[Advances in Political Science_ An International Series] Klaus von Beyme (auth.) - Parliamentary Democracy_ Democratization, Destabilization, Reconsolidation, 1789–1999 (2000, Palgrave Macmillan UK).pdf

Parliamentary Democracy
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Parliamentary Democracy
Democratization, Destabilization,
Reconsolidation, 1789–1999
Klaus von Beyme

Professor of Political Science
University of Heidelberg
Germany
in association with
INTERNATIONAL POLITICAL SCIENCE ASSOCIATION
First published in Great Britain 2000 by
MACMILLAN PRESS LTD
Houndmills, Basingstoke, Hampshire RG21 6XS and London
Companies and representatives throughout the world
A catalogue record for this book is available from the British Library.
ISBN 978-1-349-41911-1 ISBN 978-0-230-51439-3 (eBook)
DOI 10.1057/9780230514393
First published in the United States of America 2000 by

ST. MARTIN’S PRESS, INC.,
Scholarly and Reference Division,
175 Fifth Avenue, New York, N.Y. 10010
ISBN 978-0-312-22779-1
Library of Congress Cataloging-in-Publication Data
Beyme, Klaus von.
Parliamentary democracy : democratization, destabilization, reconsolidation,
1789–1999 / Klaus von Beyme.
p. cm. — (Advances in political science)
Includes bibliographical references and index.
ISBN 978-0-312-22779-1
1. Representative government and representation. 2. Democracy.
3. Comparative government. I. Series.
JF1051 .B49 2000

321.8'09'034—dc21
99–052085
© Klaus von Beyme 2000
Softcover reprint of the hardcover 1st edition 2001 978-0-333-77839-5
All rights reserved. No reproduction, copy or transmission of this publication may be made
without written permission.
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Any person who does any unauthorised act in relation to this publication may be liable to
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This book is printed on paper suitable for recycling and made from fully managed and sustained
forest sources.
10 9 8 7 6 5 4 3 2 1
09 08 07 06 05 04 03 02 01 00
Contents
List of Figures and Tables vii
Introduction 1
1 Parliamentary Government: the Rise of a Concept 4
2 The Parliamentarisation of Representative Governments 16

2.1 Waves of parliamentarisation of the executive 16
2.2 Parliamentarisation via the constitutional weapons
of parliament 18
2.3 Parliamentarisation and democratisation:
the struggle for universal suffrage and its impact on
parliamentary government 26
2.4 The parliamentary system and constitutional
engineering 31
2.5 Parliamentary government by the constituent
power of the people 35
3 The Organisational Basis of Parliamentary Sovereignty 38

3.1 Organisational autonomy 39
3.2 Non-hierarchical parliament 39
3.3 Non-hierarchical relations in two-chamber systems 41
3.4 Social equality among deputies and economic
independence 50
3.5 The rise of a new hierarchy in parliamentary work:
plenary and committee work 52
3.6 The steering function of parliamentary groups 64
4 Functions of Parliaments 72
4.1 Representation and articulation of interests 73
4.2 Controlling functions 81
4.3 The legislative function 88
4.4 The recruitment function 98
5 The Role of the Head of State in Relation to Parliament

and Government 108
5.1 The creation of a head of state 110
5.2 Cohabitation of presidential and parliamentary
majorities in semipresidential systems 111
v
vi Contents
5.3 Functions of the head of state in legislation 117

5.4 Functions in government building 122
5.5 Indications for government formation 128
5.6 The process of consultation on government formation 133
5.7 The head of state and the routine business of
government 135
5.8 The head of the state and the end of government 135
5.9 Dissolution of parliament by decree of the head of
state 136
6 The Government and Parliamentary Majority 149

6.1 Cabinet solidarity 149
6.2 The organisational power of government and the
proliferation of offices 150
6.3 Ministers without portfolio 154
6.4 Cabinet hierarchy and ministerial solidarity 155
6.5 The office of prime minister 157
6.6 The organisational basis of the prime ministerial
office 161
6.7 Coalition research in the light of rational-choice
approaches 163
6.8 Oversized coalitions 169
6.9 Undersized coalitions and minority governments 173
6.10 The dissolution of government by parliamentary
vote 178
6.11 Non-parliamentary reasons for government
termination 182
6.12 Conflict in the governing coalition as a reason for
government termination 186
6.13 Party systems and governmental stability 186
6.14 Reasons for government termination and
governmental stability 188
6.15 Alternating governments 194
7 Conclusions 198
7.1 The consolidation of parliamentary systems 198
7.2 Decline of parliament? The changing functions of
parliamentary democracy 211
Notes and References 217
Bibliography of Comparative Literature 240
Index 243
List of Figures and Tables
Figures
1.1 Degree of presidential power in semipresidential systems 13
3.1 Typology of networks 63
6.1 Party fragmentation and duration of governments,
1946–94 172
Tables
1.1 Forms of government and executive–legislative relations 6
1.2 Self-defined characteristics of parliamentary democracies 10
1.3 Typology of parliamentary, semipresidential and
presidential systems 14
2.1 Waves of parliamentarisation of the executive 19
2.2 Parliamentary means of ensuring the accountability of
government to parliament 21
2.3 Types of regime and the extension of suffrage 28
2.4 Participation in elections, 1850–1980 30
2.5 Electoral systems in Eastern Europe, 1995 32
2.6 Constitutions and parliamentary government 34
3.1 Opportunities for the opposition and government
backbenchers office to participate 42
3.2 One- and two-chamber systems and their relation to
federalism 45
3.3 Annual gross minimum pay of parliamentarians, 1996 51
3.4 Committees: legal framework and political competences 56
3.5 Frequency of recorded votes 70
3.6 Can MPs be removed from committees and/or stripped
of tasks? 70
4.1 Women in parliament and quota arrangements in EU
countries 77
4.2 Trust in institutions in parliamentary democracies 79
4.3 Voters’ esteem of parliaments 80
4.4 Parliamentary means of control 83
4.5 Ministerial accountability and duty to resign from office 86
4.6 Participation in legislation 89
4.7 Legislative output, 1978–82; 1980–89 in the lower house 93
4.8 The role of parliaments in government building 100
vii
viii List of Figures and Tables
4.9 Ministers’ career pattern in parliamentary democracies 106

5.1 Election of the head of state 112
5.2 The head of state and legislation 118
5.3 The head of state and government building 123
5.4 Dissolution of parliament 137
5.5 Early dissolution of parliament as indicator of a crisis 146
6.1 Typology of coalition systems in terms of multidimensional
policy space 166
6.2 Parliamentary basis of cabinets, 1945–94 171
6.3 Minority governments, 1945–87 176
6.4 Causes of government downfall, 1832–1939 183
6.5 Causes of government dissolution, 1831–1967 188
6.6 Causes of government dissolution in Western democracies,
1946–90 189
6.7 Duration of cabinets 191
6.8 Alternation of governments or coalitions 196
Introduction
Parliamentary democracy was a favourite subject of ‘grandpa’s political

science’. The old debates between Laski and Price on the virtues of par-
liamentarism versus presidentialism were forgotten until transitology
reintroduced them into the debate. 1 The debate on constitutional engi-
neering launched by Giovanni Sartori introduced a third, intermediary
type, the semipresidential system. This was more or less neglected in
the older debates because the types offered by Second French Republic
(1848–51), the Weimar Republic (1918–33) and Finland between the
two wars were hardly attractive alternatives. The approach of constitu-
tional engineering proved to be useful in cases of transitions from one
type of democracy to another, as for example in New Zealand, Israel
and Italy.2 It was less useful in the context of transitions from authori-
tarian state socialism to democracy because there were fewer options
open to the constitution makers. They were frequently dictated by the
necessities of modes of transition, the strength of the old and new
elites and the existence of a charismatic leader who was able to impose
a ‘designer’s democracy’ for himself, as Yeltsin did in the Russian con-
stitution of 1993. Semipresidential systems – which were created in
great numbers in Eastern Europe – despite the views of some writers are
a form of parliamentary democracy, and it is not by chance that they
are preferred in states with unsafe prospects for the consolidation of
democracy.
Parliamentary democracy is a product of the twentieth century and
was fully realised in most countries after 1918. There were, however,
some attempts to create such a system during the 1848 French revolu-
tion – without producing a consolidated system. What Huntington has
called the first long wave of democratisation (1828–1926) was in most
1
2 Parliamentary Democracy
cases parliamentarisation. 3 The ‘holy trinity’ of transitional stages in

the 1990s have been:
• Liberalisation.
• Democratisation.
• Consolidation.
However, in the case of parliamentary regimes that developed after the

French Revolution the sequence should read:
• Parliamentarisation.
• Democratisation (which frequently ended in destabilisation of the
parliamentary regime).
• Reconsolidation.
This sequence may be amplified as follows:
• The parliamentarisation and consolidation of parliamentary regimes fre-

quently took place on the basis of a dualistic system in constitu-
tional monarchies in the nineteenth century (Chapter 1).
• The democratisation of parliamentary regimes took place from the end
of the nineteenth century and culminated in universal suffrage in
most countries after the First World War (Table 2.3). This democrati-
sation destabilised most of the parliamentary regimes between the
two world wars. Quite a few systems perished, for example those of
Italy, the Weimar Republic, Austria and the Spanish Republic. Other
parliamentary regimes fell into deep crisis because of growing polar-
isation, such as those in France, Belgium and Finland.
• Only after 1945 did a reconsolidation of parliamentary democracy take
place. The second wave of democratisation in the twentieth century
was followed by a third wave in the 1970s in southern Europe and
by a fourth wave in Eastern Europe after 1989.
The historical study of parliamentary regimes has a wider focus for

transitology because it includes transitions from absolute monarchy,
constitutional monarchy or dictatorship to a parliamentary system
(Tables 1.1 and 2.1), while a comparative study includes the main
actors in parliamentarisation and democratisation.
• Parliaments (Chapters 2, 3, and 4).

• The head of the state (Chapter 5).
Introduction 3
• The executive (Chapter 6).
Parliamentary regimes are, however, characterised by cooperation

between various actors. The legislature and the executive are integrated
by another main group of actors that frequently did not feature in the
constitutions of older parliamentary systems: the parties (Chapter 3).
The more recent the historical focus the greater the range of parlia-
mentary systems (Chapter 6): 20 systems after 1945 but only eight
between the two world wars, six for the period 1884–1918 and only
two continuously working parliamentary systems from 1832 to 1918
(Britain and Belgium). Classification of the causes of government ter-
mination and patterns of coalition building nevertheless need
quantification in order to escape mere description.
1
Parliamentary Government: the
Rise of a Concept
A great assembly is as soon spoiled by overindulgence as a little

child. The whole life of English politics is the action and reac-
tion between the Ministry and the Parliament.
Walter Bagehot
The term ‘parliamentary government’ had hardly been accepted when

– following Bagehot’s seminal work on the English constitution (1867)
– the view was expressed that the British system was more a form of
executive government or prime ministerial government. Indeed parlia-
mentary government as a notion was vague. It was used synonymously
with ‘representative government’, which was even less precise: it
included the existence of representation but the notion did not indi-
cate whether it was a system governed mainly by the nobility, the
clergy and the estates (the commons, as in eighteenth-century Poland
and Sweden) or with a degree of participation by the monarch, as in
Britain, or a constitutional monarchy with clear dominance by the
monarch (as in most territories in the German confederation,
1814–66).
Parliamentary government as a notion presupposed a clear distinc-
tion between the form of the state (forma imperii) and the mode of gov-
ernment (forma regiminis). This distinction, arising in the period from
Bodin to Kant, overhauled the traditional Aristotelian typology of
regimes. Forms such as monarchy, aristocracy or democracy were of
secondary importance to the type of government, which hinted at the
mode of governance. The desired modern form of government – in
Kant’s work this was republicanism combined with representative gov-
ernment, while in Constant’s theory of the state it was constitutional
monarchy1 – had a higher systematic value than formal terms such as
4
Parliamentary Government 5
monarchy or democracy. Kant even called non-representative govern-

ment the ‘non-form’ of government (Un-Form), an abstract Germanism
that is hard to translate.
Most of the representative governments of the nineteenth century
were monarchies. The two major republican democracies – Switzerland
and the United States – were seen as an interesting anomaly. But repre-
sentative monarchies exhibited very different balances of power. Five
types can be discerned (Table 1.1):
• Regimes dominated by the estates in an electoral monarchy.

