A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,U.S.

A AND INDIA

RESEACH PAPER

ON THE TOPIC

A Comparative analysis of federalism in Australia, U.S.A. & India

Submitted to
PROF. RAVINDER KUMAR,
Professor, University School of Law and Legal Studies
Guru Gobind Singh Indrapastha University (GGSIPU)
as a part of internal assessment for
CONSTITUTIONAL LAW-I (Code-106)
BBA LLB(Hons.)

By:
RIDDHISH V. SAMANTA (058)
&
KHANAK SUWASIA (033)

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 A comparative analysis of federalism in Australia, U.SS.A. and India

ACKNOWLEDGMENT

We would like to extend our deepest appreciation towards all the people who helped us
with the project.

We would especially like to thank our teacher, Prof. Ravinder Kumar Sir, for his sincere
guidance and being an inspiration through this journey.

We would also like to thank, Mr. Ankit Yadav, for his constant presence and guiding
force.

We express our heartful gratitude to Prof. Queeny Pradhan Singh, Head & Dean,
University School of Law and Legal Studies, Guru Gobind Singh Indrapastha University
and all the other faculty members for their encouragement.

This study has helped us explore more about this topic and has made us more
knowledgeable in many aspects.

THANK YOU
RIDDHISH V. SAMANTA
KHANAK SUWASIA
BBA LLB(H), 2ND Semester
 A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,U.S.A AND INDIA

TABLE OF CONTENTS

 ABSTRACT……………………………………………………4
 INTRODUCTION……………………………………………..5
 MEANING AND ORIGIN……………………………………6
 FEDERALISM IN AUSTRALIA…………………………….7
 FEDERALISM IN U.S.A……………………………………..9
 FEDERALISM IN INDIA……………………..……………11
 CONCLUSION………………..……………………………..13

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 A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,U.S.A AND INDIA

A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,

U.S.A. AND INDIA

ABSTRACT
This paper aims to increase our understanding and capture conceptual and analytical framework
that explains federalism. It further involves a comparative analysis between three federations –
the Indian, Australian and American. This study will help us understand in depth the meaning of
the term federalism and how it is embedded in our country and also inthe other two nations-
Australia and U.S.A.

The comparative scope of the study encompasses us to understand how the origin, type and
functioning of federalism have taken distinct forms and paths in different states depending on
situations. All defining characteristics are not found in every federation that we will discuss in
this paper. However, a written and rigid constitution, division of power, bicameral legislature,
the existence of dispute settlement mechanism, and two tiers of government have been found in
every state. Although these characteristics are found in every state we will further discuss how
the degree of rigidity of the constitution, distribution of powers between national and provinces,
the principles of the representation of states in the federal legislature, and functioning of the
dispute settlement mechanism varies from state to state.

The findings of this study are anticipated to yield valuable insights and enhance our
understanding. By drawing insights about the federal structure of different countries, the
research aims to widen our understanding and draw a comparison between the federal
structure ofthese states.

KEYWORDS: Federation, structure, principles, distribution of powers,Constitution.

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 A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,U.S.A AND INDIA

INTROUCTION

A state can be classified as federal or unitary based on the division of powers or absence of
division of powers, between the national and provincial governments. In a federal system, the
constitution formally divides the powers between the centre/national and states/provinces, whereas
in a unitary system, power is concentrated in the centre/national government, though it may
devolve certain powers to the local governments.

Federalism is an essential concept of comparative politics. Some scholars have also used
federalism to study regionalisation and regionalism in international politics and area studies. The
usefulness of federalism has been a debated issue. 1Federalism is the theory or advocacy of federal
principles for dividing powers between member units and common institutions. Unlike in a unitary
state, sovereignty in federal political orders is non-centralized, often constitutionally, between at
least two levels so that units at each level two levels so that units at each level have final authority
and can be self-governing in some issue area. Citizens thus have political obligations to or have
their rights secured by, two authorities. The division of power between the member unit and centre
may vary, typically the centre has powers regarding defense and foreign policy, but member units
may also participate in central decision-making bodies.

