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1 Module 2 Lesson 3

Comparing Executives
Just like what was stated in the lesson on Legislatures, this material will not only supplement
your knowledge about the forms of government but will also challenge you to manifest your
understanding of the institutional approach as you apply it in analyzing the features and operation of
the executives across countries.

Learning Outcomes
1. apply your understanding of the institutional approach
2. differentiate the executives under parliamentary and presidential governments

Key Concepts to Understand


cabinet cabinet government chancellor democracy coalition government
cohabitation executive privilege head of government head of state
institutional presidency majority government ministerial government oversized coalitions
presidential government presidential monarch prime ministerial government semi-presidential executive
separation of powers

excerpt: Hague, R., Harrop, M. & McCormick, J. [2022]. Comparative government and politics: An introduction. 12th Edition. USA:
Palgrave.

The political executive is the core of government, consisting as it does of the political leaders
who form the top level of the administration: presidents, prime ministers, ministers, and
cabinets. The institutional approach to comparison focuses on the role of the executive as a
government’s energizing force, setting priorities, mobilizing support, reacting to problems,
resolving crises, making decisions, and overseeing their execution. Governing without an
assembly or judiciary is feasible, but ruling without an executive is arguably impossible. And in
authoritarian systems, the executive is often the only institution that wields true power...
It is … important to distinguish between two different roles carried out by executives: the
head of state (the figurehead representative of the state and all its citizens) and the head of government (the
political leader of a government). In presidential executives such as the United States, Mexico, and
Nigeria, the two jobs are combined in one office. In parliamentary systems, the prime minister or
chancellor is the head of government, while monarchs or non-executive presidents carry out the
role of head of state. In semi-presidential systems, the division of roles – as we will see – is
more complicated.

Head of state: The figurehead leader of a state, who may be elected or appointed, or – in the case of
monarchs – may inherit the position. The role is non-political and has many functions but few substantive
powers.

Head of government: The elected leader of a government, who comes to office because of the support of
voters who identify with their party and platform.

In liberal democracies, understanding the executive begins with the study of institutional
arrangements. Liberal democracies have succeeded in the delicate and difficult task of
subjecting executive power to constitutional constraint. The government is not only elected, but
remains subject to rules which limit its power; it must also face regular re-election…
The executives of liberal democracies fall into three main groups: presidential,
parliamentary, and semi-presidential. In all three types, power is diffused, and they can each be
understood as contrasting methods for dividing and controlling executive authority. These
2 Module 2 Lesson 3

arrangements can be tested against their contributions to political stability and effective
governance.
In presidential and semi-presidential regimes, the constitution sets up a system of
checks and balances between distinct executive, legislative and judicial institutions. In
parliamentary systems, the government is constrained in different ways, its survival depending
on retaining the confidence of the assembly. Typically, its freedom of action is limited by the
need to sustain a coalition between parties that have agreed to share the task of governing.

Presidential executives. The world contains many presidents but fewer examples of
presidential government. This is in part because many parliamentary systems possess a
president who serves only as ceremonial head of state, and in part because any dictator can
style themselves ‘president’, and many do so. For these reasons, the existence of a president is
an insufficient sign of a presidential system.

Presidential government: An arrangement in which power is divided between a president and a legislature.
This distinction is achieved by separate elections and also by separate survival; the president cannot
dissolve the legislature and the legislature can only remove the president through impeachment.

In essence, a presidential executive is a form of constitutional rule in which a single chief


executive governs using the authority derived from popular election, alongside an independent
legislature. The election normally takes the form of a direct vote of the people, with a limit on the
number of terms a president can serve. The president directs the government and, unlike most
prime ministers in parliamentary government, also serves as the ceremonial head of state. The
president makes appointments to other key government institutions, such as the heads of
government departments, although some may be subject to confirmation by the legislature.
Because both president and legislature are elected for a fixed term, neither can bring down the
other, giving each institution some autonomy.
Presidential executives have both strengths and weaknesses. Among the strengths are:
• The president’s fixed term provides continuity in the executive, avoiding the collapse
of governing coalitions to which parliamentary governments are prone; (can be
dismissed through impeachment).
• Winning a presidential election requires candidates to develop broad support across
the country.
• Elected by the country at large, the president rises above the squabbles between local
interests represented in the legislature.
• A president provides a natural symbol of national unity, offering a familiar face for
domestic and international audiences alike.
• Since a presidential system necessarily involves a separation of powers, it should also
encourage limited government and thereby protect liberty.
But presidential government also carries risks. Only one party can win the presidency;
everyone else loses. All-or-nothing politics can lead to political instability, especially in new
regimes. Fixed terms of office are inflexible, and the American experience shows that deadlock
can arise when executive and legislature disagree, leaving the political system unable to
address pressing problems. Presidential systems also lack the natural rallying-point for
opposition provided by the leaders of non-ruling parties in some parliamentary systems. In
particular, there is no natural equivalent to Britain’s notion of the Leader of Her Majesty’s
Opposition.
Under these circumstances, there is a danger that presidents will grow too big for their
boots. In the past, Latin American and African presidents have frequently amended the
constitution so as to continue in office beyond their one- or two-term limits. Even worse, a
3 Module 2 Lesson 3

