Just wondering what’s the difference and why some contries use one over the other…I was thinking it had to do with the monarchy (ex. Japan and UK have monarchy…) but then there’s canada…hmmn…any ideas? thanx
In the main, those countries without a monarch or monarchial representative have a President over and above a Prime Minister. Those with monarchs tend to have PMs and governors/governors-general, with the exception of states where the monarch resides.
Sometimes, a country’s ruler just likes the sound of calling himself “El Presidente”. It appears to be the highest civil, non-royal title available.
Canada? Maybe a touch of copy-cat stuff. Both the US and France have presidents. I’ll leave that for the Canadians to answer.
There are two roles–head of state, which is largely ceremonial or symbolical; and head of government, the person who actually runs things. In the United States, the president is both head of state and head of government, functioning as ceremonial Leader of the Nation and as Chief Executive of the government. In modern European-style monarchies, the king or queen is the head of state and symbol of national unity, but the prime minister (generally chosen by the parliament or legislature) is the head of government and is in charge of decision making and the wielding of actual political power (with these responsibilities often being shared with the other ministers in the cabinet).
Other republics generally follow either the American model, with a “strong president” who is both head of state and government, or have a president who is in effect an elected monarch with only symbolic functions, and a prime minister (usually responsible to the legislature) who is head of government. France has a hybrid system, with a prime minister and a president who both wield real political power.
Canada is technically a monarchy; Queen Elizabeth of the U.K. is queen of Canada as well and is head of state. She is represented in Canada by a governor general and by lieutenant governors in each of the provinces who serve as ceremonial heads of state for their respective jurisdictions. The prime minister, chosen by the Canadian Parliament, and the provincial premiers, chosen by the legislative assemblies, are the actual heads of the national and provincial governments.
Another Canadian here… <maple leaf grin> 
I’ll add that the US, at least, elects its president in a separate ballot from the rest of the legislature. You may remember a bit of a tiff that last time that happened.
MEBuckner, a clarification: In Canada, and possibly other places that follow the British parliamentary system, no-one, even Parliament, elects the “government leader” (in Canada, the Prime Minister) as such. He or she is simply the leader of the party with the largest number of seats in the elected part of Parliament (in Canada, the House of Commons), and is theoretically just another Member of Parliament.
Parties choose their leaders before elections, with the full knowledge that the Leader of the Party That Gets The Most Seats And Therefore Wins will become PM. If a ruling party replaces its leader, that new leader automatically becomes PM as well. But the choosing is a party affair, not a government affair. Usually, there is a Deputy PM who can take over if the regular PM is ill, out of the country, etc, although I’m not sure whether this is formal.
(Experts, can a Prime Minister exist who is NOT an MP? In other words, if the PM loses a by-election while his or her party is still in power, and therefore loses his or her seat in Parliament, does the PM have to leave office and the party choose another leader?)
The Canadian Head of State is Her Majesty Queen Elizabeth II, who is ably represented by our Governor-General, Her Excellency the Right Honourable Adrienne Clarkson.
I’m pretty sure that in the UK the Prime Minister is simply a member of the majority political party in parliament and as such does not even need to be a sitting member of parliament initially to become prime minister, but is simply voted for by that party. I’ve a feeling that in the not too distant past we’ve had a PM who renounced his peerage (could not have been an elected MP) to take the office of PM.
Alec Douglas-Home?
Australia, too, operates under the Westminster system. Our Prime Minister must be a sitting member of parliament.
IIRC correctly, there are a couple of countries which have both a president and a prime minister - which is the republican model being proposed for Australia.
IIRC there is no absolute necessity for the Prime Minister of the UK to be a member of the House of Commons- many historic Prime Ministers sat in the Lords, and Lords can be created at will. However, it is likely (cf. Alec Douglas Home) that a PM sitting in the Lords would now be informally constitutionally unacceptable. If the unthinkable happened and a party won an election but its leader lost his/her seat, the party would need to decide whether to stick with the current leader (involving major problems with the Monarch who technically chooses the PM being asked to delay her decision) until a by election could be called in a safe seat and the potential PM re-elected. The danger with that is that the British electorate has a disdain for falsly called by elections and often acts perversely and elects the unlikely candidate for that constituency.