Much recent philosophical attention is spurred by renewed political interest in federalism and
backlashes against particular instances, coupled with empirical findings concerning the requisite
and legitimate basis for stability and trust among citizens in federal political orders. Philosophical
contributions have addressed the dilemmas and opportunities facing Canada, Australia, Europe,
Russia, Iraq, Nepal, Ethiopia and Nigeria, to mention just a few areas where federal arrangements
are seen as interesting solutions to accommodate differences among populations divided ethnic or
cultural cleavages yet seeking a common, often democratic, political order.

Federalism continues to play a crucial role in the modern times in addressing governance
challenges in diverse and decentralized societies. It allows for flexibility in policymaking, fosters
innovation and experimentation at the regional level, and can accommodate cultural and linguistic
diversity with a nation. However, federal systems also face challenges such as balancing power
between different levels of government, addressing inequalities among regions, and ensuring
effective coordination in areas of shared jurisdiction.

Overall, federalism remains a dynamic and evolving concept that continues to shape the structure
and function of governments worldwide. Its historical origins, theoretical underpinnings, an
practical applications make federalism a rich subject of study for researchers and policymakers
alike.

1
“Federalism (Stanford Encyclopedia of Philosophy),” November 2, 2022,
https://plato.stanford.edu/entries/federalism/.

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 A COMPARATIVE ANALYSIS OF FEDERALISM IN AUSTRALIA,U.S.A AND INDIA

FEDERALISM: MEANING AND ORIGIN

The word “federalism” has been derived from the Latin word foedus, which means treaty, contract
or compact. Thus, a federal state is seen as a compact or association of states/provinces due to an
agreement or treaty. It is an arrangement by which many relatively autonomous parts come
together to make a whole. It refers to a structurally and functionally divided government into
national governments and its constituent parts, called provinces or states. The political institutions,
their compositions and the functioning of federal states necessarily reflect this associated
relationship. Robert Garan has defined federalism as a “form of government in which sovereignty
or political power is divided between the central and provincial governments so that each of them
within its sphere is independent of the other”. William S. Livingstone defines federalism as a “form
of political and constitutional organization that unites into a single polity a number of diversified
groups or component politics so that the personality and individuality of component parts are
largely preserved while creating in the new totality a separate and distinct political and
constitutional unit”.
Most often, federalism comes into being through either of the two processes: centripetal and
centrifugal. In the centripetal process, the constituent units take the initiative in the formation of the
federation. The motive behind federation making may diverge from case to case. However, security
concerns of the constituent units and desire for economic prosperity are two main pull and push
factors in the centripetal origin of federalism. Independent states come together to form a
federation if they think they can maximize their security and achieve a high level of economic
prosperity by forming a federation than doing it alone. The US federalism is an excellent example
of the centripetal origin of federalism. In the early federation making process, the US federation
was formed when thirteen independent states expressed their consent to create a federation. Since,
the provinces have made US federalism, the national government cannot bring territorial changes
in provinces against their will.
Federation also come into being through a centrifugal process when the national government
initiates and gives designated powers to the provinces. In this process the central/national
government divides its territories into various province for administrative convenience or meets
people’s aspirations for a separate identity. India is an excellent example for this federation. The
present structure of the Indian federation is primarily a function of centrifugal tendencies working
in the Indian political system. In the Indian constitutional scheme, the central or union government
has the authority to draw state borders and create new states. The modern concept of federalism,
however finds its roots in the political theories of early modern thinkers such as Jean Bodin,
Johannes Athusius, and Montesquieu. These philosophers argued for a system of government that
balanced centralized authority with regional autonomy, believing that such a system would
promote political stability and protect individual liberties. The idea of federalism gained
prominence during the enlightenment era, particularly in the context of the American and French
Revolutions.
In the United states, federalism became a foundational principle with the drafting of the
constitution in 1787. The framers of the constitution sought to create a government that combined
elements of both centralized authority and states sovereignty. This resulted in a dual system of
governance where the federal government was granted specific power while the states retained
authority over areas not explicitly assigned to the federal government.

