A number of states in their submissions before the International Court of Justice in the Advisory Opinion case concerning the legality of Kosovo's Declaration of Independence (DoI) asserted that Kosovo's entitlement to external self-determination was justified given the unilateral withdrawal of Kosovo's autonomous arrangements (internal SD) under FRY. The court was also, in parallel and sometimes in not so clear terms, presented with an argument for remedial secession. This paper surveys the post-1999 proposals for accommodating Kosovo within a united Serbia, and explores the reasons for their failure. It further seeks to shed light on whether Kosovo presents a case study for the impossibility of internal self-determination along the lines of the federal idea, where the population in question has been subjected to egregious violations of International Humanitarian Law (by the existing state) thereby rendering an internal solution insufficient for the future protection of the population in question.