If the above scenario did occur, the party with a majority would probably elect a new leader and the Queen would then appoint this new leader as PM.
We need a real constitution!
Slight nitpick. A member of the House of Lords is a member of Parliament, just not an elected one - so can be a minister, even a Prime Minister, just like any elected MP. In these democratic times in which we live, though, it’s not considered the “done thing” for a Prime Minister to be a member of the Lords.
IIRC, there isn’t, technically, a requirement for the Prime Minster to be the leader of a political party. What happens is that someone gets “invited” by 'Er Majesty to form a Government. That person has to be someone who can command a majority in the Commons (I think they test this formally by having a vote on the content of the Queen’s Speech), so, in practice it’s going to be the leader of the winning party.
Sunspace, colour me confused… over here, the only way you can have a by-election is if the sitting MP stands down (or dies, goes mad, or is convicted of a felony), so how could a sitting PM lose a by-election? (I suppose it’s possible for an MP to resign a seat and re-fight it over some point of principle…) Are things different in Canada?
No country follows the “American System,” that is, the way we do things in the U.S. Our system is so old and unrepresentative, that no recent republic would ever have anything to do with it.
Instead, most European countries have chosen a Parliamentary System in which, as you have noted, there is a head of state and a head of government. In those nations that don’t have a king or queen – who serves as the head of state – there usually is a president. (Switzerland serves a State that does not follow the usual system). The President’s powers in such countries is limited. Usually he (or she) serves to greet guests of the state and perform other ceremonial functions.
However, in a parliamentary system, it is usually to the President that the Prime Minister reports. And, if the government is no longer functional, it is the responsibility of the President to call new elections. Similarly, in nations with Queens or Kings, it is the monarch who demands new elections when a government becomes unviable.
In a Parliamentary system, there may be maximum limits on the amount of time a government can serve without demanding new elections (as in England). Elections, nevertheless, can happen at any time.
The US is unique, though, in my understanding of Republcan systems. We have a system in which elections are held rigorously according to the calendar. In a Parliamentary system, all those unhappy with George Bush, who serves the functions of both President and Prime Minister (of a Parliamentary system), could be voted out in a week. Sadly, we have a unique system and will be saddled with four years of his ineptitude. Constitutionally, there is no way around it as long as he doesn’t break the law (that is: commit a “high crime or misdemeanor”).
Nitpicking Oscar’s post for a second - sorry, Or’n’ry. Some countries with parliamentary systems have fixed election dates. My adopted country is one of them: parliamentary elections every four years. (Local elections are also held every four years, and these alternate so that there is an election of some form held every other year.) If the government loses a confidence vote, a new government must be formed from the sitting parliament. In other countries, like Britain, elections can as you said be called at any time, with a maximum period between elections set by law.
The President or monarch in a parliamentary system sometimes formally chooses the governing party or coalition. In practice, of course, any head of state in a democratic parliamentary system naturally chooses the party/coalition with the greatest support in parliament.
The situation in the Netherlands is precisely like flodnaks description of Norway. We’re a monarchy, and have a government that is formed from the parliament after general elections. The one carrying out the initial coalition negotiations with the respective party leaders is called the informateur. He or she is appointed by the Queen - in all her wisdom, she usually (hell, always) chooses a respected member of the winning (i.e. largest) party to carry out the role. When all the cards are on the table, it is time to start the end negotiations in which the ministerial and sub-ministerial tasks are divided among the parties that were able to agree upon a coalition. This part of the process is supervised by the formateur (again officially appointed by the Queen), who in 90% of all cases is of the same party as the informateur, and who in 95% of all cases will become the next prime minister.
Interesting, a ‘newer’ democracy (Israel) also chose to follow the Westminster system. There’s no Monarchy there (well, since King David maybe…?).
Also worth pointing out that Parliamentary systems operate under both first-past-the-post and various forms of proportional representation – it’s flexible (capable of adapting to modern circumstances) whether you have a written Constitution or not.
There are a number of distinct problems with the American system (no system is perfect, far from it). One might see the imbalance of Corporate power influencing Government policy as one important issue / problem.
The precise constitional arrangements of each country varies and each has its own peculiarities. The head of state/head of government distinction is the important one.