frustrated or ambitious president can turn into a dictator; presidential democracies are more
likely than parliamentary democracies to disintegrate …
Presidential government predominates in the Americas, and is also found in many
African countries, such as Nigeria. The United States is the representative case, and as such
provides important insights into how the presidential executive works. The framers of the US
constitution wanted to create an office that could both make decisions and be prevented from
accumulating too much power…
In addition to a general obligation to oversee the execution of laws, the president is given
explicit duties (such as commander-in-chief) that have been interpreted over time as giving
presidents further implied powers. For instance, presidents can claim executive privilege: the
right to withhold information from Congress and the courts which, if released, would damage the
president’s capacity to execute the laws. Presidents can also issue executive orders,
statements, and proclamations. At the same time, they also often find their hands tied, because
they share important powers with Congress:
• The president is commander-in-chief but only Congress can declare war.
• The president can make government appointments and sign treaties, but only with the
consent of the Senate.
• The president can veto legislation, but Congress can override the veto.
• Congress, not the president, controls the purse strings.
Describing the relationship between the president and Congress as a separation of
powers is misleading, because there is in reality a separation of institutions: the two-share
authority, each seeking to influence the other but neither being in a position to dictate. In
parliamentary systems, prime ministers can normally rely on strong support in the legislature
from their party or coalition; this is rarely the case in presidential executives.

The separation of powers is the hallmark of the presidential system: executives have the power to lead and to execute,
legislatures have the power to make law, and courts have the power to adjudicate. While there is certainly an overlap in
practice, the focus of responsibilities is generally clear, and is typically reinforced by a separation of personnel. Neither the
president nor members of the cabinet can sit in the legislature, creating further distance between the two institutions.
Similarly, legislators must resign their seats if they wish to serve in the government, meaning the president’s ability to buy
members’ votes with the promise of a job is self-limiting.

Contrasting methods of election create a natural difference of interests. Legislators depend only on the support of
voters in their home district, while the president (and the president only) is elected by a broader constituency – typically,
the entire country. This divergence generates the political dynamic whereby the president pursues a national agenda as
distinct from the special and local interests of the legislature. So, despite the focus on a single office, presidential
government divides power. The system creates a requirement for the executive to negotiate with the legislature, and vice
versa, and thereby ensures the triumph of deliberation over dictatorship.

There is a practical separation of powers in parliamentary systems as well, in the sense that executive and
legislative functions are distinct. But members of the executive also sit in the legislature, and rather than legislators having
to resign in order to serve in government, occupying a seat in the legislature is all but a prerequisite to being appointed to
a top government job, such as the head of a government department. Above all, the very survival of the executive in a
parliamentary system depends on it retaining the legislature’s confidence.

The paradox of the American presidency – a weak governing position amid the trappings
of omnipotence – is reflected in the president’s support network. To meet presidential needs for
information and advice, a conglomeration of supporting bodies has evolved, including the White
House Office, the National Security Council, and the Office of Management and Budget.
Collectively, they provide far more direct support than is available to the prime minister in a
parliamentary system, forming what is sometimes known as the ‘institutional presidency’ ...
Relative to parliamentary systems, the US presidential system lacks a strong cabinet.
There is a federal cabinet, but it is not mentioned in the constitution, its meetings are usually
little more than a presidential photo opportunity, and cabinet members often find it hard to gain
access to the president through the thicket of advisers. …, presidential government is never
cabinet government as it formally is in parliamentary executives.
4 Module 2 Lesson 3

Cabinet: A body consisting of the heads of the major government departments. Sometimes known as a
Council of Ministers. More important in parliamentary than in presidential systems.

The norm in a presidential system is for the president to be elected separately from
the legislature. Presidential survival (if not success) is thus independent of party numbers in
the legislature, and the president is tied to a national constituency while members of the
legislature are elected from local districts. This is not how matters are organized in South Africa,
however, which offers an interesting variation on the theme of a presidential executive. It has a
president, but the officeholder is elected by members of the legislature rather than in a direct
national vote. This makes the South African president more like a prime minister in a
parliamentary system, particularly since the president is usually head of the largest party in the
legislature. However, the South African president is both head of state and head of
government, is limited to two five-year terms in office, and while required to be a member of the
legislature in order to qualify to be president, must resign from the legislature upon election as
president. Only two other countries – Burma and Botswana – use this system. Determining the
political impact of this rare format has been complicated by the dominance in post-apartheid
South Africa of a single party, the African National Congress. Were legislative elections to
produce no clear majority party, it would be interesting to see how the election of the president
would be affected.

Parliamentary executives. Unlike presidential systems, in which the chief executive is


