LAW

Comparative Constitutional Law

Constitutional Design: Presidentialism, Parliamentarism and Semi-Presidentialism

 Q1: E-TEXT
Module ID 6: Constitutional Design:
Presidentialism, Parliamentarism and Semi-presidentialism

Subject Name: Law

Paper Name: Comparative Constitutional Law

Module ID: 6

Pre-requisites: Knowledge of constitutional law, comparative law.

Objectives:
- Overview of various systems of governments and design choices in sharing of powers
between the legislature and the executive organs
- Comparative study of the presidential, parliamentary and semi-presidential models of
governments

Keywords: comparative constitutional law, comparative law, presidentialism,

parliamentarism, semi-presidentialism
 1. Introduction

A Constitution lays down the fundamental rules by which a society is governed. It

thereby empowers and limits the institutions that govern the society. A Constitution
embodies the institutional design that the Constitution makers wishes to entrench.
Hence we can say that the exercise of Constitution-making is ultimately about making
institutional choices: Which institution should be vested with the powers to govern
the society? What system of government can best serve the interests of the people?

Constitutions essentially represent certain fundamental values and seek to structure

the institutions of governance on the basis of these values. Constitution makers create
the institutions that govern human conduct on the basis of speculative predictions of
how institutions will function in relation to the people. Constitution making has
always been comparatively informed and the final document is usually arrived at after
considering the viability of various systems of governments (Ginsburg, 2012).

Constitutional Design has a fundamental role to play in the way a society is governed.
While a good constitutional design can facilitate democracy and control religious
conflicts, a bad design might result in democratic breakdown and communal conflicts.
Comparative studies of constitutional designs have found that the design laid out in
the Constitution have important effects on policy choices and outcomes (Congleton
and Swedenborg, 2006).

Hence, perhaps the most fundamental aspect of constitutional design is about

choosing the right institutional form of government: should the country have a
presidential system of government, a parliamentary system or a semi-presidential
system which is a hybrid system that combines aspects of parliamentarism with
presidentialism.
 2. Presidential System
A presidential system is a system of government where the head of government is
usually directly chosen by the people and is also the head of state. The president is the
head of the executive branch of the government and is clearly separate from the
legislative branch. The President has a fixed term in office and cannot be normally
removed by a vote of confidence in the legislature. Hence, the President is not
responsible to the legislature and cannot be removed from office by the legislature
except in extraordinary cases through methods like a motion for impeachment.

According to Giovanni Sartori (1994), for a system of government to be called a

Presidential system, it needs to meet the following 3 pre-requisites: the head of state is
popularly elected; parliament can neither appoint nor remove the government; the
head of state is also the head of the government. The President appoints the members
of the cabinet who serve at the pleasure of the president although the appointment of
certain executive posts may require the approval of the legislature. Neither the
President nor the members of the cabinet are members of the legislature. Hence the
executive branch (consisting of the president and the cabinet members) of the state is
clearly separate from the legislative branch.

The first modern Presidential System of government was the one established in the
United States of America with enactment of The Constitution of the United States in
1787. One of the reasons for strongly adopting a Presidential system was to ensure
that separation of powers- between the legislature, executive and judiciary- was
maintained in the context of the revolution against the concentrated power of the
British Crown. The founding fathers of the American Constitution drew heavily from
political thinkers like Locke and Montesquieu who advocated the need for a clear
separation of the executive and legislative powers of the state(Bellamy, 1996). Hence,
the American Constitution requires a member of Congress to resign if that person is
appointed to the cabinet.

In the Federalist Papers, a collection of 85 essays written by Alexander Hamilton,

James Madison, and John Jay promoting the ratification of the United States
Constitution, some of the justifications of keeping the Legislature and Executive
separate from each other was further expressed. In Federalist Paper no. 47 Madison
wrote that "the accumulation of all powers, legislative, executive, and judiciary, in the
same hands, whether of one, a few, or many, and whether hereditary, selfappointed, or
elective, may justly be pronounced the very definition of tyranny" (Madison, 1788).
This being one of USA’s foundational ideas, the presidential system was adopted
which had a clear emphasis on the separation of powers.

