Nevertheless, the Supreme Court in the Independence Referendum Bill Reference followed the 1998 decision of the 12 in holding that this Supreme Court of Canada in the Quebec Secession Reference gives rise to a right of external self-determination (i.e. to become independent) in only three sets of circumstances, none of which apply to Scotland: to colonies, to oppressed people, such as those living under foreign occupation, or to people denied 13 meaningful access to government.