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A
prime minister is the most senior minister of cabinet (government) in the Executive (government) branch of
government in a parliamentary system. The position is usually held by, but need not always be held by, a
politician. In many systems the Prime Minister selects and can dismiss other members of the cabinet, and allocates posts to members within the Government. In most systems they are the presiding member and
chairperson of the cabinet. In a minority of systems, notably in
semi-presidential system of government, a prime minister is the official who is appointed to manage the
civil service and execute the directives of the
President.
In parliamentary systems like the
United Kingdom's or
Australia's
Westminster system, the prime minister is the presiding and actual head of the government and head of the executive branch. In such systems, the head of state or the head of state's official representative (the King, Queen, President, or Governor-General), although officially the head of the executive branch, in fact holds a ceremonial position. The Prime Minister is often, but not always, a member of parliament and is expected with other ministers to ensure the passage of bills through the
legislature. In some monarchy the prime minister also exercises executive powers (known as the
Royal Prerogative) which are constitutionally vested in the Crown and can be exercised without the approval of parliament.
As well as being Head of Government, a prime minister may have other roles or titles — the Prime Minister of the United Kingdom, for example, is also
First Lord of the Treasury and
Minister for the Civil Service.Contrary to popular perception the two posts are separate and need not be held by the one person. The last prime minister not to be First Lord of the Treasury was Lord Salisbury at the turn of the 20th century. 10 Downing Street is actually the First Lord's residence, not the Prime Minister's. As Salisbury was not First Lord he had to live elsewhere as prime minister. Prime ministers may take other ministerial posts — for example during the
Second World War Winston Churchill was also
Minister of Defence (although there was then no
Ministry of Defence (United Kingdom)).
Primus inter pares
Historically, prime ministers are often referred to
Primus inter pares, a Latin term translated as
first among equals, and which reflects the original concept of a prime minister as merely the first minister or most senior minister to the monarch, not the dominant or presiding minister, a role later assumed by many prime ministers in many states.
History
, the first Prime Minister of the United Kingdom.While the modern office of Prime Minister was developed in the UK the first actual usage of the word Prime Minister or Premier Ministre was used by
Cardinal Richelieu, when, in 1624 he was named to head the royal council as prime minister of France.
Louis XIV and his descendants generally attempted to avoid giving this title to their chief ministers.The term Prime Minister in the sense that we know it originated in the 18th century in the
United Kingdom. Since medieval times Kings of England and the United Kingdom had ministers in whom they placed special trust and who were regarded as the head of the government. Examples were
Thomas Cromwell, 1st Earl of Essex under Henry VIII of England; William Cecil, 1st Baron Burghley under
Elizabeth I of England;
Edward Hyde, 1st Earl of Clarendon under
Charles II of England and Sidney Godolphin, 1st Earl of Godolphin under Anne of Great Britain. These ministers held a variety of formal posts, but were commonly known as "the Minister," the "first Minister" and finally the "Prime Minister."
The power of these ministers depended entirely on the personal favour of the Monarch. Although managing the Parliament was among the necessary skills of holding high office, they did not depend on a parliamentary majority for their power. Although there was a
Cabinet, it was appointed entirely by the Monarch, and the Monarch usually presided over its meetings. When the Monarch tired of a first minister, they could be dismissed, or worse: Cromwell was executed and Clarendon driven into exile when they lost favour. Kings sometimes divided power equally between two or more ministers to prevent one minister becoming too powerful. Late in Anne's reign, for example, the Tory ministers Robert Harley, 1st Earl of Oxford and Mortimer and Henry St John, 1st Viscount Bolingbroke shared power.
In the mid 17th century, after the
English Civil War and the The Protectorate, Parliament had strengthened its position and it emerged even more powerful after the
Glorious Revolution of 1688. The King could not establish any law or impose any tax without its permission.Thus it has been said that the House of Commons became a part of the government and it has been only a further step of this development that a new kind of prime minister should emerge. This turning point in the evolution of the prime ministership came with the death of Anne in 1714 and the accession of George I of Great Britain. George spoke no English, spent much of his time at his home in
Hanover, and had neither knowledge of nor interest in the details of English government. In these circumstances it was inevitable that the King's first minister would become the
de facto head of state. From 1721 this was the British Whig Party politician Robert Walpole, who held office for twenty-one years. Walpole chaired Cabinet meetings, appointed all the other ministers, dispensed the royal patronage and packed the
British House of Commons with his supporters. Under Walpole, the doctrine of Cabinet solidarity developed. Walpole required that no minister other than him have private dealings with the King, and also that when the Cabinet had agreed on a policy, all ministers must defend it in public or resign. As a later Prime Minister,
William Lamb, 2nd Viscount Melbourne, said: "It matters not what we say, gentlemen, so long as we all say the same thing."