• Absolute monarchies, in which the estates were only called upon
when the monarch needed money.
• The continental regimes that prevailed during the restoration in
Europe (1814–48), which emphasised a neo-absolutist ‘Monarchical
principle’ with a constitution as an octroi by the monarch and domi-
nance by the monarch over the representative legislatures.
• Dualistic systems with a constitutional monarchy, extending from
Sweden down to Italy in the nineteenth century, with a balance
between monarch and parliament. These did not represent, as some-
times thought, a ‘special road’ (Sonderweg) of development in the
German-speaking monarchies.
• Finally, a parliamentary system with clear dominance by the
legislature.
Not all systems went through all five stages. Many countries did not
experience the first phase: dominance by the estates. Oddly enough it
can be said that the progression to parliamentary government needed
an absolutist system. Where the monarch remained captive in the
hands of the estates, such as in Poland, the regime eventually collapsed
and never developed parliamentary government. Even Sweden needed
a neo-absolutist phase in order to make parliamentary dominance pos-
sible in the long run. Dominance by the estates during the time of
liberty (frihetstiden) in the eighteenth century was marked by a lack of
the concentration of power that even a parliamentary government
needed. 2
All five regimes can be classified in terms of legitimation, the posi-
tion of the representative assembly, the constitutional regulations, the
existence of ministries, the regulations of a monarchical veto, the right
to determine the state budget, the nomination of ministers, the com-
patibility of ministerial office and parliamentary mandate, and the pos-
sibility of dissolving parliament (Table 1.1).
Table 1.1 Forms of government and executive–legislative relations in monarchies 6
Constitutional monarchy
with parliament or new
Constitutional monarchy with estates with
The old estates Absolute-monarchy monarchical principle constitutionalism Parliamentary system
Legitimation of the Elected monarchy or Divine-rights Weakened political rights on Two legitimate dual Parliamentary
monarch commitment of an the part of the king powers recognition and rule
inherited monarch to of succession
‘capitulations’
Status of Theoretical primacy of Derivated position of Rights granted by the Original right of Parliament is the
representation estates, if necessary representation monarch representation institutional seat of
right of resistance the sovereignty of the
people
Constitutional rules Positive right, Monarch legibus Imposed constitution (octroi) Separation of Pouvoir constituant by
in regime customary law, solutus constitutional powers the people or their
natural law as a barrier representatives
Existence of a Individual councillors Occasionally a leading Government occasionally as Ministries with legal Joint parliamentary
ministry of the monarch statesman a product of the responsibility cabinet
organizational power of the
monarch
Chair of the None None Monarch (and chairman of a Monarch, rising Prime minister
executive ministerial council) distinction of a first
minister
Right to initiate Monarch, protection Monarch, petition of Monarch (veto if legislative Monarch and Parliament and
legislation of rights, petitions, estates initiative of parliament) legislature (king in government
Poland 1505ff, head of parliament)
state
Veto against laws of None None Absolute veto Mostly power of delay No veto, except in
legislature case of legal doubt
Summoning of Monarch and self- Monarch Monarch Monarch and self- Self-constitution of
representation constitution in case of constitution parliament
crisis
Table 1.1 continued
Constitutional monarchy
with parliament or new
Constitutional monarchy with estates with
The old estates Absolute-monarchy monarchical principle constitutionalism Parliamentary system
Budgetary rights Approval of budget Restricted budgetary Approval of budget Budgetary rights Parliamentary
through estates rights in times of become crucial for approval, preparations
crisis dependence of by executive
executive
Appointment of None Monarch Monarch Monarch de jure De jure monarch
ministers (exception: Sweden),
de facto leader of
parliamentary
majority
Dismissal of None Monarch Monarch Monarch de jure, in Monarch on the
ministers reality increasing advice of prime
influence of estates minister,
parliamentary
downfall possible
Compatibility of None None None In doctrine often Yes, with the
ministerial office opposed, but happened exception of some old
and mandate increasingly, most of constitutions
the time resignation (Netherlands, Sweden,
from mandate Luxembourg)
Vote of no- None None Petition of relieve of office Motion of disapproval Yes
confidence often ignored
Dissolution of No, but de facto yes Yes Yes Yes Yes, on advice of
parliament by prime minister
monarch (exceptions: Norway,
Israel)
7
The definition of parliamentary government – as the fifth stage of

development in government–parliament relations – was developed for
the transitionary British regime between the two parliamentary
reforms of 1832 and 1867. But even advocates of parliamentary
government, from Burke to Mill, continued to prefer the term ‘repre-
sentative government’. It has been said that the British knew how to
implement the new system but could not find a consistent theory –
whereas the French, from Montesquieu and de Lolme to Constant,
never managed to develop a parliamentary government but did
develop a fairly realistic theory of the English system. But paradoxi-
cally even Constant – frequently considered the great theoretician of
parliamentary government – did not accept all its features, such as the
vote of no-confidence, which was later considered the dominant
criterion for the system. Many advocates of the systems continued to
speak of ‘representative government’ or ‘constitutional monarchy’,
whereas its opponents tended to use terms such as ‘parliamentary
government’ or even ‘parliamentarianism’, for example the great
conservative Spanish politician and writer Donoso Cortés.3 Even the
torchbearers of the theory of parliamentary government did not
accept that parliament should govern.4 Foes and friends who
recognised the differences between parliamentary government and
traditional representative government looked for vague substitutes.
The term ‘Coburg-style government’ – as practised in Belgium (ruled
by Leopold of Saxony-Coburg-Gotha) and Britain under Queen
Victoria (Prince Albert was also a member of that central German
dynasty) – was used to describe the innovations in government–
parliament relations that took place when, during the crisis of 1834, a
conflict between the crown and parliament ended with victory by the
legislature.
On the continent the term parliamentary government was fre-
quently accepted during the regime of Louis-Philippe (1830–48),
who came to power by means of a parliamentary revolution. In
German treatises the term was used by conservatives such as Huber,
Stahl and Lorenz von Stein after its introduction by the liberal
Robert von Mohl. 5 French opponents of the new system used the
term ‘assembly government’ (gouvernement d’assemblée), which was
widely used for the regimes of the French Revolution between 1791
and 1799.
Revolutionary assembly government, however, was clearly distinct
from parliamentary government, with a tradition of checks and bal-
ances inherited from representative government, because:
• The ministers did not develop cabinet solidarity.

• The assembly hardly recognised any constitutional limits to the
power of the majority.
• The governments were mere delegates of the legislature with no
sanction against majority votes, such as the dissolution of parlia-
ment after a vote of no-confidence.6
If we look at the constitutions of parliamentary regimes and the way in

which they define themselves in the preamble or the initial articles we
are struck that parliamentary government plays a minor role. Regimes
of the Westminster model normally renounce of declarations on ‘goals
of the state’ and eternal self-definitions of the regime. Older monarchi-
cal constitutions such as those of Norway or Denmark emphasise
limited government. In constitutions after 1918 and 1945 the word
‘democratic’ is commonplace. Many of the more recent regimes were
inspired by the German Basic Law, which stresses the ‘social legal
state’. Federations emphasise federalism while centralised systems
stress indivisibility (France) or the unitary character of the state (the
Czech Republic). Only Luxembourg accepts the term ‘parliamentary
democracy’ (Article 1), while Sweden (Chapter 1.1) prefers a ‘parliamen-
tary state’ and Bulgaria defines its state as a ‘republic with a parliamen-
tary form of government’ (Article 1.1) (Table 1.2).
There are many types of parliamentary government, but most of
them have developed common institutional criteria:
• Compatibility of parliamentary mandate and ministerial office

(exceptions are the French Fifth Republic, Luxembourg and the
Netherlands) in order to guarantee close cooperation between the
parliamentary majority and the executive.
• Prime ministers are normally members of parliament.
• The government has to have the confidence of the parliamentary
majority. Ministerial responsibility is not defined in terms of legal
responsibility, as in dualistic constitutional monarchies. The gov-
ernment has to resign in the event of a vote of no-confidence
unless it chooses to ask the head of the state to dissolve parliament
in order to give the electorate the opportunity to resolve the
conflict.
• Parliament controls the government by raising questions, exercising
the right to interpellate and setting up of committees of enquiry,
which facilitate the decision about whether the strongest sanction –
a vote of no-confidence – should be used. This right is shared by
Table 1.2 Self-defined characteristics of selected parliamentary democracies
Federalism/
Form of state Form of government Type of state centralism
Austria Republic Democratic

Belgium See Art. 1 Federal
Bulgaria See Art. 1.1 Republic with
parliamentary form
of government
Czech Republic Republic Democratic Legal Unitary
Denmark See Art. 2 Limited monarchy
Germany See Art. 20 Democratic Social Federal
Finland Sovereign republic Democratic
France Republic Democratic Laicist, social Indivisible
Greece Republican Parliamentary
democracy
Hungary Republic Democratic Legal
Ireland See Arts 1, 5 Democratic Sovereign
Israel Preamble Democratic
Italy Republic Democratic
Japan See preamble Representative Sovereign
Luxembourg Grand duchy Parliamentary
democracy
Norway Monarchy Limited, inheritable
monarchy
Poland Republic Democratic Legal and social
Portugal Republic Democratic Legal
Russia Type of republic Democratic Legal Federal
Sweden See ch. 1,31 parliamentary
Slovakia See preamble Democratic
Spain Monarchy parliamentary Democratic legal
dualistic presidential systems, apart from the possibility of toppling

the head of government and his or her other cabinet.
• Some analysts have postulated as an essential feature a formal vote
of the government at its first meeting with parliament (investiture),
as in the French system under the Third and Fourth Republics and
in Italy, or even demanded the formal election of the prime minis-
ter, which was developed in the German Basic Law of 1949. Most
parliamentary regimes do not accept this condition.
• More widespread is acceptance that parliament should be dissolved
if the prime minister has lost the confidence of the parliamentary
majority. Sometimes this has not been instituted, for example in
Norway and Israel. In other cases the legal possibility of dissolution
has become inapplicable because it has been abused by unparlia-
mentary presidents, as in the Third French Republic.
Besides the minimal institutional criteria, certain social–structural fea-

tures are essential for the consolidation of parliamentary government:
• Organised parties to facilitate the building of parliamentary

majorities.
• Party-building to facilitate the development of cabinet solidarity.
• Development of the office of prime minister. In early systems where
the estates dominated, and even in certain absolutist monarchies,
the power centres – the estates or the crown – impeded the activities
of the first minister. A certain hierarchisation of the ministerial council
also strengthens cabinet solidarity.
• The existence of a loyal opposition.
• Development of a political culture favourable to appropriate parlia-
mentary behaviour and alternating government.
Not all these institutional criteria can be found in every type of parlia-
mentary system. Therefore subtypes have been proposed. Most ideo-
logical is the distinction between authentic British parliamentarism
and the allegedly ‘inauthentic’ parliamentary system of the French
type – close to revolutionary government. Latecomers to parliamen-
tarisation, such as Germany (1918) and Sweden (1917), have often
denounced the dangers of the French type, especially the German
school of Redslob.7
Oddly enough, France itself has reacted strongly against the short-
comings of the parliamentary system of the Third and Fourth
Republics. De Gaulle’s constitutional ideas, close to those of Carré de
Malberg and later developed by Michel Debré, were first pronounced in
1946 in the famous speech of Bayeux but failed to obtain a majority
when the Fourth French Republic was declared in 1946/47. But De
Gaulle got his revenge when the Fourth Republic collapsed and he was
able to shape the institutions of the Fifth Republic according to his
ideas. A new system was born that since Duverger has been called the
semipresidential system.
In spite of its name this was clearly a subtype of parliamentary gov-
ernment, though the double responsibility by parliament and the head
of the state – which existed in constitutional monarchies such as at the
regime of Louis Philippe – reemerged. But in the long run – probably
even in Russia after the ascendance of Yeltsin – the dominance of par-
liament in executive–legislative relations was reestablished. De Gaulle’s
new system was not new at all: it had developed as a republican type of
constitutional regime from 1848 (the Second French Republic,
1848–51) and reemerged in the Weimar Republic (1919) and Finland.