separate from the legislature and independently elected, the executive in a parliamentary
government is organically linked to the assembly. The leader (the prime minister, or – in
Germany and Austria – the chancellor) is normally the head of the largest party in parliament (or
head of one of the parties in the governing coalition), continues to hold a seat in parliament
while also running the country, works in conjunction with a separate head of state who has little
substantive power, and is subject neither to a separate election nor to term limits. Most
government ministers are also members of parliament (although, in some countries – such as
Sweden – this dual mandate is not allowed). Like presidents, prime ministers make
appointments to other key government institutions, but these are rarely subject to confirmation
by the legislature. And in two other key contrasts with the presidential executive, a prime
minister can be removed from office as the result of a vote of no confidence, and can usually
call new elections before the full term of a legislature has run its course.
• Prime minister (or chancellor, premier) is normally head of the biggest political party in
the legislature.
• Governments emerge from the legislature and the prime minister can be dismissed
from office by losing a legislative majority or a vote of confidence.
• Executives can serve an unlimited number of terms in office.
• The executive is collegial, taking the form of a cabinet (or council of ministers) in which
the prime minister is traditionally first among equals. The cabinet typically contains
around two dozen members.
• Prime minister is head of government, working with a separate ceremonial head of
state.
• Examples: most European countries, Australia, Canada, India, Japan, New Zealand.
Parliamentary government lacks the clear focus of the presidential system on a single
chief executive, and instead involves a subtle and variable relationship between prime minister,
cabinet, and government ministers…
For advocates of the parliamentary system, cabinet government has the advantage of
encouraging more deliberation and collective leadership than occurs in a presidential system.
When Olsen … wrote that ‘a Norwegian prime minister is unlikely to achieve a position as
5 Module 2 Lesson 3

superstar’, many advocates of parliamentary government would have regarded his comment as
praise. Finland provides a clear case of cabinet government at work: by law, the Finnish
State Council (the cabinet) is granted extensive decision-making authority, prime ministers are
mainly chairs of Council meetings, and it is at these meetings that decisions are reached and
compromises made. Meanwhile, both the prime minister and individual ministers are subject to
constraints arising from Finland’s complex multi-party coalitions. But the system works best in
smaller countries; in many larger countries, the number and complexity of decisions means they
cannot all be settled around the cabinet table.
As regards prime ministerial government, the guiding principle is hierarchy rather than
collegiality. Germany has an arrangement known as a ‘chancellor democracy’ in which the
Bundestag (Germany’s lower house) appoints the chancellor, and accountability to the
Bundestag is mainly through the chancellor’s office. The chancellor answers to parliament, while
ministers answer to the chancellor. The strong position of Germany’s chief executive derives
from the Basic Law (the German constitution) which says that the ‘chancellor shall determine,
and be responsible for, the general policy guidelines’.
Several commentators suggest that parliamentary executives are moving in the direction
of prime ministerial government; prime ministers have ceased to be primus inter pares (first
among equals) and have instead become president-ministers. Writing of Canada, Savoie …
suggests that in setting the government’s agenda and taking major decisions, there is no longer
any inter or pares, only primus. Similarly, Fiers and Krouwel … argue that since the 1990s prime
ministers in Belgium and the Netherlands have acquired more prominent and powerful
positions, transforming these democracies into a kind of ‘presidentialized’ parliamentary
system. King … identified three factors at work: increasing media focus on the prime minister,
the growing international role of the chief executive, and the emerging need for policy
coordination as governance becomes more complex. A substantial prime minister’s office
reflects these distinctive responsibilities and reinforces prime ministerial authority.
The third type is ministerial government, which arises when ministers operate without
extensive direction from either prime minister or cabinet. This decentralized pattern can emerge
either from respect for expertise, or from the realities of a coalition. Looking again at Germany,
the chancellor sets the overall guidelines but the constitution goes on to say that ‘each Federal
Minister shall conduct the affairs of his department autonomously and on his own responsibility’.
Ministers are appointed for their knowledge of the field and are expected to use their
professional experience to shape their ministry’s policy under the chancellor’s guidance. So,
Germany mixes two models, operating ministerial government within the framework of
chancellor democracy.
In many coalitions, parties appoint their own leading figures to head particular ministries,
again giving rise to ministerial government. In the Netherlands, for instance, the prime minister
does not appoint, dismiss, or reshuffle ministers. Cabinet members serve with, but certainly not
under, the government’s formal leader. In these conditions, the prime minister’s status is
diminished, with ministers owing more loyalty to their party than to either the prime minister or
the cabinet. The chief executive is neither a chief nor an executive but, rather, a skilled
conciliator. In India’s multi-party coalitions, too, open defiance of the prime minister is far from
unknown ...
In Japan, too, ministers must often operate without strong guidance from the prime
minister. The prime minister is more like the keeper of the helm than captain of the ship and few
officeholders leave a lasting personal stamp on government. Turnover has been rapid: while the
United States had four presidents and Britain had four prime ministers between 1990 and 2015,
Japan had 14 prime ministers serving 21 terms among them, some of those terms lasting only a
matter of months. The comparison is with Italy … rather than the United States or Britain. In
Japan, limits are placed on prime ministerial power by the powerful bureaucracy and upper
legislative chamber, factions within political parties, other party leaders, and the consensus style
6 Module 2 Lesson 3