Walpole always denied that he was "Prime Minister," and throughout the 18th century parliamentarians and legal scholars continued to deny that any such position was known to the Constitution. The title was first referred to on Government documents during the administration of
Benjamin Disraeli but did not appear in the formal British
Order of precedence until 1905. George II of Great Britain and
George III of Great Britain made strenuous efforts to reclaim the personal power of the Monarch, but the increasing complexity and expense of government meant that a minister who could command the loyalty of the Commons was increasingly necessary. The long tenure of the wartime Prime Minister William Pitt the Younger (
1783-
1801), combined with the mental illness of George III, consolidated the power of the post.
The prestige of British institutions in the 19th century and the growth of the
British Empire saw the British model of cabinet government, headed by a prime minister, widely copied, both in other European countries and in British colonial territories as they developed self-government. In some places alternative titles such as "Premier," "Chief Minister," "First Minister of State", "President of the Council" or "Chancellor" were adopted, but the essentials of the office were the same. By the late 20th century the majority of the world's countries had a "Prime Minister" or equivalent minister, holding office under either a constitutional monarchy or a ceremonial president. The main exceptions to this system have been the United States and the presidential republics in Latin America, modelled on the U.S. system, in which the president directly exercises executive authority.
Prime ministers in republics and in monarchies
The post of prime minister is one which may be encountered both in constitutional Monarch (such as Prime Minister of Belgium, Prime Minister of Denmark,
Prime Minister of Japan, The Netherlands,
Prime Minister of Norway, Prime Minister of Malaysia,
Prime Minister of Spain Although the roles of the Spanish Head of State coincide with the definition of a 'Prime Minister', in Spain the position is in fact referred to as 'the Presidency of the Government' ,
Prime Minister of Canada,
Prime Minister of Australia, and the Prime Minister of the United Kingdom), and in republics in which the head of state is an elected (such as
Finland, France,
Germany, India, Republic of Ireland, Portugal,
Romania, Turkey) or unelected official (such as
Singapore before 1993) with varying degrees of real power. This contrasts with the
presidential system, in which the
President (or equivalent) is both the head of state and the head of the government. See also "
First Minister" , "
Premier", "Chief Minister" "Chancellor" and "Taoiseach": alternative titles usually equivalent in meaning to, or translated as, "prime minister."
In some
Presidential system or
Semi-presidential system systems such as those of
Politics of France, Politics of Russia or
Politics of South Korea the prime minister is an official generally appointed by the President but usually approved by the legislature and responsible for carrying out the directives of the President and managing the civil service. (The premier of the
Politics of the Republic of China is also appointed by the president, but requires no approval by the legislature. Appointment of the prime minister of France requires no approval by the parliament either, but the parliament can force the resignation of the government.) In these systems, it is possible for the president and the prime minister to be from different political parties if the legislature is controlled by a party different from that of the president. When it arises, such a state of affairs is usually referred to as (political)
cohabitation (government).
Entry into office
In parliamentary systems a prime minister can enter into office by several means.
- By appointment by the Head of State, without reference to parliament: While in practice most Prime Ministers under the Westminster system (including Australia, Canada, New Zealand, Malaysia, India and the United Kingdom) are the leaders of the largest party in parliament, technically the appointment of the Prime Minister is a royal prerogative exercised by the Queen or the Governor-General. No parliamentary vote takes place on who is forming a government. However as the government will have to outline its legislative programme to parliament in the Speech from the Throne, the speech is sometimes used to test parliamentary support. A defeat on the Speech is taken to mean a Motion of Confidence and so requires either a new draft (a humiliating act no government would contemplate), resignation, or a request for a dissolution of parliament. Until the early 20th century governments when defeated in a general election remained in power until their Speech from the Throne was defeated and then resigned. No government has done so for one hundred years, though Edward Heath in 1974 did delay his resignation while he explored whether he could form a government with Liberal Party (UK) support.