Semipresidential systems are not a mixed type, not even the three-
quarter presidential system that Yeltsin tried to develop. The backlash
of a humiliated legislature was felt in Russia in 1998 when Yeltsin was
forced to renounce Chernomyrdin and accept the parliamentary candi-
date Primakov.
Maurice Duverger was the first to classify the constitutional norm
and the institutional reality in the relationship between a president –
elected by the people – and the majority in the legislature. Roughly
three types can be discerned:
• Semipresidential systems in which the president has more power

de facto than de jure, as in France and increasingly during the
Weimar Republic.
• Systems in which de facto power and de jure power are in tune, as in
Finland and Portugal.
• Systems in which the president’s real powers are below the level of his
constitutional competences, as in Austria and Iceland (Figure 1.1).
Purely parliamentary systems, semipresidential and presidential

systems have developed distinctive features (Table 1.3).
The distribution of countries among the three types shows that there
is no purely presidential system in Europe, although Belorussia comes
close. Semipresidential systems presuppose the abolition of the monar-
chy, as in Germany and Finland after the First World War, and they
tend to be found in countries where there was no legitimised party
system to shape the regime, as in France in 1958 and after 1989 in
Eastern Europe.
On paper the old communist system was extremely parliamentary.
The head of state, from a legal point of view, was merely the parlia-
mentary chairman or the chairman of a collective presidium of the leg-
islature. After 1989 communists advocated the continuation of this
kind of system but anticommunist movements frequently espoused a
semipresidential system, such as Solidarity in Poland and in Lithuania
after Landsbergis. Only where communists still predominated after the
collapse of the old regime, as in Romania, did left-wingers advocate a
semipresidential system. In the process of consolidation the boundaries
between these forces were blurred: both right-wing leaders and left-
wing groups advocated a semipresidential system if this would serve to
strengthen their power station. That Mecîar in Slovakia did not trans-
form his parliamentary regime into a semipresidential system was only
According to In political
the constitution reality
1. France
1. Finland 2. Finland
2. Iceland
Ranking of countries 3. Weimar
3. Weimar
4. Portugal 4. Portugal
5. Austria
5. Austria
6. France
6. Ireland
7. Iceland
7. Ireland
Source: Maurice Duverger, Le système politique français (Paris: PUF, 1985, 18th
edn, p. 522)
Figure 1.1 Degree of presidential power in semipresidental systems
due to the fact that an appeal to the people promised uncertain results.
The road to democracy has been of secondary importance in postcom-
munist countries. The two countries that experienced a ‘negotiated rev-
olution’, Poland and Hungary, have chosen different systems: Hungary
chose a purely parliamentary system while Poland opted for a semi-
presidential type. There is, however, one striking trend: the greater the
number of floating voters and the less consolidated the parties, the
more likely it was that a semipresidential system was chosen. This was
even more the case when a charismatic leader was at the head of the
movement, such as Walesa, Landsbergis and Yeltsin. The semipresiden-
tial system ex post facto has been justified in a ‘Gaullist’ way: when
interest representation is diverse the popular elected president has to
serve as a representative of the ‘common good’.8
14
Table 1.3 Typology of parliamentary, semipresidential and presidential systems
Parliamentary system Presidential

Indicators Purely parliamentary Semipresidential system (US model)
President elected by the people No (exceptions: prime Yes Yes

minister elected by the
people in Israel)
Double executive leadership: Yes Yes No (exceptions in Latin
president and prime minister America)
Competences of president Mostly ceremonial Prerogatives (especially in Growing prerogatives
(or monarchical leader) foreign and defence policy)
Influence of head of state on Mostly restricted, occasionally Great Solely, with limitations of
the formation of government totally derived (Sweden) or senatorial consent
bound to duties of
consultation
Dismissal of government by No De jure in presidential Easier to fire than to hire
head of state against the will of parliamentary systems (Russia,
the majority in parliament Ukraine), de facto occasionally
in France and Poland under
Walesa
Collective council of ministers Yes Yes No
with solidarity
Compatibility of ministerial Yes (exceptions in old Not in France, but not inevitable No
office and mandate parliamentary monarchies: (A, Isl, Irl, PL)
NL, Lux, S)
Table 1.3 continued
Parliamentary system Presidential

Indicators Purely parliamentary Semipresidential system (US model)
Downfall of government by Yes, partly controlled Yes, controlled parliamentarism No

vote of no-confidence parliamentarism even Stronger (F)
Dissolution of parliament by Yes (except Norway), Yes, occasionally restricted (F) No
president or monarch occasionally strongly
restricted
Legislation by the people Possible More often than in purely Non-existent at federal
parliamentary systems level, but not inevitable
Problems with ‘cohabitation’ by Unproblematic Potentially explosive Normal with mid-term
representatives of different elections, moderated by
parties low party discipline
Compatible with federalism Yes, by second chamber Less favourable Fully compatible
Countries which after two Australia, Belgium, Canada, Austria, France, Finland, USA, variations in Latin
democratic elections are Denmark, Germany, Greece, Iceland, Ireland, Portugal, America
considered to be consolidated Israel, Italy, Japan, Russia,* Ukraine* (pres.
Luxembourg, Netherlands, parl.), Croatia,* Lithuania,
Norway, New Zealand, Spain, Poland, Romania,*
Sweden, Malta, Albania,* Yugoslavia* (parl. pres.)
Bulgaria, Estonia, Latvia,
Slovakia,* Slovenia, Czech
Republic, Hungary
* Doubtful cases.
** Prime minister elected by the people.
15
2
The Parliamentarisation of
Representative Governments
What is a democracy if not a third power which political

science has hardly defined and which I call ‘the controller’? It is
nothing but this power … to topple kings and specialists every
minute, if they don’t govern in the interest of the great major-
ity. This power was a long time exercised by revolutions and
barricades. Today it is exercised by interpellations.
Alain
2.1 Waves of parliamentarisation of the executive
Modern theories of transformation to democracy assume that after

authoritarian rule there is a phase of democratisation followed by the
consolidation of democracy. In the case of parliamentary government
this sequence should read: (1) parliamentarisation of representative gov-
ernments, (2) consolidation of parliamentary government and (3) (fairly
late in the twentieth century) democratisation. The third phase has quite
frequently caused a crisis of the consolidated parliamentary system.
In the literature three long waves of democratisation and two of
antidemocratic backlash have been identified: 1
1. First long wave: 1828–1926

First wave of antidemocratic backlash: 1922–1942
2. Second short wave of democratisation: 1943–1962
Second wave of antidemocratic backlash: 1958–1975
3. Third wave of democratisation: 1974 onwards
What Huntington has called ‘democratisation’ was at best parlia-

mentarisation and this began during the French Revolution (from
16
Parliamentarisation of Representative Governments 17
1791). There were few waves of democratisation in Europe in the nine-

teenth century. When parliamentarisation did take place the torch-
bearers of parliamentary government rarely demanded universal male
suffrage as the minimum criterion for democracy. When male suffrage
was granted, as in the revolutions of 1848, the regimes were short-
lived. Only in France after 1870, when the Bonapartist regime was
toppled, did a parliamentary regime develop based on universal male
suffrage. Parliamentary government tended to be promoted by small
and not very radical revolutions such as those in 1830 in France and
Belgium, 1871 in France and 1918 in Germany. Parliament seldom
proved to be the torchbearer of parliamentary dominance in situations
of ‘revolution without revolutionary masses’, as in the Cortes of Cádiz
in Spain (1808–12).2 In the great revolutions, such as those under Pym
and Hampden in England and Mirabeau in France, parliament lost
control of the transformation process. Even in moderate revolutions
such as that in Germany in 1918, when the Imperial Diet tried to keep
its mandate, moderate torchbearers among the social democrats, such
as Friedrich Ebert, refused this claim.
Revolutions rarely led to representative government because parlia-
mentary government was not an idea that could mobilise the dis-
satisfied masses. As the German liberal Friedrich Naumann put it : ‘The
people say “why should we fight for a parliamentary regime since we
don’t know how efficient it will be?”.’3 A new governmental system was
frequently only a secondary goal of the revolutionaries. Rather it devel-
oped after the revolution, mostly as a compromise between the left and
right in a newly elected national assembly. When the left was strong –
as in Russia after the dissolution of the last duma before the revolution
in 1917 – and Liberals were not willing to assume the leadership of a
revolutionary parliament, democrats lost the opportunity to control
the transformation of parliamentary government into democracy.
It was not full-scale revolutions but rather breaks in legitimacy that
promoted parliamentary government, such as the Glorious Revolution
of 1688 in England and the French Revolution of July 1830. The
Belgian ‘revolution’ against the ‘Netherlandisation’ of the Catholic
south in 1830 was merely a political revolution that enhanced parlia-
mentary government. Similarly the breakdown of monarchical unions
in which the junior partner felt alienated, as in the case of
Luxembourg against the king of the Netherlands and Norway against
the king of Sweden, created favourable conditions for a parliamentary
regime. Hungary did not follow this pattern and instead fought in
1867 for greater autonomy within the Habsburg Empire.
Parliamentary majorities in the nineteenth century often fought for

parliamentarisation of the monarch’s executive, but they preferred to
take legal measures rather than resort to revolution. Such measures
included lodging accusations of illegal acts on the part of ministers,
refusing to vote for the government’s budget and initiating a vote of
no-confidence in the government. Waves of parliamentarisation
occurred more frequently than those of democratisation. From the
seventeenth to twentieth century there were nine waves of parliamen-
tarisation (Table 2.1).
The consolidation of parliamentary government preceded democra-
tisation and frequently involved conflicts that did not threaten the
political regime as a whole. In most cases parliamentarisation hap-
pened in systems that already had some kind of elected representa-
tion. Only rarely in the nineteenth century did a dictatorship try to
survive by accepting parliamentary government within the old
regime, as did Napoleon I during the 100 days after his return from
Elba in 1814 and Napoleon II in the so-called Empire libéral of
1869–70. Neither attempt was able to save the dictablanda (smooth
dictatorship), which tried to abandon dictadura (hard dictatorship), to
use a play on words that is only possible in Spanish. Dictatorships in
the twentieth century were brought to an end either by military over-
throw (the fascist regimes) or by more or less peaceful revolution
(communist regimes). Spain in the last phase of the Franco regime and
the Soviet Union in the last phase of perestroika were the only two
examples of dictatorships attempting to develop a more representative
system (mostly with corporatist elements that strengthened not indi-
vidual voters but large associations).
The most direct attempts to establish parliamentary government were
accompanied by the battle for universal suffrage in the fifth and sixth
waves of parliamentarisation. Another pattern was parliamentarisation
via the exercise of the constitution-making power of the people – which
corresponded to the second and fourth waves, and occasionally to the
third (Belgium). In the twentieth century this became the normal
pattern in all four waves of democratisation (waves six to nine of parlia-
mentarisation, from 1918, from 1945 during the 1970s and from 1989).
2.2 Parliamentarisation via the constitutional weapons of

parliament
There have been five types of representative or quasi-representative

system in Europe (Table 1.1). The fourth system, a dualistic regime with
Table 2.1 Waves of parliamentarisation of the executive
1 Parliamentarisation of the system of estates England from 1688