of Japanese politics. In particular, prime ministers from the leading Liberal Democratic Party are
limited by the requirement to secure regular re-election as party leader. Japanese prime
ministers are far from powerless, because they can – for example – hire and fire members of
the cabinet and all other senior members of the government. And reflecting the wider
international trend towards a focus on the prime minister, Shinzo Abe (prime minister, 2006–7, 2012–
2020) has achieved a higher domestic and international profile than most of his predecessors.
Even so, the contrast with, say, Germany’s chancellor democracy remains acute.
If the paradox of the presidential executive is weakness amid the appearance of
strength, the puzzle of parliamentary government is to explain why effective government can still
emerge from the mutual vulnerability of legislature and executive. The solution is clear: the party
provides the necessary unifying device, bridging government and legislature in a manner that
presidential systems are designed to prevent. Where a single party has a parliamentary
majority, government can be stable and decisive, perhaps excessively so. But majority
governments are increasingly rare, with the result that the typical parliamentary executive is a
coalition government or a minority administration. Looking in more depth at different kinds of
coalitions provides more insight into how parliamentary executives work.
Majority, coalition, and minority governments. In presidential and semi-presidential
systems of government, executives and legislatures are elected separately and have distinct
powers. The reach and authority of presidents is impacted by party numbers in the legislature,
but there is much that the president can do regardless. In parliamentary systems, by contrast,
the executive and the legislature are fused, and the power of the executive depends greatly
upon the party balance in the legislature. A prime minister whose party has a clear majority will
be in a much stronger situation than one governing a coalition or running a minority government.
For this reason, no review of parliamentary executives can be complete without taking each of
these variations into account.
Majority government. Britain is the classic example of parliamentary government based
on a single ruling party with a secure majority. The plurality (or winner-take-all) method of
election … usually delivers a working majority in the House of Commons to a single party, the
leader of that party normally becomes prime minister (PM), and the cabinet is made up of 20 or
so parliamentary colleagues from the same party. The cabinet is still the formal lynchpin of the
system: it is the focus of accountability to Parliament, formally ratifies important government
decisions, and coordinates the work of government departments. Its political support is essential
to even the strongest PM.
The key to the system’s stability is the party discipline that turns the cabinet into the
master of the Commons, rather than its servant. The governing party spans the cabinet and the
legislature, ensuring domination of the parliamentary agenda. The cabinet is officially the top
committee of state but it is also an unofficial meeting of the party’s leaders. As long as senior
party figures remain sensitive to the views of other Members of Parliament (MPs) (and, often,
even if they do not), they can control the Commons. The government may emerge from the
parliamentary womb but it dominates its parent from the moment of its birth.
How does the ruling party achieve this level of control? Each party has a Whip’s Office to
ensure that MPs vote as its leaders require. Even without the attention of the whips, MPs will
generally toe the party line if they want to become ministers themselves. In a strong party
system such as Britain’s, a member who shows too much independence is unlikely to win
promotion. In extreme cases, MPs are thrown out of their party for dissent and are then unlikely
to be re-elected by constituents for whom a party label is still key. Whatever their personal
views, it is in the interests of MPs to show public loyalty to their party.
Coalition and minority governments. It is quite usual in parliamentary systems
(particularly those using proportional representation, …) for no single party to win a majority
after an election. In this situation, the tight link between the election result and government
formation weakens, and government takes one of three main forms:
7 Module 2 Lesson 3

• A majority coalition government in which two or more parties with a majority of seats
join together. This is the most common form of rule in continental Europe.
• A minority coalition or alliance in which parties, even working together, still lack a
parliamentary majority. Minority coalitions have predominated in Denmark since the
1980s.
• A single-party minority government formed by the largest party.
These are common in Norway and Sweden.

Coalition government: An arrangement in which the government is formed through an agreement involving
two or more parties which divide government posts between them.

So unusual are single-party majority governments that many national constitutions


explicitly specify the hurdles a new government must clear before taking office. Some demand
that the legislature shows majority support for a new government through a formal vote of
investiture, a requirement that encourages the formation of a majority coalition with an agreed
programme.
Others, however, do not require a majority vote for a new administration. In Sweden, for
example, the proposed prime minister can form a government as long as no more than half the
members of the Riksdag object ... This requirement is to avoid majority opposition rather than to
achieve majority assent. Where constitutions say nothing on the procedure for approving a new
government, as in Denmark, the new administration takes office – and continues in power – until
and unless it is voted down by the legislature. These less demanding conventions facilitate the
formation and survival of minority governments.

Heads of state in parliamentary systems. No analysis of parliamentary executives is complete without


saying something about the distinction between the head of state and the head of government. The classic
analysis was offered by the Victorian British commentator Walter Bagehot (a one-time editor of The
Economist). In his book The English Constitution, he wrote of the two key elements of constitutions
(boldface added): first, those which excite and preserve the reverence of the population – the dignified parts,
if I may so call them; and next the efficient parts – those by which it, in fact, works and rules ... every
constitution must first gain authority and then use authority; it must first win the loyalty and confidence of
mankind, and then employ that homage in the work of government. …

Unlike presidential systems, which combine the offices of head of state and head of government,
parliamentary systems separate the two positions. Dignified or ceremonial leadership lies with the head of
state, while efficient leadership is based on the prime minister. Heads of state possess few significant
political powers, and their job is primarily non-political, and to act as a unifying influence. Prime ministers,
meanwhile, are the elected political leaders with executive power. This separation of roles creates more time
for prime ministers to concentrate on running the country, and also helps to separate government and state
in the public mind.