In such systems unwritten (and unenforceable) constitutional conventions often outline the order in which people are asked to form a government. If the Prime Minister resigns after a general election, the monarch usually asks the Leader of the Opposition to form a government. Where however a resignation occurs during a parliament (unless the government has itself collapsed) the monarch will ask another member of the government to form a government. While previously the monarch had some leeway in whom to ask, all British political parties now elect their leaders (until 1965 the
Conservative Party (UK)s chose their leader by informal consultation). The last time the monarch had a choice over the appointment occurred in 1963 when the Alec Douglas-Home was asked to become Prime Minister ahead of
Rab Butler.
- Appointment by the head of state after parliament nominates a candidate: Example: The Republic of Ireland where the President of Ireland appoints the Taoiseach on the nomination of the Dáil Éireann.
- The head of state nominates a candidate for prime minister who is then submitted to parliament for approval before appointment as prime minister: Example: Spain, where the King sends a nomination to parliament for approval. Also Germany where under the Basic Law of the Federal Republic of Germany (constitution) the Bundestag votes on a candidate nominated by the Federal President. In these cases, parliament can choose another candidate who then would be appointed by the head of state.
- The head of state appoints a prime minister who has a set timescale within which s/he must gain a vote of confidence: (Example: Italy.)
- Direct election by parliament: (Example: The Northwest Territories, Nunavut, and the Australian Capital Territory.)
- Direct election by the public (Example: Israel, 1996-2001, where the prime minister was elected in a general election, with no regard to political affiliation.)
- Appointment by a state office holder other than the head of state or his/her representative: (Example: Under the modern Swedish Constitution of Sweden, the power to commission someone to form a government has been moved from the Monarch of Sweden to the Speaker of Parliament, who, once it has been approved, formally makes the appointment.
Though most prime ministers are 'appointed', they are often inaccurately described as 'elected'.
Prime ministers and constitutions
The position, power and status of prime ministers differ depending on the age of the constitution in individuals.
Australia's Constitution of Australia makes no mention of a Prime minister of Australia of Australia.
Canada's Constitution of Canada, being a 'mixed' or hybrid constitution (a constitution that is partly formally codified and partly uncodified) originally did not make any reference whatsoever to a Prime Minister, with his specific duties and method of appointment instead dictated by "convention." In the
Constitution Act, 1982, passing reference to a "Prime Minister of Canada" is added, though only regarding the composition of conferences of federal and provincial first ministers.
Germany's Basic Law of the Federal Republic of Germany (1949) lists the powers, functions and duties of the federal
Chancellor of Germany.
India's Constitution of India (1950) lists the powers, functions and duties of the
Prime Minister of India.
Japan's Constitution of Japan (1946) lists the powers, functions and duties of the
Prime Minister of Japan.
Malta's Constitution of Malta (1964) lists the powers, functions and duties of the
Prime Minister of Malta.
The
Republic of Ireland's constitution, Bunreacht na hÉireann (1937), provides for the office of Taoiseach in detail, listing powers, functions and duties.
The
United Kingdom's Constitution of the United Kingdom, being
uncodified constitution and largely unwritten, makes no mention of a Prime Minister of the United Kingdom. Though it had de facto existed for centuries, its first mention in official state documents did not occur until the first decade of the twentieth century. Accordingly, it is often said "not to exist", indeed there are several instances of parliament declaring this to be the case. The prime minister sits in the cabinet solely by virtue of occupying another office, either First Lord of the Treasury (office in commission), or more rarely
Chancellor of the Exchequer (the last being Balfour in 1905).
Exit from office
Contrary to popular and
journalistic belief, most prime ministers in
parliamentary systems are not appointed for a specific term in office and in effect may remain in power through a number of
elections and parliaments. For example, Margaret Thatcher was only ever appointed prime minister on
one occasion, in 1979. She remained
continuously in power until 1990, though she used the assembly of each British House of Commons after a
general election to
Cabinet reshuffle. Some states, however, do have a term of office of the prime minister linked to the period in office on the parliament. Hence the
Republic of Ireland Taoiseach is formally 'renominated' after every general election. (Some constitutional experts have questioned whether this process is actually in keeping with the provisions of the Irish constitution, which
appear to suggest a taoiseach should remain in office, without the requirement of a
renomination, unless s/he has clearly lost the general election.) The position of prime minister is normally chosen from the political party that commands majority of seats in the lower house of parliament.
In parliamentary systems, governments are generally required to have the confidence of the
lower house (though a small minority of parliaments, by giving a right to block
Loss of Supply to
upper houses, in effect make the cabinet responsible to both houses, though in reality upper houses, even when they have the power, rarely exercise it). Where they lose a
vote of confidence, have a
motion of no confidence passed against them, or where they lose Supply, most constitutional systems require either:
a) a letter of resignation or
b) a request of a parliamentary dissolution.