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FEDERALISM IN AUSTRALIA
2
Australian federalism came into existence on 1st January 1901, with six British colonies as its
constituents. However, deliberations about the establishment of a federation in Australia started in
the mid-Nineteenth century. Economic considerations were leading factors. New South Wales had
passed legislation establishing ―free trade between itself and New Zealand and Van Diemen ‘s
Land. Goods from elsewhere were subject to a tariff or import duty‖ (Brodie, 2012, 7- 8). The
province of Victoria was against free trade to protect its manufacturing sector. Security concerns
had a minor role in the making of the Australian federalism, perhaps because states were colonies
under the mighty British Empire and separated by large water bodies from other countries. In
Australian federalism, the province is called ‗state ‘, while the national government is known as
the Commonwealth of Australia’. Following are the noticeable features of Australian federalism.

Written and Rigid Constitution: The constitution of the Australian is the source of authority of
both the Commonwealth and states powers. That is, both the Commonwealth and states derive their
powers directly from the constitution. Australian constitution is also a rigid constitution. The
constitutional amendment requires the majority of voters ‘support at the national level in a
referendum and the majority of voters' support at least four out of the six states. As a consequence
of the complex amendment procedure, only eight out of thirty-six proposed constitutional
amendments could be passed in the referendum till now. The rigidity of the constitution provides a
de facto guarantee to states and the Commonwealth that their respective rights cannot be violated
unilaterally.

Division of power: The division of powers in Australian federalism is explicitly mentioned in the
constitution. Section 51 of the Australian Constitution states that the jurisdiction to make law on
the listed issues rests with the Australian Commonwealth. Forty subjects have been listed or
reserved for the Commonwealth. These include defense and external affairs; overseas trade and
commerce; immigration; trade; currency, and social functions such as marriage and matrimonial
causes. The rest or unlisted subjects, formally known as residual powers, rest with the states. The
states have exclusive rights to make laws on the residual subjects. In addition to the listed and
residual powers, the concurrent list identifies subjects over which both the Commonwealth and
states can legislate. However, in case of inconsistency between the Commonwealth and state laws,
the Commonwealth laws will prevail over the state laws.

Bicameral Legislature: Australian Parliament is made of the Crown and two chambers, namely,
the Senate and the House of Representatives. The Senate is made of 76 senators, while the House
of Representatives has 151 members. The states are represented in the Senate. For representation in
the Senate, the principle of equality is followed. Each state, irrespective of its population and
territory size, has been allotted equal twelve seats in the Senate. The mainland territories the
Australian Capital Territory and the Northern Territory- send two senators each. Of the twelve
members elected from every state through the proportional representation system for six years. The

2
Wikipedia contributors, “Federalism in Australia,” Wikipedia, November 6, 2023,
https://en.wikipedia.org/wiki/Federalism_in_Australia.

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151 members of the House of Representatives are elected for three years terms by the preferential
voting system.

Dispute Settlement Mechanism: In the Australian federal system, the Courts and inter-
governmental bodies play significant roles in resolving disputes between the states and national
government or between states. The High Court is the highest court in Australia. It has played an
essential role in sustaining federalism for over a century. According to Section 77 of the Australian
Constitution, the final court of appeal is in dispute between federal and state jurisdiction. It has the
authority to interpret the Constitution. The inter-governmental Councils and Committees
representing national and state governments such as Loan Councils, Premiers Conference, Special
Premiers Conference, and Council of Australian Governments manage federal relations.

The Australian Constitution established two levels of Australian government: federal, and
state/territory. 3Each level has different powers and responsibilities, which are outlined in the
Constitution.
The Federal government represents the whole nation. Its powers and responsibilities under the
Constitution include:
 Defence
 Foreign Affairs
 Immigration
 Post and Telecommunications
State and territory governments are responsible for making laws in any area not assigned to the
Federal government. These include:
 Hospitals
 Schools
 Emergency Services
 Public Transport
The third level of Australian government, local government, is not mentioned in the Constitution.
Instead, local governments are established in each state by a Local Government Act. These acts
delegate some state responsibilities to local government and give local government the power to
make and enforce by-laws.
Local government is designed to cater to specific local needs. These can include:
 Libraries
 Parks
 Waste disposal
 Community centres/services

3
“Federalism in Action: The Three Levels of Government – Parliament of New South Wales,” Parliament of New
South Wales -, n.d., https://education.parliament.nsw.gov.au/federalism-in-action-the-three-levels-of-government/.

