Semi-parliamentary system
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Semi-parliamentary system is a system of government in which the legislature is split into two parts that are both directly elected – one that has the power to select and remove the members of the executive by a vote of no confidence and another that does not.[1] It is used is Australia on the federal and state level, as well as Japan on a national level. This variant of parliamentarism was identified and theoretically rationalised by German academic Steffen Ganghof. The Australian variant has also been called the "Washminster system" alluding to how it combines the strong bicameralism and separation of powers of the US presidential (congressional) system with the principle of parliamentary confidence from the lower house of the Westminster system.
The term "semi-parlamentary" was also previously used by Maurice Duverger to describe a prime-ministerial system, in which voters vote separately for both members of legislature and the prime minister, a system Israel used from 1996 to 2001.[2].
Definition
In the book "Beyond Presidentialism and Parliamentarism. Democratic Design and the Separation of Powers", German academic Steffen Ganghof gives this abstract definition of semi-parliamentarism:
Under semi-parliamentary government, no part of the executive is elected directly. The prime minister and cabinet are selected by an assembly with two parts, only one of which can dismiss the cabinet in a no-confidence vote even though the other has equal or greater democratic legitimacy and robust veto power over ordinary legislation.
— Steffen Ganghof, (2021) Beyond Presidentialism and Parliamentarism. Democratic Design and the Separation of Powers, Page 67, Oxford University Press
Rationale and variations
Ganghof argues the issues of a lack of separation of powers as present in a traditional parliamentary system and that of executive personalisation as found in a presidential system are confronted by dividing the legislature into 2 elected assemblies. One of these assemblies may be referred to as a "confidence chamber" that has the power to select and dismiss a prime minister and their ministers, while the other may be called a "legislative chamber". This chamber acts in a manner similar to that of the independent legislative branches that operate in presidential systems, able to introduce, amend and reject legislation, but unable to vote "no confidence" in the government.[1]
This form of semi-parliamentary government has also been further explored others[3], including Tarunabh Khaitan, who coined the phrase "Moderated Parliamentarism" to describe a form of semi-parliamentarism with several distinctive features: mixed bicameralism, moderated (but distinct) electoral systems for each chamber, weighted multipartisanship, asynchronous electoral schedules, and deadlock resolution through conference committees.[4] Ganghof's semi-parliamentary model has been highlighted as an alternative institutional solution to low-magnitude district proportional representation that may discourage unserious parties or candidates to run in the confidence chamber.[5]
It has been proposed that semi-parliamentarism may help moderate politics, however a potential challenge such a form of government may encounter is in sustaining the legitimacy of the second legislative chamber.[6] Sortition has been also proposed as a possible system for selecting members on the legislative chamber.
Countries
Semi-parliamentary systems exist in limited form (compared to its theory-driven archetype) in Australian states and on the federal level as well as in Japan.[7][8][9]
Australia
Regarding Australia, the system has also been referred to as the "Washminster system", alluding to how it combines the strong bicameralism and separation of powers of the US presidential (congressional) system with the principle of parliamentary confidence of the Westminster system. Australian constitutional law is, in many respects, a unique hybrid with influences from the United States Constitution as well as from the traditions and conventions of the Westminster system and some indigenous features. Australia has a fully elected upper house, the Senate, which must pass all its legislation, and the government is formed in the lower house, the House of Representatives, making it, in principle, semi-parliamentary.[10][11][12][13][14][15] Ganghof has argued that semi-parliamentarism in practice falls short of the archetypal concept, when the second legislative chamber has deficiencies in democratic legitimacy (compared to the confidence chamber), such as malapportionment (in Australia, this comes from the enshrined federal structure of the Senate), and longer terms of office.[16]
The Australian Senate is unusual in that it maintains an ability to withhold supply from the government of the day – a power similar to that held in the UK until 1911 by the House of Lords, which has since then been impossible, in the Westminster system. Some political scientists have held that the Australian system of government was consciously devised as a blend or hybrid of the Westminster and the United States systems of government, especially since the Australian Senate is a powerful upper house like the US Senate; this notion is expressed in the nickname "the Washminster mutation".[17] The ability of upper houses to block supply also features in the parliaments of most Australian states.
Prime-ministerial systems
In his 1956 proposal, Maurice Duverger suggested that France could attain government stability by means of a direct election of the Prime Minister, that was to take place at the same time as the legislative election, by means of a separate ballot paper. The Prime Minister and his supporting parliamentary majority would need to be inseparable for the whole duration of the legislature: in case of a vote of no-confidence, forced resignation, or dissolution of the parliament, a snap election would be held for both the National Assembly and the Prime Minister.