The latter in effect allows the government to appeal the
Opposition (parliamentary) of parliament to the electorate. However in many jurisdictions a head of state
may refuse a parliamentary dissolution, requiring the resignation of the prime minister and his or her government. In most modern parliamentary systems, the prime minister is the person who decides when to request a parliamentary dissolution. Older constitutions often vest this power in the cabinet. (In the United Kingdom, for example, the tradition whereby it is the prime minister who requests a dissolution of parliament dates back to 1918. Prior to then, it was the
entire government that made the request. Similarly, though the modern 1937 Irish constitution grants to the Taoiseach the right to make the request, the earlier 1922
Irish Free State Constitution vested the power in the
Executive Council (the then name for the Irish
cabinet).
Titles
A number of different terms are used to describe prime ministers. In Germany and
Austria the prime minister is actually titled Chancellor of Germany (
Bundeskanzler) while the Irish prime minister is called the
Taoiseach. In many cases, though commonly used, "prime minister" is not the official title of the office-holder; the Spanish prime minister is the
President of the Government (
Presidente del Gobierno). Other common forms include President of the Council of Ministers (for example in Italy,
Presidente del Consiglio dei Ministri), President of the Executive Council, or Minister-President. In
federations, the head of government of subnational entities like states or provinces is most commonly known as the Premier, Chief Minister or
Minister-president.
In non-Commonwealth countries the prime minister may be entitled to the style of
Excellency like a president. In some Commonwealth countries Prime Ministers and former Prime Ministers are styled Right Honourable, for example, the Right Honourable Sir
John Major.
In the UK where devolved Government is in place, the leader of the Scottish Government is styled
First Minister.
Chairman or chief?
Irish
political scientist Professor Brian Farrell coined the term "Chairman or Chief" to describe the two alternative concepts of prime ministerial leadership, in his book of the same name about the office of
Taoiseach.Brian F. Farrell,
Chairman or Chief? The Role of Taoiseach in Irish Government (1971) The term, widely used in political science worldwide, draws a distinction between a head of government who is merely a facilitator and co-ordinator of a cabinet (the "chairman"), and those who lead it forcefully from the front, setting its policy agenda and requiring all ministers to follow the leader's policies (the "chief").Examples of "chairmen" have included Bertie Ahern (Ireland),
John Major (United Kingdom) and Maurice Couve de Murville (France), while examples of chiefs included Indira Gandhi and Atal Bihari Vajpayee ,
Seán Lemass (Ireland),
Margaret Thatcher and
Tony Blair (United Kingdom), and
Jacques Chirac when prime minister under
cohabitation.
Not every prime minister fits exclusively into either category: Éamon de Valera, though a strong personality, was only interested in controlling some of his government's agenda (usually constitutional matters and Anglo-Irish affairs), and allowed large areas to decided by his colleagues. Though superficially a chief (and called "the Chief" literal translation of
Taoiseach by his colleagues) historians see him as more of a chairman, particularly in later governments.
Winston Churchill too, though superficially a "chief", was more chairmanlike in later governments and in those areas in which he had little personal interest.
As well as describing office holders, individual offices could be described as belonging to one or other category. Among the more dominant prime ministerial offices in terms of powers, and so more chieflike, are the premierships of Ireland and Spain, where premiers can hire and fire at will. In contrast, offices such as President of the Executive Council of the Irish Free State, Prime Minister of the Third French Republic, and the premierships of
Belgium and The Netherlands are more chairmanlike in format. Lijphart referred to the premiership of the Netherlands as "
primus inter pares without due emphasis on
primus".Jean Blondel & Ferdinand Muller-Rommel (eds)
Cabinets in Western Europe Macmillan, 1993 edition. p.81.
Description of the role
Wilfried Martens, who served as Prime Minister of Belgium, described his role as follows:
First of all Prime Minister must listen a lot, and when deep disagreements occur, he must suggest a solution to the matter. This can be done in different ways. Sometimes during the discussion, I note the elements of the problem and think of a proposal I can formulate to the Council (cabinet), the Secretary taking notes. The Ministers then insist on changing commas and full stops. The Prime Minister can also make a proposal which leaves enough room for amendments in order to keep the current discussion on the right tracks. When a solution must be found in order to reach a consensus, he can force one or two Ministers to join or resign.Wilfried Martens, quoted in
ibid.