Heads of state are not entirely non-political, however, and sometimes play a role in the formation of
governments. In India, for example, the president had to oversee the formation of a caretaker government in
1979 that governed until new elections in 1980; stepped in on three occasions between 1996–7 to identify
the party leader best placed to form a new government following indecisive elections; and was involved in
2004 in naming Manmohan Singh as prime minister after Congress Party leader Sonia Gandhi turned down
the job. Heads of state are typically either monarchs who inherit their position, or presidents who are
appointed or elected ... Eight European countries – Belgium, Denmark, Luxembourg (a duchy), the
Netherlands, Norway, Spain, Sweden, and the United Kingdom – have a constitutional monarchy, while
Malaysia’s supreme head of state provides a rare contemporary example of an elected monarch. Some
former British colonies, such as Australia and Canada, have a governor-general who stands in for the
monarch. Most monarchs are reluctant to enter the political arena in democratic times, but royal influence
can occasionally be significant, especially in eras of crisis and transition. King Juan Carlos helped to steer
Spain’s transition to democracy in the 1970s, for example, while the King of Belgium played a conciliatory
role in his country’s long march to federal status between 1970 and 1993.
8 Module 2 Lesson 3

Elsewhere, heads of state in parliamentary systems are presidents, and are elected either through a
popular vote (e.g. Ireland), by parliament (e.g. Israel), or by a special electoral college, often comprising the
national legislature plus representatives from regional or local government (e.g. Germany).

In regard to timing, some coalitions are promised or arranged before an election is held,
helping voters to make a more informed judgement about the likely consequences of their voting
choices. Most often, though, the coalitions are arranged after the election, with the outgoing
government remaining as caretaker while negotiations are under way. Agreements can be
reached in a matter of days, but the more complex negotiations take longer: it took 208 days for
agreement on a new Dutch government in 1977, and a record 541 days (18 months) for a new
Belgian government in 2010–11.
It would be logical to suggest that coalitions will form between the largest parties in the
legislature, but this is rarely the case, and coalitions come in several different types. Most
contain the smallest number of parties needed to make a viable government, which is typically,
two to four. Party interests favour these ‘minimum winning coalitions’ (MWCs) because including
additional parties in a coalition which already has a majority would simply dilute the number of
posts and the amount of policy influence available to each participant.
In addition, coalitions are usually based on parties with adjacent positions on the
ideological spectrum. These ‘connected coalitions’ particularly benefit centre parties, which can
jump either way. In Germany, for instance, the small liberal Free Democrat Party has been a
part of most coalitions, sometimes with the leftwing Social Democrats and, between 2009 and
2013, with the more conservative Christian Democrats. Either coalition could be presented as
ideologically coherent. Germany, however, also has some experience of grand coalitions
between the two major parties, marginalizing the Free Democrats. When the Free Democrats
failed to win any seats at the 2013 election, Chancellor Angela Merkel’s Christian Democrats
took the decision to form a grand coalition with the Social Democrats.
Occasionally, ‘oversized coalitions’ emerge, containing more parties than are needed for
a majority. These arrangements typically emerge when the partners are uncertain about the
stability of their pact, or there is need to address policy problems of a kind where it makes
strategic sense to win the support of as many parties as possible. For example, when Hungary
was in the throes of its post-communist reforms, the 1994 election gave the social democrats an
absolute majority of 209 out of 386 seats. Even so, they invited the liberals ( with 70 seats) to join
them in an oversized coalition, and then launched an austerity programme that included
unpopular cuts in public sector wages and employee numbers. Because the government had a
broad-based coalition, its ability to impose unpopular policies in the interests of promoting the
market economy was strengthened …

Semi-presidential executives. The third major form of executive is a combination of the


presidential and the parliamentary, mixing both models to produce a distinct system with its own
characteristics, advantages, and disadvantages. In semi-presidential government (otherwise known
as a ‘dual executive’) we find both an elected president and a prime minister and cabinet accountable
to the legislature. The president is separately elected, and shares power with a prime minister
who heads a cabinet accountable to the legislature. The prime minister is usually appointed by
the president, but must have the support of a majority in the legislature. The president is head
of state, and shares the duties of being head of government with the prime minister; the
president has an oversight role and responsibility for foreign affairs, and can usually take
emergency powers, while the prime minister is responsible for day-to-day domestic
government. The president has more opportunity to play the role of head of state than is the
case with a presidential executive, but must also deal with a division of authority within the
executive that creates the potential for a struggle between president and prime minister.
9 Module 2 Lesson 3

Semi-presidential executives
• Combines an elected president and an appointed prime minister.
• President usually appoints the prime minister and can dissolve the legislature.
• President usually serves a limited number of fixed-length terms.
• Prime minister and cabinet are accountable to both the president and the legislature.
• President serves as head of state and shares the responsibilities of being head of
government with the prime minister.
• Examples: France, Mongolia, Russia, Sri Lanka, Ukraine, several former French
colonies in Africa.
The French political scientist Maurice Duverger … provided an influential definition of a
semi-presidential system:
A political regime is considered 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.