Other than US, many of the presidential systems have often been politically unstable
and authoritarian regimes. Countries with a presidential system of government
include: Argentina, Brazil, Chile, Cyprus, Indonesia, Kenya, Maldives, Mexico,
Myanmar, Nigeria, Paraguay, Philippines, United States and Zimbabwe.
 3. Parliamentary System
A Parliamentary system is a system of government in which the executive is chosen
by and responsible to a legislature and the head of state is usually not the head of
government. In a Parliamentary system the executive, consisting of the Prime
Minister and the cabinet, is collectively responsible to the legislature from which it
derives its democratic legitimacy. The parliament (the legislature) can be unicameral
or bicameral. The Prime Minister heads the cabinet and also usually selects its
members and allocates them a portfolio.

The Prime Minister and members of the Cabinet, in most countries with a
parliamentary system, are also members of the parliament. So a parliamentary system
is characterised by a fusion of the legislative and executive branches if the state.
According to Giovanni Sartori(1994) for a system of government to be called a
parliamentary system, it needs to meet the following criteria: the government must
only be appointed, supported, and dismissed by the parliament.

The modern concept of the parliamentary system of government can traced to the
system followed in early 18th century Britain. The parliamentary system of Britain,
which came to be known as the Westminster system(after the Palace of Westminster
where the parliamentary sessions were held) was followed in many countries in the
Commonwealth of Nations. The United Kingdom is a Constitutional Monarchy where
the King or Queen serves as the legal head of the state but only has ceremonial
powers (Bagehot, 1867). In republican democracies, a president usually is the head of
state and performs similar functions.

While the head of state normally appoints the head of government, the leader of the
party or the coalition with the majority of the seats in parliament, as per constitutional
convention, is usually appointed prime minister. If the party or the coalition which the
Prime Minister represents does not enjoy majority in the house, the government can
be brought down by a vote of no-confidence in the Parliament. Hence, in a
Parliamentary system, the government can only have a maximum term and not a fixed
term since the government can be brought down and parliament dissolved atany time.
(Bates and John, 1986)

The government is required to have the continued support of the popularly elected
chamber of the legislature and such a requirement is called the principle of
responsible government which aims to keep the executive accountable to the
legislature. If the cabinet cannot maintain the confidence of the legislature, it is
required by constitutional convention to resign. Then the popularly elected chamber
of the parliament gets dissolved and fresh elections are called again.

Countries that have adopted a parliamentary system of government include the United
Kingdom, other parts of Europe and many commonwealth countries which were
previously British colonies. Countries with some form of parliamentarism include:
Australia, Bangladesh,Canada, Denmark, Germany, India, Israel, Italy, Japan,
Lebanon, Malaysia, Spain, Norway and United Kingdom.
 4. Semi-Presidential System
A semi-presidential system combines some of the features of the presidential system
with that of the parliamentary system. In such a system of government, the President
is popularly elected and exists along with a prime minister and cabinet. Unlike a
Parliamentary system, the powers of the president are substantial and not merely
ceremonial. Unlike a Presidential system, the cabinet named by the president is
accountable to the legislature. The president usually has a fixed term in office while
the cabinet may be brought down by a vote of no confidence by the legislature.

The term semi- presidentialism was introduced by Maurice Duverger in a 1980

article, “A New Political System Model: Semi-Presidential Government”. According
to Duverger, a political regime can be considered as semi-presidential if the
constitution which established it combines three elements: “(1) the president of the
republic is elected by universal suffrage, (2) he possesses quite considerable powers;
(3) he has opposite him, however, a prime minister and ministers who possess
executive and governmental power and can stay in office only if the parliament does
not show its opposition to them” (Duverger, 1980, p. 166).