2 Revolutionary regimes France 1789–92
Main problem: compatibility of ministerial office and mandate: veto of king Spain from 1808
3 Regime of restoration France from 1814 and 1830
Main problem: double responsibility of government before crown and parliament Belgium from 1831
4 Revolutionary regime 1848 France (2nd Republic)
Main problem: presidential competences, veto, two-chamber system Germany (Paulskirche)
5 Parliamentarisation of old constitutional regimes Piedmont/Italy from 1860
Main problem: assertion of parliamentary means of pressure such as impeachment of a Netherlands 1868
minister, refusal of the budget, extension of the right to parliamentary means to Norway 1884
bring down the government, recognition of election results when head of state Denmark 1901
formed the government Sweden, Finland 1917
Germany 1918
6 Parliamentarisation by democratic constitution making after First World War Weimar Republic
Main problem: competences of president in semipresidential systems (Germany, Austria
Austria, Finland), stability of governments Finland
Czechoslovakia
Estonia
Spanish Republic from 1931
7 Parliamentarisation by democratic constitution-making after Second World War France 1946/47, 1958
Main problem: rationalisation of parliamentarism Italy 1946/47
Federal Republic of Germany 1948/49
8 Parliamentarisation by downfall of dictatorships in the 1970s Portugal
Main problem: rationalisation of parliamentarism Greece
Spain
9 Parliamentarisation by downfall of communist dictatorships after 1989 Eastern Europe
Main problem: parliamentarism or semi-presidentialism, electoral system
19
a balance between the legislature and the constitutional monarchy,

lasted from 1814 to 1914 in many parts of Europe. The predominant
ideology of the restoration period after 1814 was constitutionalism
dominated by the monarchical principle. This was eroded after 1848,
even in the German-speaking countries. Theoreticians of the monarch-
ical principle – from Friedrich Julius Stahl to Juan Donoso Cortés – sus-
pected from the outset that the balance between monarch and
legislature was precarious and that development required the superior-
ity of parliament. At a pinch ‘monarchical dictatorship’ was recom-
mended as a means to stop this evolution, as in the work of Donoso
Cortés under the influence of the 1848 revolutions. Conservatives there-
fore refused to accept the three instruments of sanction open to the
legislative majority against the monarchical government: impeach-
ment, refusal to approve the budget and interpellation.
2.2.1 Impeachment
The liberal movement that tried to make the monarch’s executive
subject to the confidence of the parliamentary majority had no clear
notion of a parliamentary system, though the theories of Constant,
Mill and Mohl were quoted in many parliamentary debates on the con-
tinent. Their immediate aim was to bring about a constitutionally
legalised state. The German formula was common even abroad:
the Rechtsstaat, the most important aspect of which was human rights.
The possibility of impeaching ministers for illegal acts was also one of
the main preoccupations of liberalism. Britain had exercised impeach-
ment since 1610, France since the Restoration. Belgium became a
parliamentary system in 1833. Parliamentarisation in Belgium started
with an impeachment against Lebau (Table 2.2). On the whole, prepar-
liamentary systems used impeachment more frequently, for example
territories in the German federation and Norway before the parliamen-
tarisation of the executive in 1884, which also ushered in a full parlia-
mentary system. Many countries tried to regulate the exercise of
impeachment via a law on juridical ministerial responsibility
(Table 2.2). Nevertheless writers on the parliamentary procedure came
to the conclusion that impeachment was ‘stillborn on the continent’. 4
This was certainly a misevaluation of the impact of impeachment.
Many continental countries did not introduce a right to interpellation
that could lead to a vote of no-confidence (for example Imperial
Germany and Sweden until parliamentarisation in 1917). A vote to
proceed with impeachment was the only way of finding out whether
the cabinet still had the confidence of the parliamentary majority and
Table 2.2 Parliamentary means of ensuring the accountability of government

to parliament
Right to interpellation leading to vote of

Impeachment of ministers Refusal to approve the budget confidence and vote of investiture
Britain: Britain: Britain:

1610 1689 Halifax
1621 Mompesson et al. 1693 Nottingham
1626 Buckingham 1911 (pre-empted by dissolving 1697 Sunderland
1640 Strafford parliament) 1711 whole cabinet
1701 Somer France:
1715 Oxford Belgium: 1814
1742 Walpole (ended politically) 1841 (2nd chamber successful) 1831
1805 Melville 1877 (vote of investiture)
Prussia: 1924
1862 (disaster for parliament)
France: Germany
1820 Decazes Netherlands: (Paulskirche) 1849
1827 Villèle (ended politically) 1868 (victory of parliament)
1830 Polignac (revolution) Piedmont-Italy:
1877 de Broglie Piedmont, Italy Denmark: 1848ff
1849 Taveri 1876
1878 Netherlands:
Belgium: 1881 1868 (rejection of budget, victory of
1833 Lebeau parliamentary mode of
1865 France: government
1890 (senate)
Germany 1945 (against de Gaulle) Norway
1833 Hassenpflug (3 times) 1872ff
Italy:
Norway 1892 Germany
1845 Vogt 1910ff.
1884 (whole cabinet, victory of
parliamentary responsibility) Sweden
1907ff
Finland: (hypothetical vote of no-confidence
1933 without political consequences
1952
1961
Early legal attempts at regulation

Sweden 1810 Sweden 1809 Britain 1830ff
Württemberg 1819 German Federation 1832 France 1849
Bavaria 1820 Denmark 1849
Norway 1838 Italy 1863
Switzerland 1850 Norway 1908
Denmark 1852 German Reich 1910
Netherlands 1855
Greece 1866
Austria 1867
France (constitutional law, 3rd
Republic) 1875
Denmark 1959
it functioned in a similar way to the practice in the presidential system

of the United States, as exemplified by the cases of Johnson (1868),
Nixon (1974) and Clinton (1998): it was a test for the head of the exec-
utive as well as for the parliamentary majority to see whether the gov-
ernment had lost the confidence of the majority.
Only in one case did impeachment lead to the immediate triumph of
parliamentary government. The Third French Republic was the first
system to regulate both the political and the penal responsibility of
ministers, as laid down in the 1875 constitution (Articles 6 and 12.2).
The conflict between parliament and President MacMahon (1877),
however, revealed that juridical responsibility was superfluous when
parliamentary responsibility on the part of ministers was in place. A
parliamentary decision renounced of impeachment because the
toppled ministers are ‘hence force struck by no longer having power. 5
Nevertheless, even in some twentieth-century constitutions the penal
responsibility of ministers has been codified (Fourth French Republic,
Italy, some German Länder). In Denmark in 1959 a committee on min-
isterial responsibility was set up but voted against a law on impeach-
ment. However, in 1962/63 the bourgeois parties presented a bill that
passed into law.6 In Finland there have been several cases of impeach-
ment (1933, 1952 and 1961). As a German constitutional lawyer stated
as early as 1864: ‘Impeachment is a clumsy instrument. It aims at too
much and therefore does not achieve anything.’ 7
2.2.2 Refusal to approve the budget

The second instrument of sanction – refusal to approve the govern-
ment’s budget – was considered by English conservatives as ‘un-British’
and illegal because it allegedly imitated a French Revolutionary prac-
tice.8 Nevertheless this parliamentary weapon was commonly used in
states dominated by the estates. For example, in 1626 the Commons in
England refused to approve the budget unless the unpopular
Buckingham was dismissed by the king. 9 Refusal to approve the state
budget was seen by conservatives as a ‘parliamentary infringement’
and by liberals as a ‘legal revolution’, although leading liberal theoret-
icians of parliamentary government such as Constant and Mohl were
highly critical of this parliamentary instrument. 10 Paradoxically this
instrument was most frequently used in preparliamentary societies
dominated by the estates, such as Sweden, 11 and in dualistic constitu-
tional monarchies.
Parliamentary refusal to approve the government’s budget was a kind
of predemocratic equivalent to the later idea of a general strike of the
people. It was predemocratic because in the perception of most liberals

parliament had the right to engage in a ‘budgetary strike’ but the citi-
zens had no right to refuse to pay taxes. The budgetary strike was most
successful in Britain, Belgium, the Netherlands, Denmark and Italy
(Table 2.2). In parliamentary systems it became obsolete because the
parliamentary majority tended not to go on strike against their own
party although this did happen occasionally (Italy in 1892, France in
1890 and 1945). In the early nineteenth century the most conservative
constitutional monarchies tried to outlaw the practice (Sweden in
1809, the German Confederation in 1832). In Prussia, parliament’s
attempt to refuse to cooperate with the government under Bismarck on
the military budget was a disaster (1862–8). Bismarck emerged victor-
iously from a constitutional conflict and in the long run indemnity
was granted to the government, which had ruled for years without par-
liamentary consent to the budget. One liberal commented correctly on
the predicament in the liberal camp: a parliamentary majority that
does not risk a democratic revolution by calling on the citizens for a
tax strike cannot expect to win a constitutional conflict. The idea that
the budget could only be rejected for economic reasons, not political
ones, remained predominant. Threats to reject the budget by the upper
house in a two-chamber system were rarely successful (the exception
being France in 1890) 12 and became a reason for depriving the upper
house of budgetary powers (Britain in 1911). This happened even in
federal systems such as those of Canada and Australia.
The refusal to approve the budget was called ‘stillborn’ in the treatise
of many constitutional lawyers. Only power-oriented lawyers, such as
Carl Schmitt, a violent opponent of parliamentary government, saw
that even failed attempts to reject the budget would eventually help to
parliamentarise the government.13 Denmark (1876, 1878 and 1881) is a
good example, though parliamentary government was not established
there until 1901. There was only one instance of rejection of the
budget leading to the immediate parliamentarisation of the govern-
ment: the Netherlands in 1868. This experience caused a furore among
Dutch conservatives, and even after the Second World War, the
‘Antirevolutionary Party’ inserted in its party programme that rejection
of the budget for political reasons should be made illegal. 14 Socialists
had a similar misunderstanding of parliamentary government when in
France they advocated rejection of the budget as a means ‘to deprive
the bourgeoisie of its power’, 15 although in 1945 De Gaulle avoided
any hint that his resignation was a consequence of a heavy budgetary
crisis.
Before democratisation the rejection of all or part of a budget was

not done for political reasons. Parliaments behaved like old estates
under absolutist rule: they were stingy and wanted to restrict the activ-
ities of government. This changed after democratisation, although in
the United States a remnant remains because the dualistic structure of
the regime allows scope for mutual interference. In democratic parlia-
mentary regimes the parliamentary majorities frequently tend towards
the opposite extreme: for electoral purposes they urge the government
to spend under a populist wish for a ‘democracy of favours’
(Gefälligkeitsdemokratie). In such a system budgetary rejections are
restricted to planned spending by unpopular ministers on state
activities.
2.2.3 Interpellation leading to a vote of no-confidence against

the government
In absolutist regimes the estates used petitions to remind the monarch
of constitutional conventions and any agreements between the
monarch and the estates concerning access to the monarch. The right
to petition was granted even in the most absolutist regimes, such as
Russia. The right to vote on the state budget and to impeach were some-
times codified in constitution. The right to interpellate as a weapon
against governments was hardly ever codified and was inserted rather
late into the ‘standing orders’ and procedural codes of parliaments. In
strictly dualistic regimes, interpellations were not followed by sanctions.
In presidential systems, therefore – and not by accident – strong rights
of inquiry began to be developed. The first ousted ministers left not
because they were constitutionally obliged to do so – even in Britain
until 1834 votes of no-confidence were ignored time and again – rather
they resigned because they felt that their honour had been damaged by
a hostile parliamentary vote. Sometimes they resigned because ministers
had put psychological pressure on parliament by combining a vote on a
special question with a question of general political confidence (exam-
ples include De Broglie in France in 1835, Balbo in 1848 and D’Azeglio
in 1849 in Piedmont/Italy). The first resignations after interpellations
occurred when proud aristocrats gave up government and grudgingly
withdrew to their estates. Those who used their right to ignore votes of
no-confidence fell into the category of what the conservative historian
Treitschke called the fever ‘of Prussian ministers’. After several hostile
votes they eventually withdrew for alleged reasons of health.
The rise of the (mostly unregulated) instrument of interpellation in
the nineteenth century was delayed by three factors:
• Interpellations by a small liberal or radical opposition frequently led

to the obstruction of government activities: the Irish were able to
cause serious difficulties for even a consolidated parliamentary
system such as the British one with their filibustering.
• Governments pretended not to be able to respond to all interpella-
tions because state secrets were at stake, especially in foreign affairs.
• When interpellations were accepted the right to pass a motion of
no-confidence was frequently denied to the legislature and interpel-
lations thus were doomed to failure.
The latter problem was the most serious. In Norway in 1884, during a
serious conflict between the parliamentary majority and the king’s gov-
ernment, a motion of no-confidence was disguised as an address to the
king. From 1885 the right to interpellate leading to a motion of no-
confidence was recognised in practice but it was not codified in the
standing orders until 1908. 16 In some constitutional monarchies this
right was granted much later or not at all. In Imperial Germany it was
legally recognised in 1910, although a leading constitutional lawyer
declared that a vote of no-confidence was legally as ‘irrelevant as the
right to express three cheers for the Emperor’. 17 Even in Sweden the
progress from interpellation to motion was obstructed until the full par-
liamentarisation of the system in 1917. In 1907 the liberal leader of the
opposition still had to use the trick of proposing a ‘hypothetical vote of
no-confidence’: ‘Unfortunately, Mr. Chairman, there is no possibility to
vote on a motion. But I dare to hope that if it were possible, the second
chamber with overwhelming majority … would vote for a change of
governmental policy.’ After this declaration the liberal and social democ-
ratic opposition rose as one and applauded the declaration of censure.18
In most other parliamentary systems the right to interpellate developed