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FEDERALISM IN U.S.A

Federalism is defined as, “a hybrid arrangement that mixes elements of a ‘confederation’ and a
‘unitary’ government.” 4A confederation is where you have a number of governments that come
together because of some need and attempt to work together. When we have a confederation, we
have authority being held by independent “states” through some kind of agreement. Under
confederations there may be a central government, but it only has the power that the individual
state governments give to it. The other concept mentioned in our first definition of Federalism was
a “unitary government.” When we talk of a unitary government we are talking about some kind of
central authority or government from where power is derived. Under unitary systems, laws created
by the central government are binding on everyone.

An easier definition for Federalism is, the sharing or mixing of power between a national
government and the state governments. The United States of America is a Federation where power
is shared between the 50 state governments and the national government in Washington, D.C. but it
was not always that way.

Today, in the United States of America, we see the concept of Federalism at work. We have a
central government in the nation’s capital (Washington, D.C.), and we also have fifty individual
states that have their own elected heads (the governors), their own lawmaking bodies (the state
legislatures) and their own court systems (the state courts) that interpret individual state laws. This
is why the laws in one state may be somewhat different from the laws in another state. This
division of power between the federal government and the individual states allows for a balance
between national unity and state autonomy. Each state has its own government structure, including
its own governor, legislature, and court system, which enables it to address the specific needs and
preferences of its residents. This system also means that laws and policies can vary from state to
state, reflecting the diverse social, cultural, and economic landscapes across the country. For
example, states may have different laws regarding issues such as taxation, education, healthcare,
and social welfare, based on their unique priorities and values.

Federalism in the United States provides flexibility for experimentation and innovation at the state
level, allowing states to serve as laboratories of democracy. It also fosters competition between
states, as they may implement different policies to attract residents, businesses, and investment.
However, federalism also presents challenges, such as ensuring consistency and coherence in areas
where federal and state laws intersect, and addressing disparities in resources and capacity between
different states. Despite these challenges, federalism remains a fundamental aspect of the American
system of government, shaping the relationship between the national government and the states
since the founding of the country.

Federalism is always at work in the United States. “In principle” if states, groups, or individuals
believe that there are problems with the laws created by the Congress, or being enforced by the
President, then the United States Supreme Court can step in and say whether those laws are

4
“Chapter Five: U.S. Federalism – U.S. Government and Politics in Principle and Practice,” n.d.,
https://usgovtpoli.commons.gc.cuny.edu/chapter-five-federalism-american-style/.

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Constitutional or Unconstitutional. Sometimes the Supreme Court weighing in on questions of

Federalism can advance social movements, as the court did in the 1946 Morgan v.
Virginia decision that rules that “states could not enforce segregation on interstate
busses.” However, in other cases, the Supreme Court has empowered states to pass abortion
bans to safely terminate their pregnancies by overturning Roe v. Wade (1973) in Dobbs v.
Jackson County Health Organization (2022). Additionally, the Supreme Court allowed for
restrictive voting laws that make it harder for poor people and minorities to participate in
democratic elections in Shelby County v. Holder in 2010 where the court stripped out a key
provision of the Voting Rights Act thereby allowing states to avoid federal oversight when making
their election laws.

The Evolution of U.S. Federalism

From its beginning in 1787 to the present day, two major political theories have developed around
the concept of Federalism. One theory is called “Dual Federalism.” The other theory is known as
“Cooperative Federalism.”
Dual Federalism: The beginning of the United States marks the beginning of Dual Federalism.
Under Dual Federalism, the Federal government and the state governments occupied “separate
spheres of influence.” The federal government had areas that it controlled and the state
governments had areas that they control. The federal government and state governments were co-
equal entities. Article I, Section 8 of the United States Constitution listed a number of things that
the federal government was empowered to do. The federal government could: tax, declare war,
establish foreign policy, regulate interstate commerce, make copyright and patent laws, establish
post offices, and coin money. More of this will be discussed below. Under this theory of Dual
Federalism, it was believed that the federal government could only operate based on those items
listed in the U.S. Constitution. As a result of this the states possessed a large amount of “reserved”
powers. The United States operated under a Dual Federalism model from 1787 until about 1937
when the federal and state governments began to intersect, and sometimes conflict with one
another.

