Having been involved on the periphery of a major criminal case which started off as a defamation case (there being no libel in Scotland) I can assure you that that is not the case. Scottish Defamation and English Libel are quite different laws. A number of people have made good money from arbitraging the difference.
I know there are a lot of differences (I'm English and live in Scotland), just my understanding of libel / defamation is that broadly the nature of rulings was similar - essentially that Scotland's system while slightly different wasn't that much better than the English system.