into the right to judge government policy by means of no-confidence, a
motion first in Britain after the Glorious Revolution and then in France in
1814. France developed this instrument into a formal vote of investiture
during the accession of a new government. In the fight for the right to
vote on motions of no-confidence in many countries there were attempts
to introduce regulations – mostly to restrict this right – but without
success. There was no parliamentary government without the possibility
of toppling the government without a majority (Table 2.2).
None of the three instruments of the legislature were sufficient by
themselves to make the government fully accountable to parliament. In
many cases the instruments had to be applied for decades. In some case
(the Netherlands in 1868, Norway in 1884) the instruments were used in

concert in order to secure a parliamentary victory. Parliamentarisation –
except in constitution making – was a piecemeal affair. The instruments
were used successfully only when the parliamentary opposition was
sufficiently homogeneous to take over governmental responsibility, as
was the case in Belgium after 1831, in Britain from 1832 and in France
from 1821. Finally, the existence of a well-organised party system proved
to be as important as the development of legal parliamentary procedures.
2.3 Parliamentarisation and democratisation: the struggle

for universal suffrage and its impact on parliamentary
government
The first long wave of democratisation suggested by Huntington

(1828–1926) – two dates that hardly make sense in the context of
European systems – was (with the exception of 1848 in Europe and
1870 onwards in France) a process of parliamentarisation rather than
democratisation. Sometimes even conservative politicians and thinkers
such as Donoso Cortés were aware of the fact that parliament was a
politically neutral framework, though parliamentarianism for Cortés
was a false doctrine. Legal procedures were less important than the
political movements that followed them. The Liberals and Radicals were
seen as the torchbearers of parliamentary government. Sometimes,
however, even the Conservatives resorted to it, but only when they had
a majority. Thus the ultra-royalist Chateaubriand – in his book La
monarchie selon la Charte and in his later statements as foreign minister –
went beyond the great liberal Constant19 and demanded rule by the par-
liamentary majority. Also ‘political Catholicism’ – mobilising the reli-
gious majority against a laicist liberal state – was sometimes able to
accept the principles of parliamentary government. This was first
demonstrated in Belgium in 1830. However, it was not until 1885 that a
papal encyclical declared that no form of government would be con-
demned as long as it did not act against the doctrines of the church. 20
Radicals in many countries originally favoured an assembly government
– as later did many socialist groups. But even Marx – who had already
advocated a ‘dictatorship of the proletariat’ – conceded that in some
countries, such as Britain and the Netherlands, socialist transformation
might be carried out through parliamentary systems. 21 Socialists and
social democrats – with the exception of those who favoured a Soviet
system and anarcho-syndicalist direct action – became reliable support-
ers of parliamentarisation because they were confident that one day
they would attract the overwhelming majority of the votes of the

working class. All the parties were increasingly guided more by their
desire to acquire power than by ideological Weltanschauung concerning
their favoured form of government.
The nine party cleavages 22 that occurred in the nineteenth century
led to the formation of groups such as clericalist conservatives, agrar-
ians, right-wing extremists, some populists and ecological groups,
which had little chance of obtaining a majority or governing without
coalition partners. Their fight for universal suffrage was combined with
the fight for proportional representation in order to increase their
chance of participating in government.
Parliamentarisation and democratisation were rarely synchronised.
The short-lived revolutionary systems of 1848 and that of Sweden
(1917–20) came closest to it. In some cases reactionary leaders such as
Napoleon III preserved or introduced universal suffrage, as did Bismarck
in Germany in 1871. Their hope was to avoid liberal parliamentary gov-
ernment with the help of the conservative masses. Even Disraeli’s broad-
ening of the electorate in 1867 was prompted by similar considerations,
though parliamentary government was no longer in question. In some
countries the electorate oscillated and suffrage suffered setbacks, as in
France in (1795, 1814 and 1851), as did the power of parliament, which
was reduced on several occasions (1799, 1829, 1851) (Table 2.3).
There were few uniform developments in the process of
democratisation:
• In systems where the estates had a certain continuity, parliamentari-

sation normally took place well before universal suffrage was intro-
duced (Sweden was an exception).
• In systems where neo-absolutist regimes collapsed and revolutions
took place (France in 1848, Spain in 1820, 1834–9, 1868, 1873 and
1894), or a systemic change was realised by a national unifying
movement (Piedmont, Italy), parliamentarisation was attempted and
sometimes universal suffrage was introduced (imperial Germany).
The struggle for wider suffrage was linked in two respects to the
process of parliamentarisation:
• Widening the electoral law normally meant stabilisation of the

dominance of parliament in the system.
• Proportional electoral law was aimed at the participation of new
political forces in government.
28
Table 2.3 Types of regime and the extension of suffrage
Continuity of estate system New regimes Parliamentarisation of neo-absolutist regimes
Britain Sweden Norway Finland Netherlands Luxembourg Belgium France Italy, Spain Prussia, Austria Denmark
Piedmont Germany
Percentage of 1830, 1830, 1814, 1809, 1851, 1848, 1831, 1815, 1871, 1870, 1873, 1849,
population 2.3% 4 estates, 10% 4 estates 2.4% 2% 1% 0.25% 2.3% general 6% 14–15%
with 0.2%. 1882, suffrage,
suffrage in 1866, 2 7% participation
old regime chambers, 15.7%
5.7%
Extension 1832 1909 1885, 1906 1887, 1868 1848 1830 1912 1869 1919 1882 1849
of suffrage 1867 1898 1896 1892 1893 Reversal 1907 1897 1901
1884 1901 1795 1907
1804
1852
General 1918 1921 1898 1906 1917 1919 1919 1793 1919 1869 1867 1907 1901
male 1848 1907 1871 1915
suffrage 1875 1919
General 1928 1921 1915 1906 1917 1919 1948 1946 1945 1869 1919 1918
female 1931
suffrage
Year of 1688 ff. 1917 1884 1906 1868 1868 ff. 1831 1821 ff. 1860 1874 ff. 1918 1918 1901
parliamentarisation 1832–5, 1830 ff.
final 1848–51
conflict 1871 ff.
Sources: Stein Rokkan, Citizens, Elections, Parties (Oslo: Universitetsforlaget, 1970), p. 84ff; Dieter Nohlen, Wahlrecht und Parteiensystem, 2nd edn
(Opladen: Leske & Budrich, 1990), p. 33.
In most cases the best instrument for parliamentarisation was

endorsement of a parliamentary majority, which demanded govern-
mental power by the vote of the electorate. Under happy circum-
stances several electoral victories established the parliamentary
responsibility of government, as in Denmark (1873, 1878 and 1881,
with final victory in 1901), and made the use of other parliamentary
weapons superfluous. Sweden followed this example (1905 and 1911,
with final victory in 1917).
In the process of democratisation of parliamentary regimes there was
no clear correlation between the number of enfranchised people and
the degree of consolidation of parliamentary government. For example,
Belgium adopted a parliamentary government when only 1 per cent of
the population were enfranchised and in Britain in 1830 only about
2.3 per cent of the population were enfranchised. Sometimes anom-
alies strike the observer: we know that liberals frequently opposed uni-
versal suffrage though they fought for universal human rights; and in
Belgium even socialists rejected suffrage for women because they were
afraid of the clericalist leanings of most women.23
In some cases democratisation endangered the process of parliamen-
tarisation:
• Plebiscitary mobilisation for an extension of suffrage sometimes

strengthened conservative leanings in the electorate (1851 in
France, 1871 in Germany, in Switzerland female suffrage was
blocked for decades, and a 1971 referendum in Denmark failed to
lower the voting age to 18).
• The broadening of voting rights sometimes privileged certain
groups. Only with proportional representation were the advantages
of universal suffrage beneficial to all social groups and strata (except
Britain). Only Iceland up to 1959 upheld the plurality vote.
• Early democratisation of the electoral law did not always lead to a
high voter turnout. In the period 1870–90 the turnout in Germany,
under a regime of universal male suffrage, was 15.7 per cent, in
France it was 21.5 per cent and in Switzerland 12.7 per cent,
whereas in Britain, which still had fairly restricted voting rights,
12.1 per cent participated in the elections (Table 2.4). Voting rights
as a privilege has sometimes boosted voter turnout – in spite of the
contrary assumptions of democratic theory.
Comparative politics analysts frequently compare the impact of indi-

vidual institutions, and recent transformation and democratisation
Table 2.4 Participation in elections, 1850–1980 (percentage of population,

highest number in each period)
1850–69 1870–90 1891–1913 1918–30 1931–44 1945–59 1960–9 1970–9
Austria 0.5 1.0 17.7 55.0 62.6 62.5 61.2

Belgium 1.7 1.8 22.1 27.8 28.5 58.6 57.3 53.4
Canada 19.6** 33.2 40.0 42.6 42.0 43.2
Denmark 5.3 10.7 12.7 40.4 50.9 51.5 58.7 61.4
Finland 32.8 35.2 48.0 53.9 54.8
France 21.2 21.5 22.4 23.3 23.8 49.1 45.2 46.7
Germany/FRG 15.7 18.3 53.7 54.0 58.1 58.4 61.7
Britain 5.5 12.1 12.1 47.6 47.2 57.2 51.2 43.9
Greece 10.0 18.0 15.0 16.4 17.2 47.1 54.0 54.0
Iceland 10.2 32.1 50.2 47.5 50.4 51.9
Ireland 39.6 45.1 45.4 45.1 45.8
Italy 1.0 4.9 5.3 17.7 60.3 60.5 62.2
Luxembourg 47.8 56.7 58.6 53.4
Netherlands 2.0 5.3 12.7 41.9 47.2 53.3 54.6 56.0
Norway 2.4 4.7 20.2 42.6 50.1 54.4 56.1 54.2
Portugal 5.0 5.0 6.2 6.4 8.6 11.6 13.1 62.1
Spain 16.5* 3.9 15.8 13.4 36.7 49.8
Sweden 1.0 2.2 10.9 38.8 46.4 53.2 60.9 62.8
Switzerland 5.0 12.7 12.1 21.2 22.1 20.4 16.8 31.5
USA 18.5* 25.5 35.6 39.1 38.1 37.1
* 1873
** 1917
Source: Dieter Nohlen, Wahlrecht und Parteiensystem, 2nd edn (Opladen: Leske & Budrich, 1990), p. 36.
studies have tried to determine the appropriate mix of institutions. In

the history of parliamentarisation it has frequently been asserted – as
in Germany – that federalism and parliamentary government are
incompatible. Australia and Canada in the late nineteenth century
proved that the contrary is true, though the two most federalist states,
Switzerland and the United States developed a dualistic system where
the government was not accountable to the legislature.
In the fourth wave of democratisation after 1989 – with many new
regimes skillfully engaging in constitutional engineering – parliamen-
tary, semipresidential and presidential regimes developed a particular
mix of compatible institutions. The most important combinations
were proportional representation combined with parliamentary gov-
ernment and majority or plurality electoral systems combined with
semipresidentialism.24 Semipresidential systems have most frequently
been chosen in countries without clearly defined parties. But not
all the countries in which a loose super-party forum ushered in a
‘negotiated revolution’ ended up with a semipresidential system, as the
Czech Republic, Slovakia and Hungary have shown. The larger the
forum the less the party system was subsequently consolidated. By the
end of the 1990s forum parties everywhere had split into various polit-
ical party families.
A major conflict arose in the choice of electoral law. The old commu-
nist elites initially preferred the majoritarian systems of the communist
past. Their hopes for a majority, however, failed and power was seized
by the democratic opposition. But when the latter tried to use major-
itarian electoral formulas to stabilise their majority, they too failed.
The French socialists were the first to experience these dynamics. The
idea that a majority electoral system with two turns automatically
favours the leading party, such as the Gaullists in 1981, proved to be
wrong. When the socialists in turn lost their majority they manipu-
lated the electoral system and temporarily introduced proportional rep-
resentation – without much success. Most of the new parliamentary
and semipresidential democracies in Eastern Europe oscillated between
electoral formulas and eventually found that in constituencies with a
plurality of candidates proportional representation was the most feasi-
ble option (Table 2.5).25
After the collapse of communism in Eastern Europe the need for a
compromise between the old and new elites in the institutional mix
favoured a semipresidential regime with moderate proportional rep-
resentation.26 These are not mutually exclusive, as has been shown
in Austria, Finland, Romania and Bulgaria. Sometimes a mixed
system with parallel counting of majority and proportional votes
(Grabensystem) has been used as a compromise, as in Russia, Lithuania
and Japan. The Hungarian compensatory system is another variation
of this compromise between majority and proportional electoral
formulas.
2.4 The parliamentary system and constitutional

engineering
The doctrine of the constitution-making power of the people was a

compromise between ideas of direct democracy and representative
government. The constitutional systems of the nineteenth century
included the following:
• Constitutions imposed by the monarch (octroi). One of these, the