Cooperative Federalism: From about 1937 to the present, the United States has operated under a
Cooperative Federalism model. Cooperative Federalism came about during the Great Depression,
beginning in the late 1920 and lasting through the 1930’s and early 1940’s, when so many
Americans were struggling to make ends meet. “In Principle” under Cooperative Federalism the
federal government and the state governments work collectively with one another to address
common problems. During the Presidency of Franklin D. Roosevelt (1933-1945), the federal
government began to get more involved in the day-to-day lives of U.S. citizens. During the FDR
Administration a federal jobs program was established to get Americans back to work; as was an
expansive social safety net to provide for people who fell on hard times, because many Americans
had fallen on hard times. With a more expansive role for the federal government, there became a
need for states and national authorities to work more in tandem with one another. However, with
the post-WWII phase of the Civil Rights movement on the horizon, the shift to Cooperative
Federalism set the stage for conflict as black activists pressured the federal government to enforce
racial justice initiatives in states, both North and South, that sought to maintain the structures of
segregation and white supremacy.

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FEDERALISM IN INDIA

India adopted its constitution on 26th January 1950. Although the Indian Constitution states that
―India that is Bharat shall be a union of states‖(Article 1) and nowhere mentions the word
‗federation‘ or ‗federalism‘, Dr B. R. Ambedkar asserted in 1948 that the ―Draft Constitution
could be both unitary as well as federal according to the requirements of time and circumstances. In
normal times, it is framed to work as a federal system. However, in times of war, it is designed to
make it work as a unitary system‖ (quoted in Tillin 2019). The following characteristics of
federalism can be identified in the Indian constitution.

Written and Rigid Constitution: The Indian constitution adopted in 1950 had twenty-two
chapters, 395 Articles and eight schedules. It is the source of states and central government ‘s
powers and authorities. The Indian constitution is a blend of rigidity and flexibility. In comparison
to the constitutions of the USA and Australia, the Indian constitution is flexible. However, on
issues related to centre-state relations, the constitution is rigid. Any constitutional amendment
affecting centre-state relations such as the division of powers and state ‘s representation in the
Parliament requires a majority of the total membership of the house and a majority of not less than
two-thirds of the members of the house present and voting. The amendment also requires to be
ratified by fifty per cent of state legislatures.

Division of Powers: The scheme of division of powers in the Indian federation is presented in the
Seventh Schedule of the Constitution of India. The constitution has three lists for dividing the
powers between the centre and states, Union, State and Concurrent lists. The Union list has 100
subjects over which the central government has exclusive jurisdiction. The State list has 61
subjects. The Concurrent list initially had 47 subjects over which both the central and state can
legislate. The Concurrent list has been enlarged to 52 subjects, with the 42nd Amendment of 1976
transferring five subjects from the State List to the Concurrent List. As in most constitutions, when
there is a conflict between central and state governments ‘laws, the centre‘s law prevails over the
state laws. The residual powers rest with the Centre.

Dispute Settlement Mechanism: The judiciary and inter-governmental bodies are two
mechanisms in the Indian federation to manage and resolve disputes between the centre and state or
between the two states amicably. The Supreme Court is the ultimate arbitrator in matters on centre
vs state and state vs state. The matters related to (i) the centre and one or more states (ii) centre and
state or states vs a state or states (iii) one or more state vs one or more states fall under the primary
jurisdiction of the Supreme Court. These issues can be directly taken to the Supreme Court. The
Supreme Court also has the right to interpret the constitution. Its power of judicial review functions
as a guarantee against the possible encroachment of powers and authorities of states by the centre.
The inter-governmental bodies prevent the conflict escalation and try to manage before letting them
explore or become disputes. Inter-State Council (Article 263) and National Development Council
bring central and state governments to a single platform to discuss their problems and issues.