Robert Elgie has argued that the problem with Duverger’s definition is todetermine
what can count as “quite considerable” presidential powers. Instead he suggests that
we define semi-presidentialism as a system in which “a popularly elected fixed-term
president exists alongside a prime minister and cabinet who are responsible to
parliament” (Elgie, 1999; Elgie, 2007).According to O’Neil (1993), a semi-
presidential regime is one where executive power is divided between a president and a
prime minister, but where “the head of state wields real executive power over the
prime minister and cabinet”.

The semi-presidential system has a dual power structure whereby the executive power
is between the President who is popularly elected and the Prime Minister who is
elected by the legislature. Balance of power oscillates between the President and the
Prime Minister depending on whether or not the political party the President is from
has a majority in the Parliament. If the President and the Prime Minister are from
differing political parties, the President would be much more constrained to act. But if
the President is supported by the party that is in majority in the legislature, then
his/her position is much stronger while that of the Prime Minister becomes
considerably lesser (Duverger, 1980).

A classic case of a semi-presidential system can be seen in the constitutional design of

the current French fifth republic which replaced the parliamentary system of the
fourth republic in 1958. The fifth republic was founded by Charles de Gaulle who
served as the first president of France’s fifth republic from 1959 to 1969. It was
Duverger who highlighted the difference in France’s system and characterised it to
represent semi-presidential system. Prior to that, discussions of scholars such as Don
Price (1943) and Harold Laski (1944) on governmental systems were solely focused
on the parliamentary/presidential dichotomy (Elgie, 2009).

Countries that have adopted the semi-presidential system include countries from the
Western and Northern African region and other countries that have been inspired by
the French model. Countries that follow semi-presidentialism include: Algeria, Egypt,
France, Georgia, Mali, Portugal, Russia, Senegal, Sri Lanka, Syria, Tunisia and
Ukraine.
 5. Choosing the Right System of Government
The choice between various systems of governance- Presidential, Parliamentary and
Semi-Presidential- is a central question that dominates nations emerging out of non-
democratic systems. As America’s democracy is widely considered to be a success,
its presidential system of government has been promoted, by American foreign policy
makers and others, in new democracies that were emerging across the world in the
20th century, especially in Latin America. However, America is more an exception to
the rule since most of the democracies that endured are parliamentary democracies
and not presidential ones. As Sartori (1994) explains, “the American system works, or
has worked, in spite of its constitution—hardly thanks to its constitution.”

It was Juan Linz in the classic essay "Presidential or Parliamentary Democracy: Does
It Make a Difference?" originally written in 1985 (a different version of which
appeared as “The Perils of Presidentialism” in the Journal of Democracy in 1990) that
offered the most cogent critique of the Presidential system of government. According
to Linz (1990, 1994), the ideology of separation of powers, taken as Montesquieu’s
inflexible dicta, has been one of America’s most dangerous exports, especially in
Latin America. The adoption of such a system has resulted in repeated constitutional
crisis whereby elected presidents disband uncooperative congresses to install
themselves as dictators often with the aid of the military. In the article, Linz (1990)
put forward his finding very clearly “A careful comparison of presidentialism as such
with parliamentarism as such leads to the conclusion that, on balance, the former is
more conducive to stable democracy than the latter”.

Linz (1990) observes that the reason few long established democracies have
presidential systemsstems from the intrinsic defects of presidentialism. One of the
major problems Linz identifies with presidentialism is that in such a systemthe
president and assembly have competing claims to legitimacy. Since both derive their
power from the vote of the people “a conflict is always latent and sometimes likely to
erupt dramatically; thereis no democraticprinciple to resolve it." This is not the case
with a parliamentary system where the legislature can replace the government by
exercising a no confidence vote. Another issue with presidentialism, according to
Linz, is that the fixed presidential term entails a rigidity that makes adjustment to
changing situations extremely difficult. Unlike a parliamentary system which allows
for greater flexibility, in a presidential system even a “leader who has lost the
confidence of his own party ... cannot be replaced" (Mainwaring and Shugart, 1997).