The ‘quite considerable powers’ of the president typically include special responsibility
for foreign affairs, appointing the prime minister and cabinet, issuing decrees and initiating
referendums, initiating and vetoing legislation, and dissolving the assembly. In theory, the
president can offer leadership on foreign affairs, while the prime minister addresses the needs
of domestic politics through parliament.
In cases where the president’s party has a majority in the legislature, the power
advantage lies with the president; the prime minister and the cabinet both follow the president’s
lead, and the prime minister promotes the president’s programme in the legislature. But when
voters give an opposition party a majority in the legislature, the president has no choice but to
work with a prime minister and cabinet from that party in an arrangement known as
‘cohabitation’. In such circumstances, the prime minister must cooperate with the president in
the national interest, but also becomes the leader of the opposition in what is, in effect, a grand
coalition. An ambitious prime minister can also use the position to build the foundations for later
contesting the presidency.
Shugart and Carey … distinguish between two kinds of semi-presidential government:
president-parliamentary and premier-presidential. In the former (found in Peru and Russia), the prime
minister and the cabinet are collectively responsible to both the president and the legislature,
meaning that they can be dismissed by one or the other. In the latter (found in France, Portugal, Romania,
and Ukraine since 2005), the prime minister and cabinet are collectively responsible only to the
legislature, meaning that while the president can appoint the prime minister and the cabinet,
they can only be removed from office through a vote of no confidence in the legislature. As a
result, the position of the president is weakened.
If the United States exemplifies the presidential system, France provides the archetype
of the semi-presidential executive. In an effort to move away from the unstable Fourth Republic,
which had seen 23 prime ministers in its short 12-year life, the 1958 constitution of the Fifth
Republic created a presidency fit for the dominating presence of its first occupant, Charles de
Gaulle (president, 1959–69). De Gaulle saw himself as a national saviour, arguing that ‘power
emanates directly from the people, which implies that the head of state, elected by the nation, is
the source and holder of that power’ ... The president has been directly elected since 1962, with
recent modifications introducing slight limitations. In 2000, the presidential term was reduced
from seven to five years, with a two-term limit following in 2008.
The French president is guarantor of national independence and the constitution, heads
the armed forces, negotiates treaties, calls referendums, presides over the Council of Ministers,
dissolves the National Assembly (but cannot veto legislation), appoints (but cannot dismiss) the
prime minister, and appoints other ministers on the recommendation of the prime minister and
dismisses them.
10 Module 2 Lesson 3

The main concern of French prime ministers is with domestic affairs, casually dismissed
by de Gaulle as including such mundane matters as ‘the price of milk’. Appointed by the
president but accountable to parliament, the prime minister formally appoints ministers and
coordinates their day-to-day work, operating within the president’s style and tone. The ability of
the assembly to force the prime minister and the Council of Ministers to resign after a vote of
censure provides the parliamentary component of the semi-presidential executive.
Presidents and prime ministers need to work in harmony, a task made easier when the
same party controls both branches of government. This is usually the case, but occasionally
France has gone through a period of cohabitation. Between 1986 and 1988, for example, the
socialist president François Mitterrand had to share power with the conservative prime minister
Jacques Chirac. The latter won the presidency in 1995, and was obliged in turn to share power
with socialist prime minister Lionel Jospin between 1997 and 2002. This arrangement intensifies
competition between the two principals, and places the president in the awkward position of
leading both the country and the opposition.
Beneath the president and prime minister, the government’s day-to-day political work is
carried out by 20 senior ministers, but the Council of Ministers is less significant than the cabinet
in parliamentary systems. Most modern French governments have been multiparty coalitions,
the Council of Ministers involves more ritual than discussion, ministers are more autonomous
because they often come to their job with a background in their given policy area, and
interventions by the prime minister and the president are often to resolve disputes, rather than
to impose an overall agenda.

Executives in Authoritarian Regimes. While constitutional rules and political realities


help define what a democratic executive can or cannot do, understanding executives in
authoritarian regimes is more complicated: although authoritarian regimes also have
constitutions and rules, their executives have far fewer constraints on their ability to execute
policy compared to their democratic counterparts, and with fewer formal protections their
personal safety is also often at risk. Although this produces an authoritarian executive, the
powers of the office should not be overstated: there are always limits on the powers of anyone
in government, but the powers of authoritarian leaders are often less a reflection of the terms of
the constitution than of the capacity of officeholders to manipulate the political system to their
own advantage (so long – of course – as they can remain alive). The case of President Déby of
Chad offers an example of a leader coming up against an extreme form of limitation on his term
in office.
There are two kinds of authoritarian executive: absolute monarchs and presidential
monarchs. In the case of the first of these, monarchs control government, tolerate little or any
opposition and ensure that the legislature and courts are weak. History is replete with examples,
from King Louis XIV of France (reigned 1643-1715) to Peter the Great of Russia (reigned 1689–1725),
and while the powers of today’s absolute monarchs may not be quite so complete, they are still
impressive. Current examples include King Mswati III of Eswatini in southern Africa, and Sultan
Hassanal Bolkiah of Brunei in Southeast Asia. In such cases, monarchs use a patriarchal style
that emphasizes ruling over governing.
The authoritarian executive
■ Most significant power focused in the office of the president or the monarch, the
officeholder often being more important than the office.
■ Absolute monarchs are mainly hereditary; presidential monarchs face elections, but
the outcome is usually assured by vote rigging, threats, and the marginalization of
opponents.
■ Limits on their terms in office are defined less by the constitution than by their capacity
to hold on to power and to remain alive.
11 Module 2 Lesson 3

■ All other government institutions are subservient to the executive, who typically uses
patronage to keep them malleable.
■ President or monarch serves as head of state and de facto head of government.
■ Examples: China, Cuba, Democratic Republic of Congo, Egypt, Kazakhstan, Saudi
Arabia, Venezuela.