The particular point to note is that neither the USA nor the UK are typical. The UK system largely depends on informal and unwritten conventions, although these have influenced the written constitutions of other countries including Canada and Australia. The theory behind the British constitution can now seem very odd. Thus, for the record, there is no formal reason why a British PM need be a Member of either House (Alec Douglas-Home was neither at the time of his appointment) or the leader of a political party (Churchill in 1940). As with other ministers, the PM is, in theory, whomever the monarch believes is best suited to carry out the duties of that office. Of course, the working of the system has, in practice, been adjusted to allow for the existance of modern political parties and the advantages in being able to command a majority in the House of Commons.
The oddity of the non-existence of a US Prime Minister relates to these British peculiarities. The US constitution is simply a idealised version of the British political system as it existed in the late eighteenth century with minor adjustments being made to allow for the periodic election of the head of state. The position of Prime Minister did not exist as a formal office at that time (in Britain or elsewhere) so the Founding Fathers made no provision for one. The Secretary of State was originally the nearest equivalent. Following the British model, the senior members of an Administration are whomever the President believes is best suited to carry out the duties of the particular office (with the proviso that Congressional approval must be obtained).
A further clarification: the government is not necessarily the party with the largest number of seats. In a multi-party situation, Party A may have the largest number of seats, Party B the second largest, and Party C the smallest number. However, if Party B reaches an agreement with Party C, and together they control the House, they could form the government, either as a coalition (both Party B and C in the government), or as a minority government (Party B forms the government, Party C stays on the Opposition side, but agrees to support Party B, usually in exchange for specific policy measures).
This may seem pretty hypothetical, but I believe it happened in Canada once in the twenties - I think that the Liberals held fewer seats than the Conservatives, but stayed in power with the support of a loose coalition of Progressive members. (I’m going on memory here - will check it out and report back.)
There was also a short period of a few months in 1873-74, when the Liberals formed the government although the Conservatives technically held more seats. The Liberals defeated the Conservative government of PM Macdonald in the House on a no-confidence motion over the Pacific Scandal, with some Conservative members voting against the government. (Party discipline was considerably weaker back then). PM Macdonald resigned, the Liberals under Mackenzie formed the government right away, and general elections were not held for a few months, until the spring of 1874.
On sunspace’s second point: there is no requirement in Canada’s constitutional law that a PM hold a seat in the Commons (there have been two PMs who sat in the unelected Senate), or even in Parliament. However, as a matter of constitutional convention, a PM who does not have a seat tries to get one as quickly as possible. For example, in the 1925 federal election, PM King lost his own seat, although the Liberals managed to squeak back with a minority government. King arranged for a loyal Liberal MP to resign a few months after the general election, called a by-election in the vacant seat, and ran in it himself. He was elected, and returned to the Commons. He stayed on as Prime Minister throughout.
Another common example is when a sitting PM retires, and his/her party elects a new leader. Sometimes, the party chooses a leader who is not currently a member of Parliament. The new leader becomes PM, and then tries to get a seat quickly, either by a by-election, or by calling general elections. For example, when PM Trudeau retired in 1984, the Liberals elected John Turner as their new leader. He was sworn in as PM, called general elections shortly thereafter, and lost the election to Mulroney’s Progressive Conservatives.
APB, I can’t speak to the Aussie situation, but Canada actually follows the UK practice fairly closely. Our written constitution does not set out the principles of responsible government. As in the UK, responsible government is part of the unwritten constitution, based on precedents and custom. UK precdents are cited, although there are some differences in the degree of party discipline, etc.
Or’n’ry Oscar writes:
And, of course, Latin America doesn’t have any “real” countries, just a mishmosh of tribes and caudillos? :rolleyes:
London_Calling writes:
And found the Westminster system (combined, of course, with PR in the Knesset) sufficiently repugnant that the electorate took the choice of PM away from the Knesset and the parties.
I disagree. What all posters have omitted so far in the great distinction between the Parliamentary system and the US system is that the US system elects its executive separately from its legislative officers. The President is a purely executive office. In the Parliamentary system, the executive power is derived from the legislature; the various secretaries are drawn from the MPs and usually do not give up their seats in the House of Commons (or equivalent). In the U.S., Senators and Congressmen are not Cabinet members; if they accept a Cabinet post, they resign their legislative seat. The two branches of government are deliberately opposed to an extent; in the Parliamentary system, it would be an absurdity for the Prime Minister to veto a bill, for example. Before a bill the Prime Minister did not want became law, he would likely have faced and lost a vote of confidence (or been deposed as the head of his party and a new Prime Minister who was head of his party taken his place). In the U.S. system, the veto power is explicitly written into the Constitution. A “vote of confidence” is not even a concept. The models are thus different to that extent.
