Alex Salmond has proposed setting up a separate Scottish system of press regulation that could impose different rules to any new system introduced by the UK government after the Leveson inquiry.

The first minister said he would favour an independent ombudsman and a Scottish press council to pursue complaints against newspapers, similar to the model used in the Irish republic.

The move raises the strong prospect that different rules of press regulation could operate in Scotland and the rest of the UK. There are significant disputes emerging within the Westminster coalition government about future controls, with David Cameron facing conflicting demands for light controls and much tougher regulation.

Unlike broadcasting, which is reserved to Westminster, the Scottish parliament has devolved control over press regulation – powers that Holyrood has never proposed taking up until now. Salmond is keen to establish distinctive Scottish policies on major issues as he moves towards the independence referendum in 2014.

In an interview with BBC Scotland, Salmond rejected outright state regulation but instead preferred a "happy compromise" between legal controls and the current self-policing system run by the Press Complaints Commission.

"A lot of fears have been raised that Lord Leveson is going to recommend state regulation of the press, and I don't think he will incidentally, and I can't see there's going to be a currency of support for that in Scotland. We value our free press far too much," Salmond said.

"On the other hand if he said, 'Oh, laissez faire, all's for the best, the best of all possible worlds' – I don't think he is going to do that incidentally – then that also would be inadequate because clearly the current voluntary system is broken."

Salmond claimed the Scottish parliament, now dominated by the SNP majority government, was more likely to reach a consensus than at Westminster. However, Holyrood has never investigated a Scottish system of press regulation; a parliamentary debate will be held next week to discuss Leveson's conclusions.

Repeating his evidence to Leveson, Salmond said he preferred the Irish model. "It seems to be a happy compromise between, on the one hand the over-regulators, and on the other hand those who believe in 'laissez-faire'.

"The Irish press council system, or at least something like it, would seem to be at least an area where we can talk about and bring about a distinctively Scottish solution that protects absolutely the freedom of the press but still allows people, particularly people without the means to carry forward a defamation action, proper redress."

Salmond has faced intense controversy over his links to Rupert Murdoch and News International, after a series of confidential emails between the first minister and NI executives were released to the Leveson inquiry.

He has been accused by opposition leaders of secretly trading his political influence by supporting Murdoch's bid to take control of BSkyB in exchange for the Scottish Sun's political support, and its potential backing for independence – allegations he has denied.

The traditional view that Scottish journalism was free from malpractice has been shaken by allegations of News of the World phone hacking and historic allegations of misconduct by the Herald newspaper.

Several former News International journalists, including the former News of the World editor Andy Coulson, are facing trial after investigations by a Strathclyde police unit investigating alleged phone hacking in Scotland.

Coulson, Cameron's former press secretary, has denied charges of perjury in disgraced Scottish socialist politician Tommy Sheridan's trial for perjury in 2010. The ex-editor of the Scottish edition of the News of the World, Bob Bird, has been charged with attempting to pervert the course of justice. Bird denies the allegations.

The Leveson inquiry also heard testimony from Margaret and Jim Watson, who accused the Herald of repeatedly failing to apologise for attacks on their murdered daughter's character by the then columnist Jack McLean in 1991. Their son, Alan, committed suicide aged 15 partly because of those articles about his sister Diane, they said. The Herald apologised to the Watsons in November 2011.

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