The second and most common form of authoritarian executive is a presidential


monarch, or a president who functions more like a monarch. Such presidents lack most of the
constitutional and/or political limits of their democratic counterparts, including – in many cases –
term limits or the need to run in competitive elections. Even where term limits exist, a dominant
political party might be able to make sure that opposition candidates are unable to win office,
and sometimes dictators will change the rules so as to give themselves unlimited terms in office.
Authoritarian presidents go through the motions of running for re-election but are able to
manipulate the process – repressing their opponents and encouraging loyalty among their
supporters – in order to ensure themselves an unending string of victories. This happened with
President Déby, for example, who won elections in 1996 and 2001, and then arranged for the
elimination of term limits, winning re-election – in manipulated contests – in 2006, 2011, 2016
and 2021. By this means, a dictator creates a dictatorship.
Dictators lack the support of independent political authorities that would help them
enforce agreements, as well as the rules that govern the work of formal government institutions.
As a result, they might be inclined to use more extreme methods to win and wield power, but
they also often face greater personal risks than their democratic counterparts. They can use the
military to repress, for example, but once the military becomes essential to the survival of a
regime, it acquires leverage that it can use against the regime and might even turn against the
regime if pushed far enough.
Presidential monarchies provide a natural platform for leaders who want to set
themselves apart from – and above – all others. In such systems, presidents use what they
define as their direct mandate from the people to cast a shadow over competing institutions
such as the courts and the legislature. While they do not usually go so far as to reduce these
bodies to completely token status (they particularly need the courts and the bureaucracy to keep
things running), they work to concentrate power in themselves and their supporters rather
than to distribute it among institutions. It is this lack of institutionalization that is the central
feature of the authoritarian executive, and what we find in its place is the tradition of
personalism ...
While succession in most absolute monarchies is assured by heredity, incumbents in
several presidential monarchies have successfully groomed family members to succeed them.
However, the lack of a formal succession procedure can create a conflict among potential
successors not only after the leader’s exit, but also in the run-up to it. Presidential monarchs
keep their job for as long as they can ward off their rivals, which means that they must monitor
threats and be prepared to neutralize those who are becoming too strong.
Politics, as a result, comes before policy. The price of defeat, furthermore, is high;
politics in authoritarian regimes can literally be a matter of life and death. When the leaders of
democracies leave office, they can often give well-paid lectures, write and sell their memoirs for
large sums, be appointed to well-paid consultancies or set up foundations to do good works.
Ousted dictators risk a harsher fate, assuming they even live long enough to have a ‘retirement’.
The lucky ones might live in wealthy exile, while others languish in prison, and yet others are
executed on the street. It is hardly surprising, then, that the governing style of presidential
monarchs inclines to the ruthless.
Few dictatorships in recent history have collapsed so quickly into violent chaos as the
one in Libya. Ruled from 1969 by the autocratic and often eccentric Muammar Gaddafi, Libya
became a classic example of despotism. Gaddafi came to power in a military coup and never
12 Module 2 Lesson 3

put his leadership to the test of an election. When Libya broke down in civil war in February
2011, Gaddafi moved location in order to evade capture, but in late October that year he was
found hiding in drainage pipes on a construction site, where he was beaten to death. No
arrangements had been made for his succession, and only in 2015 did a UN–brokered
agreement result in the creation of a new government, but it failed to win general approval, and
a second civil war broke out. The Libyan case shows that government in an authoritarian regime
is often so closely tied to a single leader that the system falls apart after that person is gone.At
the same time, personalism is sometimes far from absolute, because many dictators find
themselves constrained by other political actors, including the military, leaders of ethnic groups,
landowners, the business class, the bureaucracy, multinational companies and even factions in
the leader’s own court. To survive, leaders must distribute the perks of office so as to
maintain a viable coalition of support, which is why personal rule is closely tied to corruption,
and the gallery of the world’s most corrupt leaders includes many who have held presidential
office in authoritarian regimes; examples include Ferdinand Marcos of the Philippines (1972–86;
elected in 1965, declared Martial Law in 1972), Mobutu Sese Seko of Zaire (now Democratic
Republic of the Congo) (1965–97), Suharto of Indonesia (1967–98), Zine Al-Abidine Ben Ali of
Tunisia (1987–2011) and Teodoro Obiang Nguema Mbasogo of Equatorial Guinea (since 1979).
Systems of personal rule have survived for centuries in the Middle East, limiting
the development of strong institutions. While the Arab Spring revealed the weaknesses of
dictatorships, as frustrated populations in several states protested against corrupt and
conservative regimes headed by staid autocrats, the challenges of switching from autocracy to
democracy were substantial. The problem was reflected in the case of Egypt, where President
Hosni Mubarak was ousted from office in 2011 in the wake of demonstrations against his 30-
year regime. In 2012 the country’s first-ever truly competitive elections resulted in the victory of
Mohamed Morsi, and there was reason to be optimistic for the country’s future.
However, because Morsi came from the Islamist Muslim Brotherhood, nervousness grew
abroad, particularly in the United States. When Morsi started showing signs of authoritarianism,
he was removed in a July 2013 military coup led by military chief General Abdel Fattah el-Sisi.
The general then reinvented himself as a civilian, turning in his military uniform for a two-piece
suit, won elections held in May 2014, and quickly showed an unwillingness to tolerate
opposition. After a brief and hopeful flirtation with democracy, Egyptian government was soon
back to its old ways. This was not what most Egyptians wanted, and opposition to the el-Sisi
regime grew, but Egypt’s other political institutions were too weak to resist a return to personal
rule, and el-Sisi was returned to office for a second term after March 2018 elections that were
widely condemned as fraudulent.
One variation on the theme of authoritarian executives is found in the five remaining
communist regimes: China, Cuba, Laos, North Korea and Vietnam. These are distinctive for the
way in which executive, legislative and judicial powers are intertwined with a one-party system,
such that leadership goes beyond simply holding executive powers. China has – at least until
recently – combined some of the formal features of a semi-presidential system with political
dominance by the Chinese Communist Party (CCP), but all is not as it might seem:

