarisation of the Aaland Islands".

The President appointed three jurists - F. Laurande of France; Max Huber of Switzerland; and A. Struycken... of the Netherlands. The Commission of Jurists submitted its report on September 5, 1920, after hearing all the three parties. It held that the right to self-determination was not inscribed in the Covenant of the League nor was it a rule of international law. Cession of territory was a sovereign right in the state's discretion. Others cannot demand it.

In this, the Aalands case differed fundamentally from Kashmir's. India had pledged itself to hold a plebiscite, on October 31, 1947, "not only to your (Pakistan's) government, but also to the people of Kashmir and to the world". The pledge was incorporated in two resolutions of the U.N. Commission for India and Pakistan, dated August 13, 1948, and January 5, 1949. Both countries accepted them, Krishna Menon correctly characterised them, in the U.N. Security Council on February 8, 1957, as India's "international engagements... we have entered into."

It is on the basis of these engagements that the Constituent Assembly adopted Article 370 of the Constitution of India on October 17, 1949. Its mover, Sir N. Gopalaswamy Ayyangar, explicitly referred to "the Kashmir problem" before the U.N. and to India's commitment "that an opportunity would be given to the people of the State to decide for themselves whether they will remain with the Republic or wish to go out of it. We are also committed to ascertaining this will of the people by means of a plebiscite" (Constituent Assembly Debates; Volume 10; page 424).

Article 370 is based on this pledge and provides in clause (3) for its own extinction ("cease to be operative") and thereby severance of the link between the State and the Union if the plebiscite's verdict went against India. That was the only way Kashmir could have constitutionally seceded from India. Plebiscite was official Indian policy from 1947 to 1954. It was part of the process of the partition of the subcontinent in 1947. It is another matter that by mid-1948 Nehru had privately resolved not to hold a plebiscite and in 1965 Pakistan disentitled itself from demanding it by launching a war in Kashmir. Pakistan cannot get by plebiscite or on the conference table what it failed to get at its own chosen forum, the battlefield.

It is necessary to point out all this to demonstrate the falsity... of the familiar Indian argument that a part of the nation (Kashmir) cannot claim self-determination. To repeat, plebiscite in Kashmir was official Indian Policy from 1947-54. Finland never made any such pledge in respect of the Aalands. Its neighbour demanded a plebiscite, in what in law was Finnish territory, on grounds of ethnic and linguistic affinity. The world community was alive to the consequence if this principle was accepted in respect of minorities occupying a compact area adjoining another state with which they had affinities, linguistic, ethnic or religious.

The Jurists' Report noted that the people of Finland and of the Aalands had "totally different aspirations", though they acted in unison in their separation from Russia. The dispute arose out of a certain situation at the end of the First World War "and finds its source in the separatist demonstrations of the people invoking the principle of self-determination". It, therefore, did not relate to a matter, which, in international law, came exclusively within Finland's domestic jurisdiction. An important principle was laid down - an international dispute of this kind did not become a domestic matter because secession was ruled out. It had to be settled by an international agreement. It cannot be settled unilaterally.

On the second issue, the Report recalled the convention, which Britain, France and Russia signed in Paris on March 30, 1856, declaring that "no military or naval establishment will be maintained nor set up on the Islands". It was annexed to the Peace Treaty signed after the Crimean War. It remained valid despite its breaches during the First World War.

The report, thus, put the ball back in the Council's court. Its jurisdiction upheld, the Council decided, on September 20, 1920, to set up a Commission of Rapporteurs "to recommend the solution which it considered the most equitable and most appropriate to the question". They were Felix Calonder, Bn. Beyens and Abram J. Elkus. Their report, submitted on April 16, 1921, is a masterly document, even if some of its formulations are wrong. It carefully traced the history of the islands and closely analysed the issues involved. The report charted the path that led to a settlement eventually.

The Rapporteurs agreed with the jurists on the issue of domestic jurisdiction as also on the Aalanders' manifest desire for union with Sweden. But they had been part of Finland and could not claim secession, as Finland did for itself. "There is another consideration which excludes the analogy which it is wished, to establish between the Finnish people and the Aaland population. Finland has been oppressed and persecuted; her tenderest feelings have been wounded by the disloyal and brutal conduct of Russia. The Aalanders have neither been persecuted nor oppressed by Finland... the separation of a minority from the state of which it forms a part and its incorporation in another state can only be considered as an altogether exceptional solution, a last resort when the State lacks either the will or the power to enact and apply just guarantees.

"In the case of the Aalanders, the important question is the protection of their language - the Swedish language. Its language is the very soul of a people... if it were true that incorporation with Sweden was the only means of preserving its Swedish language for Aaland we would not have hesitated to consider this solution. But such is not the case."

The alternative to secession was cast-iron guarantees of autonomy. Consider how strong India's case would have been today if Nehru had not imprisoned Sheikh Abdullah in 1953, lauded rigged elections in the State (1951, 1957 and 1962), and initiated the erosion of Article 370? It has been reduced to a shambles beyond repair. Devised to guarantee autonomy, it has been abused to destroy it.

The Rapporteurs had no problem in dismissing the option of independence. "But does the Aaland Archipelago possess the necessary capacity to survive as an independent state?" Also rejected was that of plebiscite after five years. They honed in on Finland's Autonomy Law for Aaland, enacted on May 7, 1920. It should, they suggested, go further and add guarantees for "property in the hands of the natives;" against franchise for new immigrants, and "the nomination of a Governor who has the entire confidence of the population." This last is of crucial importance.

