BRITISH & AMERICAN CONSTITUTIONAL DEMOCRACY
(Continued)
B. PARLIAMENTARY SYSTEM & PRESIDENTIAL SYSTEM (Continued)
10. The British Parliamentary System and the American Presidential System--Side-by-Side Comparison and Contrast:
The parliamentary system in the United Kingdom and the presidential system in the U.S.A. differ from each other in the following ways:
PARLIAMENTARY SYSTEM (UK): PRESIDENTIAL SYSTEM (USA):
Constitutionally, the legisla- The legislature and the execu- tive and executive powers of tive have separate constitional government are vested in the grants of authority. The Con- elective, lower chamber of the stitution grants one set of national legislature. There powers to Congress, powers is a FUSION, or CONCENTRATION, which are primarily legislative of legislative and executive in character. The Constitution powers in the House of Com- grants another set of powers to mons, thelower and more pow- the President, powers which are erful chamber of Partiament. mainly executive. Powers are PARTITIONED, rather than fused.
The top executive authority Under the Constitution, the is a part of the legislature. legislature and the executive The Prime Minister and other are institutionally separate Cabinet members simultaneously and largely independent occupy the top executive of- branches of government. The fices in the government and President and other executive hold seats in Parliament, officers are constitutionally speaking and voting on meas- excluded from the legislature. ures under consideration in That is, they are not permitted their respective chambers. to hold seats in either house Under the Constitution, the house of Congress at the same Prime Minister is the clearly time that they hold posts in recognized leader of the ma- the executive branch. jority party in the Commons.
The top executive authority The President, the top execu- is not elected separately from tive authority, is elected sep- and independently of the leg- arately from and independently islature. The Prime Minister of the members of Congress. and most of the other members While presidential and congres- of the Cabinet are elected sional elections are held at from parliamentary election the same time and in the same districts as members of the polling booths, the presiden- House of Commons. The Com- tial ballot is entirely differ- mons, in effect, chooses from ent from the U.S. House and among its own members the Senate ballots. Rather than Prime Minister and most other being elected as a member of Cabinet ministers, selecting a the legislature from a single few ministers from the House local election district, the of Lords. President, through the medium of the Electoral College, is elected by the nation's voters as the chief executive of the entire U.S.A.
The clearly recignized chief A candidate's election to the leader of the political party office of President does not winning a majority of the depend on which political party seats in the House of Commons wins a majority in either or becomes Prime Minister. Other both houses of Congress; the leaders of the majority party candidate's winning the presi- in the Commons also become dential election does not re- members of the Cabinet. The quire victory of his party in Prime Minister and other Cab- the congressional elections. inet members remain in office, The President may be of one as the top executive authori- party, and the opposition party ty, only so long as they have may hold a majority of the the confidence and support of seats in one or both houses of a majority in the House of Congress. Since the President Commons. If the Cabinet loses is elected to a fixed term of a vote of confidence in the office, his tenure and preroga- Commons, there are available tives as the nation's chief ex- two alternative courses of ac- ecutive do not depend on con- tion: (1) The Cabinet members tinuing majority support in the may jointly resign--from the legislature. Legally, a simple Cabinet, but not from Parlia- majority in Congress cannot ment. (1) The Prime Minister force the President to resign. may advise the Monarch to dis- In short, the Constitution pro- solve Parliament and call a vides the chief executive with national election. The power a separate and independent pow- and tenure of the Cabinet is er base--a power base separate based squarely on continuing from and independent of that of majority support in the House the legislature. of Commons.
The Cabinet is directly re- The President is directly and sponsible to the House of Com- primarily responsible to the mons. The Cabinet is the voters, not to Congress. The agent, or instrument, of the chief executive and the legis- Commons and is therefore di- lature are coordinate organs rectly accountable to that of government--i.e., govern- body. The Prime Minister, AS mental organs equal in rank, THE PRIME MINISTER, is not di- neither being the agent or sub- rectly responsible to the vot- ordinate of the other. ers of the United Kingdom.
The Prime Minister is head of The President is both chief of government, while the Monarch state and head of government, is chief of state. The Mon- performing the ceremonial func- arch performs the ceremonial tions of chief of state as well functions of symbolic leader as the policy and administra- and ruler of the nation. The tive leadership functions of Prime Minister, as head of head of government. government, is the principal active political leader in the country and the leading factor in the shaping of public poli- cy and in the supervision and direction of policy adminis- tration, or implementation.
The political party that has a Control of the principal organs majority in the lower chamber of government may be divided of Parliament also controls between rival political par- the top executive authority. ties, with control of the exec- As long as the country has a utive being in the hands of one strong two-party system and party and with control of one the leading party has a clear or both houses of the legisla- and secure majority in the ture being in the hands of the House of Commons, there is no opposition party. possibility of divided party control of the legislative and executive organs of govern- ment.
The government is character- The government is characterized ized by a single, unbroken by multiple and fragmented line of political authority lines of political authority from the voters through the and responsibility. legislature to the executive and a single, unbroken line of political responsibility from the executive through the leg- islature to the voters.
Most constitutional democracies in the world today are parliamentary systems. All modern constitutional monarchies are parliamentary systems. So are most modern constitutional republics.
The governmental system of the U.S.A., historically and traditionally, has been the one significant example of a presidential system. Since the establishment of the Fifth French Republic in 1958, France has had a system of government with both presidential and parliamentary features. However, the powers of the President under the 1958 De Gaulle Constitution are so overwhelming that the contemporary French government may be accurately referred to as a presidential system.