Revista Temas de Derecho Constitucional

317 I. INTRODUCTION Since 23 June 2016 the British people voted in a popular referendum to leave the Euro- pean Union, negotiations of the withdrawal agreement have attracted a great deal of academic discussion concerning the various options available to the United Kingdom (UK). 2 While the UK government embarked on the parliamentary debate, UK, Scottish and EU MPs lodged a judicial review to enquire about the possibility to revoke the noti- fication before the Court of Session in Scotland, in an unprecedented request (hereinaf- ter referred to as the Wightman case or Wightman ). 3 After some difficulties, the request made its way to the ECJ with a pronunciation on the unilateral nature of the Member State right to revoke the notification of withdrawal in a preliminary ruling issued in De- cember 2018. An upbeat mood quickly spread as this judicial decision was seen as a tangible possi- bility to stop Brexit by giving MPs another chance at the voting. Undoubtedly, political controversy surrounds the legal questions: while the ‘Brexiteers’ would fight to get the agreement re-negotiated, the ‘Remainers’ would appeal to the Government to call for a second referendum. Beyod the specific implications for Brexit, this preliminary ruling presents an interesting opportunity to reflect about the interface between EU law and international law. With this aim in mind, the article emphasises the aspects that bear significance for the relations between these two legal orders. Controversies aside, the main goal of the article consists in dissecting and analysing the legal aspects involved in the broader context of the interplay between international law and EU law. Precisely, the focus of the analysis is placed on these different relations between international law and EU Law looking beyond Brexit. The fulcrum of the argu- ments relates to the intricate relationships between these two legal systems. Particu- larly, the article details how these legal orders interact and speak to both international law and EU law scholarships. This article thus considers the ECJ preliminary ruling in Wightman from the perspective of the relationships and interactions between public international law and European Union law, pinpointing the peculiarities of the case and extracting the commonalities 2 Case C-621/18, Wightman v Secretary of State for Exiting the European Union, Judgment of 10 December 2019, available at http://curia.europa.eu/juris/document/document.jsf?text=&docid=208636&pageIndex=0 &doclang=EN&mode=lst&dir=&occ=first&part=1&cid=1188557 (accessed 5 January 2019). 3 Andy Wightman MSP and others v Secretary of State for Exiting the EU, available at http://www.scotcourts . gov.uk/docs/default-source/cos-general-docs/pdf-docs-for-opinions/2018csih62.pdf?sfvrsn= 0 (accessed 11 January 2019). UK Withdrawal from the European Union (Legal Continuity) (Scotland) Bill, available at https://www.parliament.scot/parliamentarybusiness/Bills/107725.aspx (accessed 11 January 2019).