Now the way that different governments that have a President and a Prime Minister, and how they split the power between them, is very individual. No one does it quite the way the U.S. does and also has a Prime Minister. In some cases (as has been said) the President is a titular role as head of state; in others, I believe the President has more power. YMMV.
Technically, the Prime Minister of Canada doesn’t even have to be a human being. The post does not legally exist. It’s a pure matter of tradition; somebody has to be the head honcho of the government, and we call that person the Prime Minister.
(Note to Americans: when I say “government” I am referring to not the entire organization, but the group of MPs that runs Parliament by virtue of having a majority or a stable plurality. They form a cabinet and wield power at the behest of the governor-general. This is called “forming a government.”)
The PM is recognized by a variety of small Parliamentary perks, but the Constitution does not recognize the existence of such a role (go ahead, look it up. “Prime Minister” doesn’t appear anywhere in the Constitution) and so a party could choose a senator or a politician-at-large if they so desired. Of course, it’d never happen; as Northern Piper points out, the first expectation of a seatless leader is to grab a seat, either in a byelection or in an upcoming general election.
Northern Piper:
It also happened in Ontario in 1985; the Progressive Conservatives won a plurality, but the Liberals and NDP agreed to govern together, ousting the 40-years-in-power PCs. The agreement lasted but two years before the Liberals stabbed them in the back.
RickJay, sorry to disagree, but the Prime Minister is mentioned in the Constitution, in s. 35.1 of the Constitution Act, 1982, which imposes a duty on him to call a constitutional conference in certain circumstances.
This provision is found in Part II of the 1982 Act, entitled “Rights of the Aboriginal Peoples of Canada.”
I would also disagree with your statement that the PM does not have to be human. (Although I certainly would say that you have to wonder about some of the incumbents we’ve had. Alien subsitution may be the best way to explain PM Campbell.) Although there is no office of Prime Minister under the Canadian Constitution, the various statutes governing the exercise of executive power essentially require that the powers can only be exercised by the “Governor-in-Council.” The Prime Minister by statutory implication must be a member of the Queen’s Privy Council for Canada (see Constitution Act, 1867, sections 11 and 13.) I think the courts would construe the term “member” in section 11 to be restricted to humans.
Actually, dlb, I would say that the example you give proves APB’s point, that the US system was modelled on the 18th century British consitution. The principles of responsible government and the power of the Prime Minister to which you refer evolved in the latter 18th-early 19th century. Earlier on, the British executive (the Crown) and the legislature were more clearly differentiated and sometimes clashed. The executive did in fact have, and exercised, the equivalent of a veto: the requirement that no bill becomes law without royal assent. Queen Anne was the last British monarch to withold royal assent.
Responsible government evolved in part to reconcile the non-elected executive with the increasingly democratic ethos, and in the process the legislative and executive branches merged to a certain extent, in their overlapping membership. However, that change ocurred gradually. The US constitution clearly resembles the formal structure of the British constitution as it existed in the late 18th century, even though that constitution was in the process of changing into something different.
It is customary under the Westminster parliamentary tradition that any cabinet minister (including the PM) must have a seat in Parliament. It is technically possible for a Canadian Senator to be PM, at least under the 1867 constitution, but it is probably obsolete (the last Senator-PM having been in the 1890s).
A non-Parliamentarian can be appointed to a cabinet post (and this has happened numerous times both federally and provincially) but convention dictates that the person must seek a seat in Parliament (or get appointed to one I guess, in the case of the Senate) ASAP, or vacate the post. Similarly, Don Getty, Clyde Wells, and Robert Bourassa were all invited to form provincial governments when their parties won provincial elections, even though they lost their own seats. They just had to arrange a convenient resignation to force a convenient by-election in a safe seat.
And even though the PM is only mentioned once in the various documents that make up the written Canadian constitution, there’s a whole mass of unwritten conventions that are just as much a part of a Westminster constitution. So the PM does, actually, exist!