==Lists of prime ministers==
A
prime minister is the most senior minister of cabinet (government) in the
Executive (government) branch of
government in a
parliamentary system. The position is usually held by, but need not always be held by, a politician. In many systems the Prime Minister selects and can dismiss other members of the cabinet, and allocates posts to members within the Government. In most systems they are the presiding member and chairperson of the cabinet. In a minority of systems, notably in
semi-presidential system of government, a prime minister is the official who is appointed to manage the
civil service and execute the directives of the President.
In parliamentary systems like the
United Kingdom's or
Australia's
Westminster system, the prime minister is the presiding and actual head of the government and head of the executive branch. In such systems, the
head of state or the head of state's official representative (the King, Queen, President, or Governor-General), although officially the head of the executive branch, in fact holds a ceremonial position. The Prime Minister is often, but not always, a
member of parliament and is expected with other ministers to ensure the passage of bills through the legislature. In some monarchy the prime minister also exercises executive powers (known as the
Royal Prerogative) which are constitutionally vested in the Crown and can be exercised without the approval of parliament.
As well as being Head of Government, a prime minister may have other roles or titles — the Prime Minister of the United Kingdom, for example, is also
First Lord of the Treasury and Minister for the Civil Service.Contrary to popular perception the two posts are separate and need not be held by the one person. The last prime minister not to be First Lord of the Treasury was Lord Salisbury at the turn of the
20th century. 10 Downing Street is actually the First Lord's residence, not the Prime Minister's. As Salisbury was not First Lord he had to live elsewhere as prime minister. Prime ministers may take other ministerial posts — for example during the Second World War
Winston Churchill was also
Minister of Defence (although there was then no
Ministry of Defence (United Kingdom)).
Primus inter pares
Historically, prime ministers are often referred to
Primus inter pares, a Latin term translated as
first among equals, and which reflects the original concept of a prime minister as merely the first minister or most senior minister to the monarch, not the dominant or presiding minister, a role later assumed by many prime ministers in many states.
History
, the first Prime Minister of the United Kingdom.While the modern office of Prime Minister was developed in the UK the first actual usage of the word Prime Minister or Premier Ministre was used by
Cardinal Richelieu, when, in 1624 he was named to head the royal council as prime minister of France. Louis XIV and his descendants generally attempted to avoid giving this title to their chief ministers.The term Prime Minister in the sense that we know it originated in the 18th century in the
United Kingdom. Since medieval times Kings of England and the United Kingdom had ministers in whom they placed special trust and who were regarded as the head of the government. Examples were
Thomas Cromwell, 1st Earl of Essex under Henry VIII of England;
William Cecil, 1st Baron Burghley under
Elizabeth I of England; Edward Hyde, 1st Earl of Clarendon under Charles II of England and Sidney Godolphin, 1st Earl of Godolphin under
Anne of Great Britain. These ministers held a variety of formal posts, but were commonly known as "the Minister," the "first Minister" and finally the "Prime Minister."
The power of these ministers depended entirely on the personal favour of the Monarch. Although managing the Parliament was among the necessary skills of holding high office, they did not depend on a parliamentary majority for their power. Although there was a
Cabinet, it was appointed entirely by the Monarch, and the Monarch usually presided over its meetings. When the Monarch tired of a first minister, they could be dismissed, or worse: Cromwell was executed and Clarendon driven into exile when they lost favour. Kings sometimes divided power equally between two or more ministers to prevent one minister becoming too powerful. Late in Anne's reign, for example, the Tory ministers Robert Harley, 1st Earl of Oxford and Mortimer and Henry St John, 1st Viscount Bolingbroke shared power.
In the mid 17th century, after the
English Civil War and the The Protectorate, Parliament had strengthened its position and it emerged even more powerful after the Glorious Revolution of 1688. The King could not establish any law or impose any tax without its permission.Thus it has been said that the House of Commons became a part of the government and it has been only a further step of this development that a new kind of prime minister should emerge. This turning point in the evolution of the prime ministership came with the death of Anne in 1714 and the accession of George I of Great Britain. George spoke no English, spent much of his time at his home in Hanover, and had neither knowledge of nor interest in the details of English government. In these circumstances it was inevitable that the King's first minister would become the
de facto head of state. From 1721 this was the
British Whig Party politician
Robert Walpole, who held office for twenty-one years. Walpole chaired Cabinet meetings, appointed all the other ministers, dispensed the royal patronage and packed the
British House of Commons with his supporters. Under Walpole, the doctrine of Cabinet solidarity developed. Walpole required that no minister other than him have private dealings with the King, and also that when the Cabinet had agreed on a policy, all ministers must defend it in public or resign. As a later Prime Minister, William Lamb, 2nd Viscount Melbourne, said: "It matters not what we say, gentlemen, so long as we all say the same thing."
