An investigation is to be carried out into whether Alex Salmond breached the ministerial code as the row over legal advice on Scotland's place in Europe continued.
The First Minister confirmed he would refer himself to independent investigators, who will consider if he has broken the rules that govern ministers' behaviour.
It comes after his Deputy First Minister Nicola Sturgeon revealed on Tuesday that the Scottish Government had only now commissioned specific legal advice from law officers on the issue of an independent Scotland's future within the European Union (EU).
Mr Salmond announced he was referring the matter for investigation as the row over legal advice on EU membership dominated First Minister's Questions at Holyrood on Thursday.
Conservative leader Ruth Davidson demanded that Scotland's top law officer, Lord Advocate Frank Mulholland, come to the chamber to answer questions on the matter.
Meanwhile, Labour leader Johann Lamont hit out: "Why did the First Minister say he had sought advice from the law officers when he had not?"
Ms Stihler's Freedom of Information request ended up with the Scottish Government going to the Court of Session in Edinburgh to try to prevent the release of information.
The Labour leader challenged the First Minister on this, saying: "Why did he go to court at our expense to stop the release of advice he knew didn't exist?"
The SNP leader again asserted his belief that "of course an independent Scotland would be a member of the European Union".
His remarks to the Scottish Parliament came as Spain's Foreign Minister was reported to have said Scotland would be forced to "join the queue" to achieve membership of the EU. Jose Garcia-Margallo reportedly stated that Scotland would need to gain the unanimous approval of all current member states to "obtain the status of a candidate country".
Sir David Bell, the vice chancellor of Reading University and a former top civil servant in the UK Government's education department, will lead the investigation into Mr Salmond’s conduct.
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