Piedmontese Statuto Albertino, became the constitution of the
kingdom of Italy. Although the new state had what almost
amounted to a consolidated parliamentary government, radicals
such as Mazzini never recognised the constitution as legitimate. 27
Table 2.5 Electoral systems in Eastern Europe, 1995
Types of electoral system

Country (1) (2) (3) (4) (5) (6) (7)
Albania *
Belorussia *
Bosnia-Herzegovina *
Bulgaria†
Croatia *
Czech Republic *
Estonia *
Hungary *
Latvia *
Lithuania *
Macedonia *
Moldova†
Poland *
Romania *
Russia *
Slovakia *
Slovenia *
Ukraine *
Notes:
1 Relative majority vote.
2 Absolute majority vote.
3 Majority vote with representation of minorities.
4 Majority vote in small constituencies.
5 Mixed system with parallel counting of majority and proportional votes (Grabensystem).
6 Proportional vote in multicandidate constituencies.
7 Compensatory vote.
†
In Bulgaria and Moldova there is proportional representation with a restrictive clause
(4 per cent). In Bulgaria there are constituencies, but the counting of votes is first done at
the national level; in Moldova there is only one national constituency.
Source: Dieter Nohlen and Mirjana Kasapovic, Wahlsysteme und Systemwechsel in Osteuropa
• Constitutions negotiated by legislatures and monarchs. These came into

being under the dualistic parliament – constitutional monarch
regimes in many European countries. In the German territories the
old estates were artificially transformed into new estates, but were
still referred to in the traditional way in order to avoid the word
‘parliament’. The constitutions were drawn up under the influence
of either the monarch (Württemberg 1819, Germany 1871) or
parliament (France in 1792, Spain in 1810). The early revolutionary

constitutions did not lead to consolidated regimes and parliamen-
tary government, but after 1814 in France, Belgium, the Netherlands,
Norway and Sweden constitutional regimes with a negotiated con-
stitution were transformed into parliamentary systems, sometimes
after a very long delay, as in Sweden (Table 2.6).
Sometimes negotiated constitutions almost amounted to an octroi by

the legislature. Robespierre made it clear who had the final decision in
France: ‘We do not ask Louis XVI to examine the constitution, we ask
him whether he is ready to serve as a king under this constitution.’28 In
Spain in 1810, when the representative of the crown, the Bishop of
Orense, refused to endorse the decisions of the Cortes he was arrested
and held in custody until he agreed to comply. The later revocation of
the constitution during the Restoration was justified on the ground
that the crown had given its consent under pressure. 29 Even early
constitutions in Scandinavia did not reflect a harmonious symmetry of
power. In Sweden, King Gustav Adolf IV was dethroned and his succes-
sor Karl XIII had no alternative but to agree to the constitution of the
estates. Even within the estates enormous pressure was brought to bear,
for example the consent of the farmers’ chamber was only obtained
with the use of pressure. In Norway – after the unpopular unification
with Sweden in 1814 – King Christian Frederik was able to offer sugges-
tions on the constitutional project but had little influence over the
final version.30 In countries where monarchs were called from abroad,
as in Britain under the House of Hanover, in Sweden under Bernadotte
and in Belgium under Leopold of Saxony-Coburg-Gotha, the crown
was naturally weaker than parliament. Monarchs who would not
accept parliamentary superiority could refuse the crown – as did
Friedrich Wilhelm IV of Prussia when the revolutionary national
assembly in the Paulskirche of Frankfurt offered him the imperial
crown.
With consolidated parliamentary government the doctrine of agree-
ment between crown and parliament fell into oblivion, though some
monarchists in Finland and Germany in 1918 tried to revive it. Even
the intellectual father of the Spanish republican constitution of 1931,
Posada, in his earlier works upheld a doctrine of cosovereignty of
crown and Cortes. But republican democratic doctrine transformed the
intellectual constructions of lawyers into fiction without roots in the
process of politics.
34
Table 2.6 Constitutions and parliamentary government
Constitution based on the

Imposed constitution Institutional agreement ‘pouvoir constituant’ of people
Monarch Parliament Organised from Organised from

preponderance above below
Pre-parliamentary Many states in the Württemberg, France, 1792 2nd Empire in

German federation, 1819 Spain, 1810 France, 1851
1814–48 Germany,
Netherlands, 1814 1870/71
Turned Statuto Albertino. France, 1814, 1830. France, 1958 France, 1848,
parliamentary Piedmont/Italy, Belgium, 1830/31, Russia, 1993 constitution of
or 1848, 1860 parliamentary since 1833. Paulskirche, 1848.
parliamentary Norway, 1814, Weimar
from the parliamentary since 1884. Republic, 1919
beginning Sweden, 1809, Finland, 1919
parliamentary since 1917. Spain, 1931
Netherlands, 1848, France, 1946
parliamentary since 1868 Italy, 1947
FRG, 1948/49
Southern Europe,
1974ff
Eastern Europe,
1989ff.
2.5 Parliamentary government by the constituent power

of the people
As indicated earlier, much of the first wave of democratisation was

actually parliamentarisation. Parliamentary sovereignty – first intro-
duced in Britain between the two parliamentary reforms, when govern-
ments were weak and the two-party system was in crisis (1832–67) –
did not amount to people’s sovereignty as long as the representatives
were not democratically elected by universal suffrage.
Only after 1918 did most of the new democratic regimes turn to par-
liamentary government by the people for the people. Radical demo-
crats did not demand a normal parliament but rather a special
constitution-making assembly. The French revolutionary assemblée
nationale (1791) and the German Weimar national assembly in 1919
are the best known examples of this. Where parliaments drafted the
constitution, radical democrats insisted that the approval of the people
be sought, but this happened only once – in France in 1946, when the
majority of the people refused to accept the constitution because it was
too radical.
The parliamentary constitutions were sometimes organised from
above, as in France in 1851 and 1958 in the process that led to the
Gaullist Fifth Republic, and in Russia under Yeltsin in 1993. But the
normal practice was for them to be democratically initiated from
below, as was the case during the four waves of democratisation in the
twentieth century from 1918, from 1945, the 1970s in Southern
Europe and from 1989 in Eastern Europe (see Table 2.6, final column).
Sometimes these democratic parliamentary constitutions had an
important author, appointed by representative institutions, for
example Cormenin in France in 1848, Hugo Preuss in Germany in
1919, Hans Kelsen in Austria in 1918, Ståhlberg in Finland and Posada
in Spain in 1931. The latter was the only one who did not promote a
semipresidential style of parliamentary government. Some of these
‘fathers’ of the constitution, such as Preuss, had a coherent idea of the
new system and did not accept that constitutions are normally a com-
promise between competing groups. Preuss accused ‘doctrinaire’ social
democrats of being ‘unwilling to understand the harmony of this
system’.31 By the second wave of democratisation, democratic tradi-
tions were sufficiently internalised for a grand législateur – seen as
inevitable even by radical democrats such as Rousseau – to be no
longer acceptable. Only Michel Debré – as the executor of De Gaulle’s
constitutional ideas – was able to secure a predominant position in the
constitution-making process of the Fifth Republic. But this was possible

only after the failure of the extremely liberal parliamentary system of
the Fourth Republic. This failed not because of the constitutional
arrangements, but because of its slowness, to accept the need for
decolonisation – unlike Britain.
A great founding father was less necessary after 1945 for several
reasons:
• Dictatorship had failed. A parliamentary system of the semipresi-

dential variety was the only feasible option available. A full presi-
dential system was considered only by a very small minority.32
• After 1918 semipresidential systems had mostly been a compromise
between democrats and monarchists, leading to a republican vari-
ation of constitutional monarchy. After 1945 monarchists had little
impact, although in Italy they lost a referendum by a small margin.
In 1978 Spanish monarchists were moderate and agreed to cooper-
ate even with the Eurocommunist Carrillo. They no longer fought
for wide and exclusive privileges for the crown.
• The number of cleavages in the party systems that dominated the
constitution-making assemblies had diminished in comparison with
the situation in 1918. The Christian democrats had gathered in
large sections of the right and had accepted democracy. Together
with socialists and social democrats they were the deciding force in
terms of constitutional engineering (France in 1946, Italy in 1947,
Germany in 1948/49 and Austria after 1945, which only amended
the old constitution of the First Republic).
Even in the fourth wave of democratisation after 1989, in Eastern

Europe there was hardly one father of the constitution. In Russia the
parliamentary chairman, Chazbulatov – the counter force against the
democrats under Yeltsin – sometimes tried to play the role of a found-
ing father and gave lectures to parliament on parliamentary and presi-
dential government, informing parliament that a president ‘governs
but does not reign’ (pravit, no ne tsarstvuet). This hint at Orléanist doc-
trine was aimed at limiting the powers of President Yeltsin. 33
Nevertheless in Russia an almost three-quarter presidential system was
created – semipresidential is too weak a term in Russia’s case.
With the right to issue decrees (ukazy) without the countersignature
of the prime minister and his authority over cabinet appointments and
dismissals the Russian president is far more powerful than other heads
of state in semipresidential systems. No wonder that the parliamentary
majority during the crisis of August 1998 called for the president’s
areas of competence to be reduced.
Most of the other Eastern European countries introduced a system of
‘rationalised parliamentarianism’ in line with the French and German
models, with:
• Popular elections of the president (except in purely parliamentary

systems, such as those of the Czech Republic and Hungary).
• Restrictions on votes of no-confidence (Hungary and Russia) (see
Table 2.5).
• Collective responsibility among ministers in order to stabilise the
government (Poland also added individual responsibility under
Article 157 of the constitution of 1997).
The dream of the famous Italian writer and politician Francesco de