Presidentialism, according to Linz (1990), "introduces a strong element of zero-sum

game into democratic politics with rules that tend toward a 'winner-take-all' outcome.
In a presidential system since only one person is elected as the executive, there is
indivisibility of power and such a system could favour the president to always come
from a same ethnic group. Whereas in parliamentarism, there is opportunity for
power-sharing and coalition-forming this allows the interests of many groups to be
represented.Linz also feels that the feeling of having the mandate from entire
population is likely to give a president a sense of power may make the president to be
intolerant of the opposition. And since presidents are not dependent on political
parties for their survival, they are more likely to govern in a populist, anti-
institutionalist fashion (Mainwaring and Shugart, 1997).

Alfred Stepan and Cindy Skach (1993) further showed that parliamentary
democracies had a rate of survival more than three times higher than that of
presidential democracies. They also found that presidential democracies were more
than twice as likely as parliamentary democracies to experience a military coup. Only
three presidential systems (Costa Rica, Venezuela, and Colombia) other than US have
had uninterrupted democracies for a continuous period of over 20 years.

Stepan and Skatch(1993) argue that while the essence of parliamentarism is mutual
dependence, which promotes reconciliation, the essence of presidentialism is mutual
independence, which promotes antagonism. Presidential systems have certain rigidity
between elections due to the fixed term the president enjoys while Parliamentary
systems are able to address serious conflicts by having a change of leader before the
completion of his/her term. While in a parliamentary system, if a political deadlock
occurs, there are constitutional methods like vote of no-confidence and calling of
fresh elections, in presidential systems the absence of these mechanisms make it
likely for the political leaders to look to military to break the deadlock.

As George Tsebelis (1995) argues, parliamentary systems promote more centralized

decision-making processes and administrative structures and also foster stronger
political parties. He explains this using the concept of who exercises “veto” over
whom- “in parliamentary systems the executive (government) controls the agenda,
and the legislature (parliament) accepts or rejects proposals, while in presidential
systems the legislature makes the proposal and the executive (the president) signs or
vetoes them”. Parliamentary system, being centered on political parties, fosters a style
of politics and policy making that is more institutionalized, whereas presidentialism,
being centred on individual politicians, fosters a more personalized style of leadership
and less established organizational entities.

Bruce Ackerman (2000) argues against the promotion of America’s presidential

system in other countries and instead supports the model of “constrained
parliamentarianism” followed in countries like Germany, Italy, Japan, India, Canada
and South Africa. Though he does support an independently elected presidency to
check a popularly elected congress as seen in the American system, he also rejects
Britain’s Westminster System that concentrates law-making power in one institution.
Instead he favours a “new separation of powers” found in constrained
parliamentarianism which checks the power of the executive and the legislature by
granting independence to other checking institutions like a constitutional court.

Separation of powers,argues Ackerman, actually empowers the role of a single

person, the President. Italso encourages crises in governability both during an impasse
or even when the president is supported by congress. But it still does not promote a
separation of powers that is based on functional specialization and hence
overpoliticizes public administration and erodes the rule of law. In constrained
parliamentarianism, no single institution is granted a monopoly over law-making.
While a democratically elected house is in charge of selecting a government and
enacting ordinary legislation, its power is checked and balanced by a series of
different institutions: the people acting through serial referenda, a constitutional court,
and a weak federal legislature.

Ackerman (2000) is also wary of the possibility of the “cult of personality” that,
according to Linz, dominates presidential systems. A very charismatic president who
is independently elected promotes the politics of a single personality. A
parliamentary system has better institutional settings to keep the personalistic
tendencies in check. However, a charismatic president, asserting that his/her election
represents a mandate for change, can confront a disunited legislature that opposes
president’s initiatives and call out the army to disband the squabbling
parliamentarians alternatively establish a new system of governance on the basis for a
call for national solidarity.

