Scotland doesn't have a 'completely different' justice system. It is somewhat different but I don't see why someone can't be tried in an English court under the Englsih system but held in Scotland if there is space. However, laywers would be arguing that it would be unfair on the prisoner as his/her family would find it difficult to visit. You know what it's like - never mind the victim, just make sure the perpetrator is not upset in any way.