Bicameral Legislature: Indian legislature known as Parliament is bicameral. The two chambers
are Rajya Sabha, the upper chamber and Lok Sabha, the lower chamber. In a bicameral legislature,
the Lok Sabha (People ‘s Council) represents the people across the country. In contrast, the Rajya
Sabha (Council of States) represents the states in the national legislature. Contrary to the Lok

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Sabha, whose members are directly elected by the people, the members of the Rajya Sabha are
elected by the state legislatures. The President nominates twelve members to Rajya Sabha for them
contributions towards arts, literature, sciences, and social services. Unlike the US, where all
provinces, irrespective of their size and population, are given equal seats in the Senate, in India all
states are allotted seats in the upper chamber according to their population. This is why the most
populated states of the Indian Union (Uttar Pradesh) have thirty-one seats in the Rajya Sabha while
the seven small states have only one seat each. Dual Government: in India, a central government
and state governments exist, each having its political institutions and processes. They have a
separate legislature, executive, and judiciary. The President is head of the Union of India, while the
Governor is the constitutional head of states. If the supreme court is India ‘s highest judiciary, the
High courts are the state ‘s highest judiciary. Establishing a distinct set of political institutions for
central and state governments has resulted in establishing two tiers of government in Indian
Federation, but unlike the US and Switzerland, there is only one citizenship, that is the citizenship
of India.
The Indian judiciary has time and again heard a number of cases involving the issue of the federal
character of the Indian constitution. To understand what it had to say I have collected a few cases
in a chronological order that will help in understanding the judiciary’s take on this. 5

State of West Bengal v. Union of India:

“The Constitution of India is not truly Federal in character. The basis of the distribution of powers
between the Union and States is that only those powers which are concerned with the regulation
of local problems are vested in the States and the residue, especially those which tend to maintain
the economic industrial and commercial unity of the country are left to the Union.”

State of Rajasthan v. Union of India:

“In a sense, the Indian Union is federal. But the extent of federalism in it is largely watered-down
by the needs of progress and development of the country which has to be nationally integrated,
politically and economically co-ordinated and socially, intellectually and spiritually uplifted. With
such a system, the States cannot stand in the way of legitimate and comprehensively planned
development of the country in the manner directed by the Central Government.”

State of Karnataka v. Union of India:

“The Indian Constitution is not federal in character but has been characterized as quasi-federal in
nature. Even though the executive and legislative functions of the Centre and States have been
defined and distributed, there runs through it all a thread or rein in the hands of the Centre in both
the fields. “

Kesavananda Bharati v. State of Kerala:

Some of the judges, in this case, held federalism to be a part of the basic structure of the
constitution which means it can’t be tampered with.

5
Pragya Bansal, “Federalism in India - Analysis of the Indian Constitution - iPleaders,” iPleaders, September 25, 2019,
https://blog.ipleaders.in/federalism-in-india/.

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CONCLUSION

Federalism has proved a valuable mechanism for power-sharing and conflict management in
diverse, plural and large societies. The origin, type and functioning of federalism have taken
distinct forms and paths in different states depending on situations. All defining characteristics are
not found in every federation studied in this unit. However, a written and rigid constitution,
division of power, bicameral legislature, the existence of dispute settlement mechanism, and two
tiers of government have been found in every state. Although these characteristics are found in
every state, the degree of rigidity of the constitution, distribution of powers between national and
provinces, the principles of the representation of states in the federal legislature, and functioning of
the dispute settlement mechanism varies from state to state in discussed cases. The functioning of
federalism has changed over a period. Different factors like ruling parties and ideology have
affected the functioning of federalism. As a consequence of changing role of ruling parties,
decisions of the courts and ideology, the functioning of the national and provincial governments,
federalism has taken distinct forms and patterns such as quasi federalism, cooperative federalism,
bargaining federalism, and competitive federalism. The forces of centralization and
decentralization have been competing for overall federal states.

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