The Constitution of Jammu and Kashmir provided for a Sadre Riyasat elected by the State Assembly. In April 1965 the office was abolished and replaced by a Governor appointed by the President. A former Chief Minister Mir Qasim told Greater Kashmir (August 16, 1999): "I personally regret that the post of Sadre Riyasat was abolished." Little did New Delhi realise that the more it tried to "integrate" Kashmir with India the more it alienated its people.

The Rapporteurs proposed additional guarantees. They described the advantages of guaranteed autonomy for Finland's own stability and for the peace of the region. They warned: "However, in the event that Finland... refused to grant the Aaland population the guarantees which we have just detailed, there would be another possible solution, and it is exactly the one which we wish to eliminate. The interest of the Aalanders, the interest of a durable peace in the Baltic would then force us to advice the separation of the islands from Finland, based on the wishes of the inhabitants which would be freely expressed by means of a plebiscite."

They asked the Council to recommend to Finland amendments to its Autonomy Law on the lines they spelt out - "a legal force to the new guarantees granted to Aaland which would thus assume an international character... the Finnish government, too, ought to grant the General Council of Aaland the right of direct recourse to this council [of the League of Nations] for its good offices. Alternatively, "this right might be reserved to Sweden or to each of the three Scandinavian states". The South Tyrol accord conferred on Austria the right to move the World Court if Italy violated its guarantees to the region. The Rapporteurs also proposed "recourse to the International Court of Justice" in the last resort.

They suggested replacement of the 1856 Convention by another that ensured the neutralisation as well the demilitarisation of the Aalands. Finland had no objection. A Convention was signed in Geneva on October 20, 1921, to ensure these two objectives.

Meanwhile, the League's Council met on June 24, 1921, to consider the Report of the Commission of Rapporteurs. Sweden's delegate was asked whether he was prepared to negotiate with Finland guarantees for Aaland as proposed by the Rapporteurs. He agreed to do so "while retaining very serious doubts" on their effectiveness. So did Finland's delegate. Belgium's Paul Hymans a member of the Council was nominated to assist them. The meeting adjourned till the evening when Britain's Herbert Fisher read out a draft resolution. It confirmed Finland's sovereignty over the Aalands but insisted on "further guarantees" and their neutralisation and non-fortification. Sweden and Finland were to negotiate the guarantees; Sweden demurred but accepted the binding force of the Council's resolution.

Negotiations began the next day and proved successful. The minutes of the meeting of the Council on June 27, 1921, are of crucial importance. In later years Swedish as well as Finnish officials as well as jurists took varying positions on whether it was a pact between two states or the Council's decision. The minutes record irrefutably an international agreement on which the council put the imprimatur of its endorsement: "The text containing the agreement which had been reached by the two parties was then read." It contained guarantees more elaborate than in the draft of June 24. Finland undertook to incorporate them in its Autonomy Law.

Para 7 of the Accord read thus: "The Council of the League of Nations shall watch over the application of these guarantees. Finland shall forward to the Council of the League of Nations, with its observations, any petitions or claims of the Landsting of Aaland in connection with the application of the guarantees in question, and the Council shall, in any case where the question is of a juridical character, consult the Permanent Court of International Justice." The minutes record: "The Council unanimously approved the terms of this agreement, and decided that it be annexed to its resolution of June 24th."

Finland enacted the Guarantees Act of 1922, which incorporated the agreed guarantees. In 1951 it replaced the 1920 law with a more liberal Autonomy Act followed by another Act of 1991, which further widened the islands' autonomy. It went into force on January 1, 1993. It cannot be amended or repealed without the consent of the Province's Legislative Assembly (Article 69).

In 1970 Aaland joined the Nordic Council. Finland's Act of Accession to the European Union, dated December 9, 1994, has a protocol on Aaland "taking into account the special status that the Aaland Islands enjoy under international law". Finland's declaration reaffirmed the League Council's Resolutions of June 24-27, 1921. "Aaland joined Finland's membership" of the European Union. Articles 75 and 120 of the new Constitution of Finland (2000) entrench Aaland's Autonomy Law. Its people thus enjoy constitutional as well as international guarantees.

History teaches by analogy, not identity. No two cases are alike. But, Saar, Trieste, Northern Ireland, South Tyrol and Aaland provide considerable guidance on, both, the process of conciliation as well as its end product. In all, two States were the main negotiators. In the last three, the peoples' representatives acquired a voice; but only when the states had embarked on serious negotiations and outlines of an accord were discernible. It is unrealistic of Kashmiri leaders to demand a seat on the table now when the main hurdle is yet to be overcome - recognition of Kashmir as a State whose future is yet to be determined.

This precludes neither their parleys with the Centre nor India-Pakistan talks. In the end all three will have to agree on the terms of settlement. Representatives of Irish parties came to the table only after London and Dublin had agreed on the outlines of an accord.

Neither Pakistan nor Kashmir will acquiesce in the status quo; no matter how embroidered. International guarantees on the state's autonomy are indispensable, giving each state, India and Pakistan, a locus standi to ensure preservation of autonomy in the other's half. The issue of sovereignty resolved by a new international boundary, the two halves of the state can become one, effectively. Over time, they might build intra-Kashmiri links and institutions as in divided Ireland.

In the final analysis, as in South Tyrol and the Aalands, international guarantees of autonomy by agreement with Pakistan and Kashmiris are the only "alternative to secession". Repression and suppression have been tried. They have failed. India not only refused to hold the plebiscite it had promised but also wiped out the autonomy it had guaranteed. It now proposes in settlement a status quo based on force. Only a settlement of the dispute will invest this status quo with legitimacy. Such a settlement is achievable with Pakistan as well as the Kashmiris. It will not violate Manmohan Singh's criteria. It involves no secession; only creativity and a sense of justice and fair play. The Aalands solution shows how that can be accomplished. Therein lies its great merit.