Walpole always denied that he was "Prime Minister," and throughout the 18th century parliamentarians and legal scholars continued to deny that any such position was known to the Constitution. The title was first referred to on Government documents during the administration of Benjamin Disraeli but did not appear in the formal British
Order of precedence until 1905.
George II of Great Britain and George III of Great Britain made strenuous efforts to reclaim the personal power of the Monarch, but the increasing complexity and expense of government meant that a minister who could command the loyalty of the Commons was increasingly necessary. The long tenure of the wartime Prime Minister William Pitt the Younger (1783-
1801), combined with the mental illness of George III, consolidated the power of the post.
The prestige of British institutions in the 19th century and the growth of the British Empire saw the British model of cabinet government, headed by a prime minister, widely copied, both in other European countries and in British colonial territories as they developed self-government. In some places alternative titles such as "Premier," "Chief Minister," "First Minister of State", "President of the Council" or "Chancellor" were adopted, but the essentials of the office were the same. By the late 20th century the majority of the world's countries had a "Prime Minister" or equivalent minister, holding office under either a constitutional monarchy or a ceremonial president. The main exceptions to this system have been the
United States and the presidential republics in Latin America, modelled on the U.S. system, in which the president directly exercises executive authority.
Prime ministers in republics and in monarchies
The post of prime minister is one which may be encountered both in constitutional
Monarch (such as
Prime Minister of Belgium, Prime Minister of Denmark,
Prime Minister of Japan, The Netherlands,
Prime Minister of Norway, Prime Minister of Malaysia,
Prime Minister of Spain Although the roles of the Spanish Head of State coincide with the definition of a 'Prime Minister', in Spain the position is in fact referred to as 'the Presidency of the Government' , Prime Minister of Canada, Prime Minister of Australia, and the
Prime Minister of the United Kingdom), and in
republics in which the head of state is an elected (such as Finland,
France,
Germany,
India,
Republic of Ireland,
Portugal,
Romania, Turkey) or unelected official (such as Singapore before 1993) with varying degrees of real power. This contrasts with the
presidential system, in which the
President (or equivalent) is both the head of state and the head of the government. See also "
First Minister" , "
Premier", "
Chief Minister" "Chancellor" and "Taoiseach": alternative titles usually equivalent in meaning to, or translated as, "prime minister."
In some Presidential system or
Semi-presidential system systems such as those of Politics of France,
Politics of Russia or Politics of South Korea the prime minister is an official generally appointed by the President but usually approved by the legislature and responsible for carrying out the directives of the President and managing the civil service. (The premier of the Politics of the Republic of China is also appointed by the president, but requires no approval by the legislature. Appointment of the prime minister of France requires no approval by the parliament either, but the parliament can force the resignation of the government.) In these systems, it is possible for the president and the prime minister to be from different political parties if the legislature is controlled by a party different from that of the president. When it arises, such a state of affairs is usually referred to as (political) cohabitation (government).
Entry into office
In parliamentary systems a prime minister can enter into office by several means.
- By appointment by the Head of State, without reference to parliament: While in practice most Prime Ministers under the Westminster system (including Australia, Canada, New Zealand, Malaysia, India and the United Kingdom) are the leaders of the largest party in parliament, technically the appointment of the Prime Minister is a royal prerogative exercised by the Queen or the Governor-General. No parliamentary vote takes place on who is forming a government. However as the government will have to outline its legislative programme to parliament in the Speech from the Throne, the speech is sometimes used to test parliamentary support. A defeat on the Speech is taken to mean a Motion of Confidence and so requires either a new draft (a humiliating act no government would contemplate), resignation, or a request for a dissolution of parliament. Until the early 20th century governments when defeated in a general election remained in power until their Speech from the Throne was defeated and then resigned. No government has done so for one hundred years, though Edward Heath in 1974 did delay his resignation while he explored whether he could form a government with Liberal Party (UK) support.