In a study conducted by John Gerring, Strom C. Thacker and Carola Moreno (2008)
using a global data set on policy outcomes, it was found that there existed a strong
relationship between parliamentarism and good governance. The study sought to
examine the relationship between a historical measure of parliamentary rule and 14
indicators of governance across three policy areas: political development, economic
development, and human development. It found that the executive in parliamentary
system of government had a possible role in achieving good governance, particularly
in the fields of economic development and human development.

Gerring, Thacker and Moreno (2008) list out a set of plausible reasons why
parliamentarism can lead to better governance- “stronger political parties, corporatist
interest organization, tighter principal– agent relationships within the various arms of
the bureaucracy, centralized (national-level) electoral accountability, the capacity for
flexible policymaking, a more institutionalized political sphere, and decisive
leadership.” According to the authors, the most important factor in making
parliamentary systems more reliable for good public policy is broadly its capacity to
function as a coordination device. Parliamentarism offers better ways of resolving
difficulties since it integrates a diversity of views while providing greater incentives
for actors to reach agreement. However, Jose Cheibub’s(2007) analysis has shown
that though there is a co-relation between presidentialism and regime failure, it’s
difficult to establish any causal connection. Cheibub argues that Constitutional design
is only an intervening variable whereas other unobservable factors such as the deep
structures of societies may have a larger role in determining outcomes (Ginsburg,
2012).

To explore whether the labels of presidential, parliamentary or semi-presidential

systems capture homogenous institutional configurations, Jose Cheibub, Zachary
Elkins and Tom Ginsburg (2014) evaluated 401 national constitutions written
between 1789 and 2006. The study revealed that there is a fair amount of within-type
heterogeneity within these categories with respect to important institutional attributes
and ironically its semi-presidential constitutions which has maximum internal
coherence out of the three. They conclude that more than knowing whether a
constitution is parliamentary, presidential or semi-presidential, for predicting a
constitution’s executive-legislative structure, it would be more helpful in knowing the
geographic region of the country or the period of time the constitution was written.
 6. India’s Constitutional Choice
On November26, 1949, when Constituent Assembly of India adopted the Constitution
of India, it made a clear institutional choice: that of having a parliamentary
democratic system in a federal framework. And on 13 of May 1952, the Members of
Parliament elected through the First General Elections in India’s history met for the
first time. According to Douglas Verney (1989), India, like Canada, follows a hybrid
system of government based on "parliamentary federalism" which combines two
classical models: British tradition, based on parliamentary supremacy and American
principles, with clear separation of powers and judicial review. This conceptualisation
is similar to the “constrained parliamentarism” system that Ackerman (2000) used to
characterise India’s constitutional system.

On 4th November 1948, Dr BR Ambedkar, chairman of the drafting committee of the

Constituent Assembly of India, introduced the Draft Constitution before the Assembly
in which he defended why India adopted a parliamentary system of government.
Ambedkar explained that both presidential and parliamentary systems are democratic
and the choice between the two is not very easy. According to him, a democratic
executive must satisfy two conditions:

1. It must be a stable executive

2. It must be a responsible executive

Ambedkar then explained that the difficulty in formulating a new Constitution is in

choosing a system of government that ensures both a stable and responsible
executive-

“Unfortunately,it has not been possible so far to devise a system which

can ensure both in equal degree. You can have a system which can give
you more stability but less responsibility or you can have a system, which
gives you more responsibility but less stability.The American and the
Swiss systems give more stability but less responsibility. The British
system, on the other hand, gives you more responsibility but less
 stability...The American executive is a non-parliamentary executive,
which means that it is not dependent for its existence upon a majority in
the Congress, while the British system is a parliamentary executive,
which means that it is dependent upon a majority in Parliament…
Looking at it from the point of view of responsibility, a non-parliamentary
executive being independent of Parliament tends to be less responsible to
the legislature, while a parliamentary executive being more dependent
upon a majority in Parliament become more responsible.” (CAD, Vol.
VII, 1948)

Another major difference between the parliamentary and presidential system which
Ambedkar identifies is regarding the time and agency for assessment of executive’s
responsibility.