■ In spite of China’s intricate governmental structure (which includes a cabinet, a


legislature and a network of supporting agencies), these bodies do little more than
legitimize the decisions already taken by the party leadership …
■ Identifying who holds power is less a question of formal titles and offices than of
understanding links across institutions, personal networks and the standing of key
figures in the system. For example, Deng Xiaoping was ‘paramount leader’ of China
from 1978 until his death in 1997, yet the most senior posts he ever held were those of
party vice chairman and chairman of the party’s Military Commission. By 1993, the only
position of any kind that he held was the presidency of China’s bridge association.
13 Module 2 Lesson 3

Jiang Zemin may have been president of China and general secretary of the CCP, but
Deng was still the real power in China.

As China emerged out of isolation in the 1990s, changes to the rules seemed to be
headed towards producing an executive that looked in form more like some of its democratic
counterparts. At the apex was the president, who was nominated by the leadership of the
Chinese legislature (the National People’s Congress (NPC)) and then elected (or confirmed) by
the NPC for a maximum of two five-year terms. The presidency was, at first, mainly a
ceremonial head of state, but it had many conventional executive powers, such as the ability to
appoint (with NPC approval) all members of the State Council (the functional equivalent of a
cabinet). The officeholder was also conventionally head of the CCP and of the Central Military
Commission, posts that provided enormous political power. At the same time, the president had
to work with a premier, the de facto head of government and a senior member of the party
nominated by the president and confirmed by the NPC.
Matters changed after 2013, when Xi Jinping became president and exerted more
control over China, cracking down on dissent and corruption, supporting internet censorship and
advocating a more assertive foreign policy for China. In March 2018 he solidified his control by
arranging for the CCP to abandon a clause in the constitution limiting the president to two five-
year terms. The old days of the paramount leader of China are apparently back.
Military leaders are perhaps the ultimate form of the authoritarian executive,
combining as they do control over civilian and military institutions. They are currently
much less common than they once were, but even if full-fledged military leaders are unusual,
there are still many civilian leaders who rely for office on keeping the military happy. If great
power in democracies comes with great responsibilities, then power in dictatorships
comes with great risks, as illustrated by the case of Nigeria. Since independence in 1960, it
has had 15 leaders: six civilian presidents (two of whom were former military leaders who came
back to office as civilians) and nine military leaders. Of the 15, three were removed from office
through military coups in which the leaders were killed, and four were removed from office but
survived. All have had to keep a careful eye on critics within the military, who have always been
ready to organize opposition and, if necessary, a coup to remove the incumbent. Although they
do not always capture international headlines (because most countries and their media are only
interested in their major allies and their major enemies), authoritarian executives are more
common than their democratic counterparts. …, the Democracy Index in 2020 ranked 92
countries as hybrid or authoritarian regimes (compared to 75 full or flawed democracies), while
Freedom in the World ranked 49 countries as Not Free and another 63 as Partly Free. …

Enhancement Activity 1
(You are not required to submit your output)
Define the following:
1. Cohabitation
2. Executive privilege
3. Separation of powers
4. Semi-presidential executive
5. Chancellor democracy
6. Presidential government
7. Authoritarian executive
14 Module 2 Lesson 3

Enhancement Activity 2
(You are not required to submit your output)
Differentiate the following terms:
1. head of state vs. head of government
2. cabinet government vs. prime ministerial government
3. prime ministerial government vs. ministerial government
4. majority government vs. coalition government
5. president-parliamentary vs. premier-presidential
6. absolute monarch vs. Presidential monarch

Enhancement Activity 3
(You are not required to submit your output)
Use only the given material as your source in completing this comparative table.

COMPARING EXECUTIVES

Questions Presidential Semi-Presidential Parliamentary Authoritarian


Who is the head of state?
What is the method of selecting the head
of state?
What is the means of removing or
dismissing the head of state from office?
Does the executive serve in the
legislature?
Is the head of state given the power to
veto bills?
Is the head of state given the power to
formally dissolve the legislature?
Is there a separation of powers?

Who is the head of government?


What is the rule governing the selection of
the head of government?
What is the means of removing or
dismissing the head of government from
office?
What is the general role or obligation of
the head of government?

Does the appointment of secretaries/


ministers require approval from the
legislature?
Are elected legislators allowed to serve at
the same time as cabinet
secretaries/ministers?
Can the secretaries/ministers be removed
from office by the legislature?
What is the situation that requires the
formation of a ruling coalition?
What is the major political factor of stability
in the government?
Do the heads of state and government
belong to the same political party?

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