Sanctis seems to have come true: ‘Now, when we are at a normal stage
of development, parliamentary governments should become a
“religion”.’ 34
3
The Organisational Basis of
Parliamentary Sovereignty
In England there has always been more liberty, but worse

organisation, while in other countries there is better organisa-
tion, but less liberty.
John Stuart Mill
In the democratisation of parliamentary systems the doctrine of

popular sovereignty superseded the older doctrine of parliamentary
sovereignty. De facto, however, the difference was slight. In democratic
regimes the constitutional wisdom is that parliament is the in-
stitutional seat of popular sovereignty – especially when there are few
possibilities for the people’s will to be expressed via referenda.
Democracy – after the failure of the anarchist-council form of direct
democracy (we cannot call it ‘soviet’ any more because Russia distorted
the original idea) and the mandate-form of government by assembly –
is a system in which exercise of the people’s will is limited by human
rights strictures, checks and balances, representative exercise of popular
aspirations, party government and sometimes federalism – which
ideally, according to Calhoun’s famous formula, puts concurrent
majorities above numerical majority. 1
Parliamentary sovereignty was always a fiction. The famous bon mot
that the British parliament could do anything except transform a man
into a woman was only partly true because there have been counter-
checks on its activities in most periods of British history. Moreover the
spirits which legislatures called in the nineteenth century began to
dominate parliament: responsible governments became the masters of
the legislature rather than its servants when cabinet and prime minis-
terial government developed. Nonetheless parliaments have had a
38
Organisational Basis of Parliamentary Sovereignty 39
certain autonomy – though less room for manoeuvre than the legisla-
ture in a presidential system.
Parliamentarisation of the executive involved certain preconditions:
• The existence of autonomous rights of organisation for the parlia-

ment including the right to assemble without being called by the
monarch, and an independent financial base. Organisational auton-
omy was rarely guaranteed in the constitution, but emerged step by
step through the standing orders issued by parliament itself.
• A non-hierarchical concept of equality among deputies and a
certain corps d’esprit among the members.
• Non-hierarchical relations between the two houses of parliament.
• A guarantee of independence from outside influence by trans-
forming parliamentarians’ representative function into a paid
profession.
Each of these will be discussed in turn.
3.1 Organisational autonomy
In constitutional monarchies the monarch usually had to agree to the

standing orders of parliament. In regimes with very large executives,
parliament was prevented from developing organisational autonomy.
It was only during the last two waves of democratisation (the 1970s
and 1989 onwards) that attempts were made to constitutionalise the
details of parliamentary organisation. Some constitution-makers – with
the best of intentions – went too far and even regulated the length of
parliamentary debates on government declarations as in Portugal
(Articles 166ff.). There are many details that are better left to the
standing orders of parliament.
3.2 Non-hierarchical parliament
Hierarchies and markets are the extreme poles on a continuum of

organisational models, with parliaments lying somewhere near the
middle. Rational choice approaches have frequently treated parlia-
ments as a kind of free market, with negotiations for coalition building
and log-rolling. The market model of parliament tends, however, to
overlook the hierarchical elements that emerge in legislatures when
those in the majority party or coalition are obliged to cooperate with
their government. Legislatures have therefore been compared to great

industrial enterprises because parliamentary votes are organised by a
strong hierarchy of party ‘entrepreneurs’.2 However, the latter are inte-
grated into complicated networks of codecision making, whereas
company heads usually only have bankers as codecision-maker and
then only when the liquidity of the company is in jeopardy. This, of
course, does not apply to legislatures. There are no bankers to pay for
their work – even if there is occasional corruption.
A further difference between parliaments and other forms of organ-
isation is the existence of conflicting government and opposition
groups. Majoritarian models of the Westminster type have been joined
by more consensual parliaments. Lijphart has added a further dimen-
sion to the typology by including federalism versus centralisation. Four
types of governmental organisation can be discerned among the
Western systems:
• Majoritarian: New Zealand (though this was before the constitu-

tional reform), United Kingdom, Ireland, Luxembourg, Sweden and
Norway.
• Majoritarian-federal: United States, Canada, Germany, Austria and
Australia.
• Consensual-unitary: Israel, Denmark, Finland, France (Fourth
Republic) and Iceland.
• Consensual: Switzerland, Belgium, Netherlands, Italy and France
(Fifth Republic, though this classification is subject to some doubt).3
For the mere comparison of parliament as indicators have been found

to operationalise the differentiation of majoritarian and consensual
parliamentary systems at the level of plenary work:
• Share of deputies without governmental office in the presidium.

• Minority veto over standing orders.
• Minority veto in respect of constitutional amendments.
• More than 100 plenary sessions per year, which provides the opposi-
tion with sufficient opportunities to express their views.
At the level of parliamentary committee work:
• Committees parallel to the ministries in order to improve parlia-

mentary control.
• Proportional distribution of the post of committee chairpersons.
• Ability to question civil servants.

• Ability to summon witnesses.
• Control over official files.
• Possibility to report for minorities. 4
According to these indicators some parliamentary systems – unlike

Lijphart’s overall indicators for consensualism – are more majoritar-
ian at the level of plenary work than at the committee level
(Denmark, Greece, Austria, Portugal and Spain). Hardly any parlia-
mentary system is consensual to the same degree at both levels
(Table 3.1), not even the classic examples of majoritarian parliaments
(Westminster model countries). Ireland has proved to be even more
‘British’ than Britain. This has been explained by the domination of
parliament by two major nationalist parties and the weakness of the
Labour Party.
Special rights on the part of minority parties, even in majoritarian
systems, have greatly contributed to group cohesion in parliament.
This is the more important, as in parliamentary systems governments
have some control over the majority in parliament. There are, more-
over, certain issues in which parliament as a whole – government and
opposition – can develop a group feeling. This trend is strengthened on
the continent by the fact that in many countries a tendency towards
‘cogovernment of the opposition’ has developed (see Chapter 5),
which is alien to the majoritarian Westminster type.
3.3 Non-hierarchical relations in two-chamber systems
Under the estate regime, there was basic equality among peers and gov-
ernments were built on collegial solidarity. There was no prime minis-
ter and ministerial hierarchies were not tolerated (see Chapter 6).
However, relations within the assemblies of the various estates were
extremely hierarchical. It has already been mentioned that the aristo-
cratic chamber in Sweden passed a constitution only after strong pres-
sure from the farmers’ chamber. But even in dualistic constitutional
monarchies the two-chamber system was built on hierarchy. The
British doctrine of ‘king in parliament’ included a system of checks and
balances not only between the executive and parliament but also
between the social strata represented in the Lords and Commons.
Liberals from Constant to Tocqueville have championed the two-
chamber system as an essential component of representative govern-
ment. Constant even preferred a hereditary chamber according to the
Table 3.1 Opportunities for the opposition and government backbenchers to

participate
Plenary sessions
Minority veto of More than 100

Share of Minority veto for constitutional plenary sessions Index
chairmanship standing orders changes per year total
Austria x x x – (39) 3.0

Belgium x – x – (79) 2.0
Britain – – – x (167) 1.0
Denmark x x – x (111) 3.0
Germany x x x – (62) 3.0
Finland x – + x (131) 2.5
France + – + x (149) 2.0
Greece + na x x (224) 2.5
Ireland – – – – (84) 0.0
Italy x x x x (137) 4.0
Luxembourg x x x – (77) 3.0
Netherlands x – x – (82) 2.0
Norway x – x na 2.0
Portugal x – x x (108) 3.0
Spain x x x – (88) 3.0
Sweden x + + x (123) 3.0
Distribution of permanent committees
Structural Proportional Questioning Inspection

equality to chairmanship of Summoning of Minorities Index
ministers of opposition civil servants witnesses records report total
Austria x + x x x x 5.5
Belgium + x x – – + 3.0
Britain – – – – – – 0.0
Denmark + x – – – – 1.5
Germany x x x – – + 3.5
Finland – x x – x x 4.0
France – – x – – – 1.0
Greece x – x + x x 4.5
Ireland – + – – – – 0.5
Italy x – x x x x 4.5
Luxembourg x x – – – – 2.0
Netherlands x x + – – – 2.5
Norway x x + – + x 4.0
Portugal + x x x x + 5.0
Spain x + x x x + 5.0
Sweden x x + + + – 3.5
Notes:
x = existent whole index point.
+ = restricted, half index point.
– = does not exist, no index point.
na = no answer.
Source: Herbert Döring, ‘Parlament und Regierung’, in Oscar Gabriel (ed.), Die EU-Staaten im Vergleich
(Opladen: Westdeutscher Verlag, 1992), p. 341.
British model. Tocqueville was more inspired by the US Congress.5 The

bourgeois fear of radical democracy was behind this preference.
Allegedly Jefferson once complained to Washington that the majority
in the Convention preferred a two-chamber system. ‘Why do you want
a second chamber?’ Jefferson allegedly asked. Washington’s counter-
question was ‘Why do you pour milk into your tea?’ The innocent
answer was ‘To cool it down.’ Washington then happily explained that
this was precisely what the majority had in mind with parliamentary
decisions: ‘to cool them down’. This story may not be true, but it is well
to the point. John Stuart Mill was one of the first to confess that ‘I am
inclined to think that if all other constitutional questions are rightly
decided, it is but of secondary importance whether the Parliament con-
sists of two Chambers or only of one’. 6 Mill was correct in predicting
that with increasing democracy the old doctrines would become
meaningless.
With the democratisation of parliamentary systems small countries
abolished the second chamber (New Zealand in 1950, Denmark, 1953,
Sweden in 1970). In Sweden – a country that was unique in preserving
the system of four estates until 1866 – this did not happen without
severe party conflicts.7 Larger countries have deprived the upper house
of many competences and transformed it into a chamber of delibera-
tion. Other large centralised countries have not dared to abolish the
upper house because the one-chamber system was discredited by the
French revolutionary regime. As a chamber of local and regional elite
representation the second chamber has developed new functions in
some decentralising countries, for example Italy and Spain, and to
some degree even France.
Two-chamber systems have been preserved under certain conditions,
though they contradict the democratic formula of ‘an undivided
nation’ that can be found in some constitutions, including those of
France and the Czech Republic:
• In Federalist countries two chambers are inevitable.

• Regionalised countries can give the second chamber a new meaning.
But only in Spain (Article 69.1 of the constitution) are the regions
the explicit base of representation.
• Consensual countries – with the exception of some smaller ones –
prefer two-chamber systems.
• Large countries tend to preserve two chambers, as Lijphart has
emphasised.
The hierarchy that used to privilege the upper house in the

nineteenth century has been turned upside down:
• Second chambers (in Sweden until 1970, and in the Netherlands the
people’s representation is still called the second chamber) are
smaller (the British House of Lords is an exception), but esprit de
corps and senatorial courtesy are more developed than in the
people’s house.
• Many second chambers have turned to partial replacement of out-
going deputies (half of the deputies every three years in Australia,
Japan, the Netherlands and the Fourth French Republic; one third
every two years in the United States Senate, one third every three
years in the Fifth French Republic. In federalist countries renewal
takes place on an irregular basis as in Switzerland, Austria and
Germany. Lijphart has called this ‘staggered elections’).8
• In some second chambers vestiges of the principle of ‘nomination
instead of election’ are preserved. Some senators are nominated in
Ireland, Italy and Canada. Members of the German Federal Council
have democratic legitimacy only at the Länder level. They are dele-
gates of their respective governments and are thus not representa-
tives in a proper sense. In the Netherlands (and until 1911 in the
United States) the non-popular chamber is composed of delegates
from provincial assemblies or state legislatures. The democratic
deficit of second chambers has usually resulted in diminished com-
petences in the legislative process – with the exception of Germany.
In most two-chamber systems the asymmetry of rights and compe-

tences is growing. There are three categories: almost symmetrical,
strongly asymmetrical and weakly asymmetrical competences (Table 3.2).
Symmetrical relations are mostly produced by federalism or by the
party state when the representational formula is not significantly dif-
ferent from that in the first chamber – as in Italy until 1994. The exist-
ence of symmetry can be determined only by studying the following
factors.
First, second chambers are involved in the constitution-amending
process. When a majority of states have to consent to proposed changes
the federalist position is even stronger. No wonder that in more than
200 years only 26 amendments have been carried through in the United
States and required judicial review for constitutional change.
Second, second chambers are usually able to propose bills. The
Netherlands is an exception here but this weakness is compensated by
Table 3.2 One- and two-chamber systems and their relation to federalism
Small countries Large countries
Unitary Federal Unitary Regionalised Federal

unitary
One-chamber Bulgaria
systems Denmark (since
1953)
Finland1
Iceland3
Israel2
Luxembourg1
New Zealand
(since 1950)
Norway3
Sweden (since
1971)
Czech Republic
Slovenia
Hungary
Two-chamber Switzerland1 Japan Italy1 Australia1
systems Poland Spain1 Belgium2
approximately Romania Germany1
symmetrical USA1
competences Russia
Assymetrical Ireland Austria Netherlands France (5th Canada
competences UK Republic)
Notes:
1 Elements of consensus democracy.
2 Strong elements of consensus democracy.
3 One-chamber systems divided into two subordinate chambers.
In the classification there are two important anomalies: (1) Germany has to be counted among the
two-chamber systems because of the competences of the Bundesrat. But legally the Bundesrat is not a
second chamber, even if the press calls it that. (2) Norway and Iceland are unreal mixed systems. The
Norwegian Storting elects one quarter of the deputies into the upper house (Odelsting); the Icelandic
parliament one third. Disagreements are resolved by a united plenary session of both half-chambers. In
Norway there are even united committees in the legislature.
the ability to veto legislation, which cannot be overridden by a