Under Charles de Gaulle, France adopted a different variant of the parliamentary government, since called semi-presidential system. Duverger's proposal thus remained unnamed until the French political scientist termed it "semi-parliamentary" in 1996. After Israel decided to abolish the direct election of prime ministers in 2001, there are no national prime-ministerial systems in the world; however, a prime-ministerial system is used in Israeli and Italian cities and towns to elect mayors and councils.
See also
- List of countries by system of government
- List of political systems in France
- Parliamentary system
- Presidential system
- Semi-presidential system
References
- ^ a b Ganghof, S (May 2018). "A new political system model: Semi-parliamentary government". European Journal of Political Research. 57 (2): 261–281. doi:10.1111/1475-6765.12224.
- ^ Duverger, Maurice (September 1996). "Les monarchies républicaines" [The Republican Monarchies] (PDF). Pouvoirs, revue française d'études constitutionnelles et politiques (in French). No. 78. Paris: Éditions du Seuil. pp. 107–120. ISBN 2-02-030123-7. ISSN 0152-0768. Archived from the original (PDF) on 1 October 2018. Retrieved 10 September 2016.
- ^ Tong, Zhichao (2026-01). "Designing Confucian democracy: A semi‐parliamentarian framework". American Journal of Political Science. 70 (1): 188–201. doi:10.1111/ajps.12941. ISSN 0092-5853.
{{cite journal}}: Check date values in:|date=(help) - ^ Khaitan, Tarunabh (2021). "Balancing Accountability and Effectiveness: A Case for Moderated Parliamentarism" (PDF). Canadian Journal of Comparative and Contemporary Law. 7: 81–155. Retrieved 3 September 2021.
- ^ Lovett, Adam. "The choice argument for proportional representation". American Journal of Political Science. n/a (n/a). doi:10.1111/ajps.12980. ISSN 1540-5907.
- ^ Birch, Sarah (2024-02-23). "Semi-parliamentarism and the challenges of institutional design". Critical Review of International Social and Political Philosophy. 27 (2): 266–273. doi:10.1080/13698230.2022.2159663. ISSN 1369-8230.
- ^ Ganghof, Steffen; Eppner, Sebastian; Pörschke, Alexander (2018-04-03). "Australian bicameralism as semi-parliamentarism: patterns of majority formation in 29 democracies". Australian Journal of Political Science. 53 (2): 211–233. doi:10.1080/10361146.2018.1451487. ISSN 1036-1146.
- ^ Ganghof, Steffen (2025-09-29). "Taking democracy seriously: A theory and global typology of democratic forms of government". Global Constitutionalism: 1–23. doi:10.1017/S2045381725100129. ISSN 2045-3817.
- ^ Smith, Rodney (2018-04-03). "New South Wales: an accidental case of semi-parliamentarism?". Australian Journal of Political Science. 53 (2): 256–263. doi:10.1080/10361146.2018.1451486. ISSN 1036-1146.
- ^ Aroney, Nicholas (2009). The constitution of a federal commonwealth : the making and meaning of the Australian constitution. Cambridge, UK: Cambridge University Press. ISBN 978-1-139-12968-8. OCLC 774393122.
- ^ Williams, George; Brennan, Sean; Lynch, Andrew (2014). Blackshield and Williams Australian Constitutional Law and Theory (6 ed.). Leichhardt, NSW: Federation Press. pp. 77–88. ISBN 978-1-86287-918-8.
- ^ Aroney, Nicholas; Kincaid, John. "Analysis | Comparing Australian and American federal jurisprudence". Washington Post. ISSN 0190-8286. Retrieved 2020-11-04.
- ^ James A. Thomson, American and Australian Constitutions: Continuing Adventures in Comparative Constitutional Law, 30 J. Marshall L. Rev. 627 (1997)
- ^ Zelman Cowan, A Comparison of the Constitutions of Australia and the United States, 4 Buff. L. Rev. 155 (1955).
- ^ Evans, Harry (December 2009). "The Other Metropolis: The Australian Founders' Knowledge of America". Papers on Parliament No. 52. Retrieved 2020-11-04.
- ^ Ganghof, Steffen (2021). Beyond Presidentialism and Parliamentarism: Democratic Design and the Separation of Powers. Oxford University Press. ISBN 978-0-19-289714-5.
- ^ Thompson, Elaine (1980). "The 'Washminster' mutation". Politics. 15 (2): 32–40. doi:10.1080/00323268008401755.
Further reading
- Khaitan, Tarunabh (2021). "Balancing Accountability and Effectiveness: A Case for Moderated Parliamentarism" (PDF). Canadian Journal of Comparative and Contemporary Law. 7: 81–155. Retrieved 3 September 2021.