Vic wrote:
>> Lets say this something I said here was a serious criminal offense in .de
>> - then FWIU The UK police could turn up on my door, drag me out of bed
>> and ship me off to the fatherland without seeing a UK beak.
>
> No. German law does not apply in the UK. We are a separate sovereign
> nation[1], with our own laws.
>
> Our laws require our legislators to fashion our legal system such that it
> does not contravene certain international agreements - but that is a world
> away from saying that a foreign nation has supremacy over our own laws.
>
>> I may have it wrong
>
> You do...
>
>> I may have to appear before a UK beak.
>
> If you have not committed a crime, you do not have to appear before
> anyone. I wrote some emails last night with a large G&T in my hand -
> that's an offence in many Middle-Eastern countries. Guess how many plods
> came knocking at my door this morning...
>
> The principle of extraterritoriality does apply in some situations - but
> that means that UK citizens are governed by some UK laws even when they
> are not in the UK. If Germany has similar laws (and I've no idea if they
> do or not), then *German* citizens would be subject to German laws whilst
> in the UK - but I am not a German citizen, so that does not apply.
>
>> BUt fast
>> track extradition was intended to be just that - one day in a UK police
>> cell next in a german one.
>
> Sure - so *if* you commit an offence against German law whilst under
> German jurisdiction, you could be extradited back to Germany to face the
> charges. But that is not even remotely similar to becoming subject to the
> laws of a foreign state. German law simply does not apply here;
> extradition is about returning people to the jurisdiction in which they
> allegedly committed an offence in order to be tried for that offence. It
> is not the unification of nation states.
Two recent cases you should consider before you decide how laws apply
across the EU.
1) Germany, forced Yahoo France to remove Nazi memorabilia for an
online auction/sale
2) David Irving, as UK citizen, was tried, prosecuted, and found guilty
of Holocaust Denial by a German court and served time an a German prison.
IANAL but I don't believe the that it is against UK law to trade in Nazi
memorabilia, and I don't believe that UK plc is considering prosecuting
David Irving for is views on the Holocaust.
ps: I do not condone the trade in Nazi memorabilia, nor am I in anyway a
support of the views expressed by David Irving.
>
> Vic.
>
>
> [1] Well, we are at the moment. Given the gay abandon with which
> transgressions by certain foreign powers have been accepted by our
> government over the last few years, I'm not sure we will always remain
> such :-(
>
>
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