In such systems unwritten (and unenforceable) constitutional conventions often outline the order in which people are asked to form a government. If the Prime Minister resigns after a general election, the monarch usually asks the Leader of the Opposition to form a government. Where however a resignation occurs during a parliament (unless the government has itself collapsed) the monarch will ask another member of the government to form a government. While previously the monarch had some leeway in whom to ask, all British political parties now elect their leaders (until 1965 the
Conservative Party (UK)s chose their leader by informal consultation). The last time the monarch had a choice over the appointment occurred in 1963 when the
Alec Douglas-Home was asked to become Prime Minister ahead of
Rab Butler.
- Appointment by the head of state after parliament nominates a candidate: Example: The Republic of Ireland where the President of Ireland appoints the Taoiseach on the nomination of the Dáil Éireann.
- The head of state nominates a candidate for prime minister who is then submitted to parliament for approval before appointment as prime minister: Example: Spain, where the King sends a nomination to parliament for approval. Also Germany where under the Basic Law of the Federal Republic of Germany (constitution) the Bundestag votes on a candidate nominated by the Federal President. In these cases, parliament can choose another candidate who then would be appointed by the head of state.
- The head of state appoints a prime minister who has a set timescale within which s/he must gain a vote of confidence: (Example: Italy.)
- Direct election by parliament: (Example: The Northwest Territories, Nunavut, and the Australian Capital Territory.)
- Direct election by the public (Example: Israel, 1996-2001, where the prime minister was elected in a general election, with no regard to political affiliation.)
- Appointment by a state office holder other than the head of state or his/her representative: (Example: Under the modern Swedish Constitution of Sweden, the power to commission someone to form a government has been moved from the Monarch of Sweden to the Speaker of Parliament, who, once it has been approved, formally makes the appointment.
Though most prime ministers are 'appointed', they are often inaccurately described as 'elected'.
Prime ministers and constitutions
The position, power and status of prime ministers differ depending on the age of the constitution in individuals.
Australia's Constitution of Australia makes no mention of a
Prime minister of Australia of Australia.
Canada's Constitution of Canada, being a 'mixed' or hybrid constitution (a constitution that is partly formally codified and partly uncodified) originally did not make any reference whatsoever to a Prime Minister, with his specific duties and method of appointment instead dictated by "convention." In the Constitution Act, 1982, passing reference to a "
Prime Minister of Canada" is added, though only regarding the composition of conferences of federal and provincial first ministers.
Germany's Basic Law of the Federal Republic of Germany (1949) lists the powers, functions and duties of the federal Chancellor of Germany.
India's Constitution of India (1950) lists the powers, functions and duties of the
Prime Minister of India.
Japan's Constitution of Japan (1946) lists the powers, functions and duties of the
Prime Minister of Japan.
Malta's Constitution of Malta (1964) lists the powers, functions and duties of the
Prime Minister of Malta.
The
Republic of Ireland's constitution, Bunreacht na hÉireann (1937), provides for the office of
Taoiseach in detail, listing powers, functions and duties.
The
United Kingdom's Constitution of the United Kingdom, being
uncodified constitution and largely unwritten, makes no mention of a Prime Minister of the United Kingdom. Though it had de facto existed for centuries, its first mention in official state documents did not occur until the first decade of the twentieth century. Accordingly, it is often said "not to exist", indeed there are several instances of parliament declaring this to be the case. The prime minister sits in the cabinet solely by virtue of occupying another office, either First Lord of the Treasury (office in commission), or more rarely Chancellor of the Exchequer (the last being
Balfour in 1905).
Exit from office
Contrary to popular and journalistic belief, most prime ministers in parliamentary systems are not appointed for a specific term in office and in effect may remain in power through a number of
elections and parliaments. For example,
Margaret Thatcher was only ever appointed prime minister on
one occasion, in 1979. She remained
continuously in power until 1990, though she used the assembly of each British House of Commons after a general election to
Cabinet reshuffle. Some states, however, do have a term of office of the prime minister linked to the period in office on the parliament. Hence the Republic of Ireland
Taoiseach is formally '
renominated' after every general election. (Some
constitutional experts have questioned whether this process is actually in keeping with the provisions of the Irish constitution, which
appear to suggest a
taoiseach should remain in office, without the requirement of a
renomination, unless s/he has clearly lost the general election.) The position of prime minister is normally chosen from the political party that commands majority of seats in the lower house of parliament.
In parliamentary systems,
governments are generally required to have the confidence of the
lower house (though a small minority of parliaments, by giving a right to block Loss of Supply to upper houses, in effect make the cabinet responsible to both houses, though in reality upper houses, even when they have the power, rarely exercise it). Where they lose a
vote of confidence, have a
motion of no confidence passed against them, or where they lose Supply, most
constitutional systems require either:
a) a letter of resignation or
b) a request of a parliamentary dissolution.