“Under the non-parliamentary system, such as the one that exists in USA,
the assessment of the responsibility of the executive is periodic. It is done
by the electorate. In England, where the parliamentary system prevails,
the assessment of responsibility of the executive is both daily and
periodic. The daily assessment is done by members of Parliament,
through questions, resolutions, no-confidence motions, adjournment
motions and debates on addresses. Periodic assessment is done by the
electorate at the time of the election, which may take place every five
years or earlier.The daily assessment of responsibility that is not available
under the American system is it is felt far more effective than the periodic
assessment and far more necessary in a country like India. The draft
Constitution in recommending the parliamentary system of executive has
preferred more responsibility to more stability.” (CAD, Vol. VII, 1948)

In India, after independence, there has not been much debate on whether to reject the
parliamentary system of government for a new system. There was a major discussion
about shifting to a presidential system when India was under emergency between
1975 and 1977 under Indira Gandhi’s leadership. A paper advocating a presidential
form was prepared by AR Antulaybut ultimately when the Swaran Singh Committee
report was submitted in 1976,it declared that the parliamentary system wasbest suited
for the country since it “ensures greater responsiveness to voice of the
people”(Austin, 1999). Even when the “National Commission to Review the Working
of the Constitution” was set by AB Vajpayee-led NDA Government in February
2000, the terms of review stated that the commission examine how best the
Constitution can respond to the changing needs of efficient, smooth and effective
system of governance “within the framework of parliamentary democracy” (NCRWC,
2002).

Some of the more contemporary criticism of the parliamentary system has come from
BK Nehru (1992), ArunShourie(2007) and Shashi Tharoor (2011). Citing the instance
of paralysis of Parliament due to unruly MPs, Tharoor, Shourieand Nehruhave
separately argued that the parliamentary system borrowed from the British has
outlived its utility and advocated a shift to a presidential system like that of the US.
According to Tharoor, under the current system the main reason for entering
parliament is to attain governmental office and this has resulted in executive posts
being given to “those who are electable rather than to those who are able”. He argues
that under the present system dissension by a coalition party hampers “decisive
action” and holds the “executive hostage to the agendas of a range of motley
partners”. However it has been pointed out in a rejoinder (Idiculla, 2011), that most
of the major criticisms charged on the parliamentary system can be solved by making
changes to certain laws and practises, without completely abandoning the
parliamentary system.
 7. Summing Up
We can say that parliamentarism is a system of government in which the executive,
consisting of the prime minister and cabinet, is chosen by and responsible to the
legislature, whereas presidentialism is a system where law-making power is divided
between two separately elected bodies: the legislature and the president (Gerring,
Thacker and Moreno, 2008). And semi-presidentialism is a system of government
where executive power is divided between a president and a prime minister and the
cabinet named by the president is accountable to the legislature.

Choosing between these three systems of government is one of the most important
aspects of constitutional design. An examination of various countries reveals that
except America, most of the democracies that endured are parliamentary democracies
and not presidential ones. In fact, presidential democracies are more than twice as
likely as parliamentary democracies to experience a military coup. However, it’s
difficult to establish thatit’s the constitutional design of presidentialism that is
responsible for the country’s failure.

India’s parliamentary democratic system can be called “constrained

parliamentarianism” which differs from the classical Westminster model since it does
not concentrate law-making power in one institution and instead checks the power of
the executive and the legislature by granting independence to other institutions like a
constitutional court. While choosing between a stable executive, as witnessed in
presidential systems like US, and a responsible executive, as witnessed in
parliamentary systems like UK, India’s constitution makers preferred more
responsibility to more stability. Though there have been some debates on its
suitability for India, the parliamentary system is well-entrenched in India and is likely
to remain a permanent feature of Indian polity.
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