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Using a royal charter to regulate the press would set a "wonderful example to Putin and Mugabe and other dictators", MSPs have been told.

Lord McCluskey, who produced a report on press regulation in Scotland after the Leveson Inquiry, has given evidence to Holyrood's education committee.

He criticised the UK government's plans for an independent regulator via a royal charter.

He said this would "bypass" parliament and deny politicians "a voice".

Following the publication of the Leveson Report last year, the three largest parties at Westminster agreed to a royal charter, due to be approved by the Queen at a Privy Council meeting in May, which will establish a "recognition panel" to oversee press regulation.

In Scotland, First Minister Alex Salmond asked Lord McCluskey to chair an expert group set up to recommend press regulation reforms north of the border.

that a voluntary code was unlikely to work.

Pizza-filled rooms

Now Holyrood's education and culture committee is examining what the royal charter could mean in practice in Scotland.

Lord McCluskey, a former High Court judge, told the committee the Leveson Inquiry "never considered the merits or demerits" of using a royal charter.

He said: "The charter is a creature of this government. It is written by the Privy Council, by those three or four members of the Privy Council who are convened, and is signed by the Queen.

"A wonderful example to Putin and Mugabe and other dictators to say the way we regulate the press in the United Kingdom is we don't allow the democratically elected parliament to have a say, we do it with the Queen signing a document."

Lord McCluskey said a royal charter "does not go through parliament" and would also not be covered by a legislative consent motion in Scotland, meaning MSPs at Holyrood "would be denied a voice" on it.

He highlighted what he called the "very important question" of who should be covered by the charter.

He said: "That decision is one that ought to be taken by the elected parliament. That ought to be looked at by legislators, not decided in smoke-filled rooms, or pizza-filled rooms I think it is nowadays, of the Privy Council.

"I've already made the point that Putin and Mugabe must be rubbing their hands in glee with the idea that you can just issue a decree.

"What a terrible example for us to offer to the world: we bypass our legislature in all these matters and they are to be done by the unelected head of state."

The former solicitor general and senator of the College of Justice also told the committee he has had no contact Mr Salmond since his report was published.

When asked if he discussed his proposals with Mr Salmond, Lord McCluskey said: "No. I have to say he hasn't even written me a thank-you letter yet, but no doubt he will.

"But no, there's been no communication whatsoever with the Scottish government or the first minister."