The latter in effect allows the government to appeal the
Opposition (parliamentary) of parliament to the
electorate. However in many jurisdictions a head of state
may refuse a parliamentary dissolution, requiring the resignation of the prime minister and his or her government. In most modern parliamentary systems, the prime minister is the person who decides when to request a parliamentary dissolution. Older constitutions often vest this power in the
cabinet. (In the United Kingdom, for example, the tradition whereby it is the prime minister who requests a dissolution of parliament dates back to 1918. Prior to then, it was the
entire government that made the request. Similarly, though the modern 1937 Irish constitution grants to the Taoiseach the right to make the request, the earlier 1922
Irish Free State Constitution vested the power in the
Executive Council (the then name for the Irish
cabinet).
Titles
A number of different terms are used to describe prime ministers. In Germany and
Austria the prime minister is actually titled Chancellor of Germany (
Bundeskanzler) while the Irish prime minister is called the Taoiseach. In many cases, though commonly used, "prime minister" is not the official title of the office-holder; the Spanish prime minister is the
President of the Government (
Presidente del Gobierno). Other common forms include
President of the Council of Ministers (for example in
Italy,
Presidente del Consiglio dei Ministri),
President of the Executive Council, or Minister-President. In federations, the head of government of subnational entities like states or provinces is most commonly known as the Premier,
Chief Minister or
Minister-president.
In non-Commonwealth countries the prime minister may be entitled to the style of Excellency like a president. In some Commonwealth countries Prime Ministers and former Prime Ministers are styled Right Honourable, for example, the Right Honourable Sir
John Major.
In the UK where devolved Government is in place, the leader of the Scottish Government is styled First Minister.
Chairman or chief?
Irish
political scientist Professor
Brian Farrell coined the term "Chairman or Chief" to describe the two alternative concepts of prime ministerial leadership, in his book of the same name about the office of
Taoiseach.Brian F. Farrell,
Chairman or Chief? The Role of Taoiseach in Irish Government (1971) The term, widely used in political science worldwide, draws a distinction between a head of government who is merely a facilitator and co-ordinator of a cabinet (the "chairman"), and those who lead it forcefully from the front, setting its policy agenda and requiring all ministers to follow the leader's policies (the "chief").Examples of "chairmen" have included Bertie Ahern (Ireland), John Major (United Kingdom) and Maurice Couve de Murville (France), while examples of chiefs included
Indira Gandhi and Atal Bihari Vajpayee ,Seán Lemass (Ireland), Margaret Thatcher and Tony Blair (United Kingdom), and Jacques Chirac when prime minister under
cohabitation.
Not every prime minister fits exclusively into either category: Éamon de Valera, though a strong personality, was only interested in controlling some of his government's agenda (usually constitutional matters and Anglo-Irish affairs), and allowed large areas to decided by his colleagues. Though superficially a chief (and called "the Chief" literal translation of
Taoiseach by his colleagues) historians see him as more of a chairman, particularly in later governments.
Winston Churchill too, though superficially a "chief", was more chairmanlike in later governments and in those areas in which he had little personal interest.
As well as describing office holders, individual offices could be described as belonging to one or other category. Among the more dominant prime ministerial offices in terms of powers, and so more chieflike, are the premierships of Ireland and Spain, where premiers can hire and fire at will. In contrast, offices such as President of the Executive Council of the Irish Free State, Prime Minister of the Third French Republic, and the premierships of Belgium and
The Netherlands are more chairmanlike in format. Lijphart referred to the premiership of the Netherlands as "
primus inter pares without due emphasis on
primus".Jean Blondel & Ferdinand Muller-Rommel (eds)
Cabinets in Western Europe Macmillan, 1993 edition. p.81.
Description of the role
Wilfried Martens, who served as Prime Minister of Belgium, described his role as follows:
First of all Prime Minister must listen a lot, and when deep disagreements occur, he must suggest a solution to the matter. This can be done in different ways. Sometimes during the discussion, I note the elements of the problem and think of a proposal I can formulate to the Council (cabinet), the Secretary taking notes. The Ministers then insist on changing commas and full stops. The Prime Minister can also make a proposal which leaves enough room for amendments in order to keep the current discussion on the right tracks. When a solution must be found in order to reach a consensus, he can force one or two Ministers to join or resign.Wilfried Martens, quoted in ibid.
==Lists of prime ministers==
prime minister
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