qualified majority as in most other countries.
Third, asymmetry can be judged by the existence of the right to
introduce the national budget. Most second chambers are underprivi-
leged in this respect. In Australia and Ireland (Article 20.1), the second
chamber has no right to introduce financial bills. In federalist coun-
tries, with the exception of Australia, there is normally more symmetry
in financial matters than in unitary states.
Fourth, another asymmetry lies in the regulation of mutual veto

functions in legislation. In most cases the bills of a second chamber
can be vetoed by a qualified majority vote (except in the German
Federal Council for acts that regulate matters of state interest).
Fifth, the mediation process between the two chambers has certain
asymmetries. Some countries do not have a mediation procedure (for
example the Netherlands) because of the unequal distribution of initia-
tive and veto functions. Equality seems to be greatest in systems where
a bill goes back and forth between the chambers (the French navette
system, also found in Italy and Belgium). Still more symmetry lies in
the conference committees (the United States, Germany, Ireland, Japan
and Spain, in some matters). In some countries conference committees
convene after a period of navette (France, Canada and Switzerland). The
greater the influence of the second chamber over legislation the greater
its influence over the fate of a government.
Sixth, in a democratic system the question arises of whether prime
ministers and ministers can be elected from the second chamber. In
democratic parliamentary systems prospective prime ministers and
ministers are normally members of the first chamber, even when there
is symmetry of rights between the two chambers. The British lower
house parliamentarianism developed with many fights and backlashes
in the nineteenth century. Until 1832 most British prime ministers had
been members of the House of Lords, although the advisers of the
crown frequently recommended a commoner. The last prime ministers
from the House of Lords (Rosebery, 1894–95; Salisbury, 1895–1902)
came to power only because their parties were suffering a leadership
crisis. In 1923 Lord Curzon expected to be asked to form a government
and was deeply shocked when Baldwin was chosen – Curzon consid-
ered Baldwin to be ‘a man of utmost insignificance’. Baldwin’s selec-
tion was later taken as a binding precedent. As late as 1940 the king
and Chamberlain thought that Lord Halifax might be called instead of
Churchill. Halifax himself had misgivings: ‘he could only act as a
shadow or a ghost in the Commons where all the real work took
place’.9 Only in 1965 did the Peerage Act make it possible for Lord
Home to renounce his peerage and take office as prime minister.10
On the continent resistance to a peer holding the highest executive
office first arose in the French system of Louis-Philippe (Molé in 1839).
In the Third French Republic (1870–1940) and Italy senators served as
prime ministers but did not play a major role. 11 In Belgium the
appointment of a prime minister from the second chamber has nor-
mally indicated a crisis of leadership (Pierlot in 1939, Duvieusart in
1950 and Pholien in 1950). In the Scandinavian countries – with many

minority governments – and in the Netherlands, where the relation-
ship between parties and their ministers is normally loose, the appoint-
ment of a prime minister from the second chamber as a ‘legal reserve’
is of minor importance. In federalist countries prime ministers have
rarely been taken from the second chamber.12
The rules for the ministers are less strict in parliamentary systems.
Democratisation has meant that since 1924 important roles such as
foreign minister and chancellor of the exchequer have normally been
entrusted to a commoner (exceptions were in 1938–40 with Halifax
and 1960–3 with Home as foreign minister). But even Churchill’s
cabinet included six lords, prompting the epithet ‘Lords Help Us
Government’. 13 In constitutional monarchies before parliamentarisa-
tion most ministers came from the upper house. In parliamentary
systems there were no uniform rules. In Australia senators sometimes
received one third of cabinet posts. In Belgium, during a crisis in 1950
senators took over as many as two thirds of the portfolios. In the
French Third and Fourth Republics senators were frequently included
in the cabinet. Even radical leaders needed senators for protection
against hostile votes, although this did not always work: for example,
the socialist Blum cabinet was toppled by the Senate even though it
contained three senators.14 Most constitutions have not regulated the
matter, apart from that of Ireland which limits the number of senators
in the cabinet to two (Article 28.7).
Seventh, the question that has caused most conflict between the two
chambers is that of ministerial accountability to the second chamber.
The democratisation of parliamentary systems made ministerial
accountability to the upper house unacceptable. This was the more so
as in many cases the upper house was not threatened by the dissolu-
tion of parliament in the event of a hostile vote. In England this
conflict was avoided. In the period of juridical responsibility the lords
were judges and therefore rarely served as public prosecutors of the
government – this judicial restraint also has been preserved in periods
of political ministerial responsibility. But since impeachment fell into
disuse as early as 1805 this explanation is inadequate. Until 1834
British monarchs sometimes insisted on ministerial accountability to
the House of Lords because the lords’ votes gave them a legal pretext to
dismiss unpopular ministers (such as Fox and North in 1783). 15 But
since 1834 no British monarch has revoked a government and the
crown is unable to help the lords to enforce ministerial accountability
to the upper house.
The theory of the co-equal houses was challenged by Bagehot, 16

although more traditional writers continued to believe in equal rights
between the two houses. But with increasing democratisation in the
era of Disraeli and Gladstone co-equality was eroded, and in 1911 the
last conflict between the two houses resulted in a parliamentary reform
that deprived the House of Lords of many rights and changed its
character completely.
In France under the Third Republic (1870–1940) five presidents of
the ministerial council were toppled by votes of no-confidence in the
Senate (Bourgeois, Herriot, Tardieu and Blum on two occasions) Four
more prime ministers themselves initiated a crisis by raising a question
of confidence (Briand, Herriot, Tardieu and Laval). Two other prime
ministers resigned because of a hostile vote in the Senate (Fallières in
1883 and Tirard in 1890). The increasing power of the second chamber
over the fate of French governments can be explained by a reshuffling
of the party system. Leftist governments such as Herriot’s Cartel and
Blum’s Popular Front were confronted with a conservative majority in
the Senate. 17 This increase in the power of the conservative second
chamber happened in spite of the fact that the investiture vote for gov-
ernments was used only in the first chamber. Many lawyers claimed
that the Senate’s right to defeat governments was contrary to the
Republican tradition. The most important point, however, was that at
that time the French senate could not be dissolved by the President.
For their part the oligarchy in the senate cited the arguments of the
conservative interpreters of the French tradition in the school of
Duguit and Redslob.18
At that time the kingdom of Italy was in a similar position and the
Senate could not be dissolved. According to leftists ‘II senato non fà
crisi’ (the senate does not make crises). Many governments survived
hostile votes and the senate was increasingly criticised because it was
not an elected second chamber.
In times of conflict there was a tendency to increase the number of
nominated members in the upper house. In England this ploy was first
used in 1711, when Queen Ann wanted to secure the ratification of the
Treaty of Utrecht. It was used more often in the nineteenth century,
and in the twentieth century even the Labour Party discovered this
instrument of patronage. With the Life Peerage Act of 1958 Macmillan
tried to regulate the number of peerage nominations, but only in 1963
did it become possible to reject peerage proposals. The creation of peer-
ages no longer serves to reduce opposition in the Lords. The conflict of
1911 led to a diminution of the power of the House of Lords, but the
mass nomination of lords (Asquith created 108 peers in eight years)

continued for other purposes, such as to reward friends and patrons
and until 1963 to neutralise critical House of Commons politicians. 19
The regime of Louis-Philippe in France (1830–48) and the Kingdom of
Italy after 1860 followed the British example with what they called the
fournée or infornata of members of the upper house. After democratisa-
tion of the upper houses these abuses were abolished in most parlia-
mentary regimes.
Double accountability of ministers to both chambers of parliament
developed only in systems where the upper house was elected in a
fairly democratic way, such as in Belgium, the Netherlands, Sweden
until 1970 and the Republic of Italy. In federalist systems ministers are
rarely accountable to the second chamber because dissolution of this
chamber would be tantamount to a violation of the federal principles
of the system (there have been some exceptions in Australia).20 Sweden
experienced many cases where the simple alternative with which the
liberal Staaff challenged the crown in 1906 to decide whether it wanted
to govern with the ‘Lord’s power’ or ‘people’s power’ could not really
develop since governments were dissolved after being defeated in both
houses (Sandler in 1925, Lindmann in 1930 and Hansson in 1936). In
Sweden the unusual situation developed whereby the social democrats
had a majority in the upper house so there was less conflict with gov-
ernment and the social democrats were less eager than previously to
abolish the second chamber (in Sweden this was still called the ‘First
chamber’). This they did only in 1970. Also unusual was a declaration
by the first social democratic prime minister (statsminister), Branting, in
1923: ‘The government did nothing to diminish the importance of the
First Chamber. We recognise the importance the First Chamber has in
Swedish political life, not the old one but the democratised Chamber.’ 21
The Republic of Italy made the government accountable to both
houses (Article 94). This is logical in a system where the vote on the
investiture of a government is taken in both houses. Nevertheless the
senate has rarely decided the fate of a government (exception that of
Andreotti in 1972) and hostile votes have sometimes been ignored
(as under Moro in 1967). In rare circumstances governments have
even been saved because they had the confidence of the senate
(as under Tambroni in 1960). Max Weber already knew in 1918 that ‘a
double responsibility of government to both houses’ would cause
‘complications’.22
For all seven of the factors listed above, in two-chamber systems the
tendency has developed for dominance by the lower house. The democ-
ratisation of parliamentary government made such a development

inevitable. ‘Consolidated parliamentarism’ – as a deadlock between the
people’s house and the higher social strata represented in the upper
house – for a while seemed to be under threat in Britain when in 1911
the last great conflict broke out between the government and the House
of Lords. However, parliamentary government was reconsolidated, after
the complete introduction of democratic principles.
3.4 Social equality among deputies and economic

independence
In early parliaments – elected by a restricted electorate on the basis of a

restricted electoral law, under which only 2–5 per cent of the popula-
tion had the right to vote – there was a certain degree of social equality
among members on the basis of education and property, but when the
lower strata and eventually the workers entered the political arena this
disappeared. As the Rechtsstaat, the constitutionalised legal state, had
to be completed by the welfare state for all citizens, parliamentarians
from the lower strata had to be supported by allowances. In democratic
parliamentary regimes the deputies receive more or less equal
allowances. Only the speakers, the leader of the opposition, the parlia-
mentary group leaders and committee chairpersons are in some
regimes paid more than ordinary MPs. Preparliamentary constitutional
regimes tried to avoid paying allowances or at best kept them low –
they were not seen as a payment for a professional job. Deputies living
in the capital did not always receive daily allowances for attending ses-
sions, and in the nineteenth century the German territories spent less
on the remuneration of deputies than they did on their court cafete-
ria.23 Bismarck deliberately tried to avoid paying allowances in order to
strengthen the ranks of well-to-do bourgeois deputies, but the social
democrats compensated for this by paying parliamentary group
allowances to their representatives. An odd consequence of this stingi-
ness was that the restaurant in the imperial legislature went bankrupt
because the majority of the deputies could not afford to frequent it. 24
Things have changed in Germany and deputies are now better paid
than their counterparts in all other countries except the United States
and Italy. The Constitutional Court has ruled that even Länder
parliamentarians have to be remunerated. Representation has become a
profession.
The hierarchy of allowances (Table 3.3) shows that the professionali-
sation of parliamentary work increases with the wealth of the country,
Table 3.3 Annual gross minimum pay of parliamentarians, 1996 (£ sterling

converted into the equivalent of purchasing power)
Eurostat index of Penn world table of purchasing

purchasing power power parities of consumers
Australia 39 262 40 469

Austria 44 402 39 225
Belgium 44 402 39 225
Canada 33 753 34 672
Denmark 26 510 24 397
Finland 2 360 23 108
France 38 522 34 524
Germany 43 007 37 847
Ireland 34 962 31 771
Italy 89 653 81 024
Luxembourg 16 248 15 991
Netherlands 38 137 35 888
New Zealand 31 467 29 971
Portugal 44 125 45 694
Spain 28 853 26 948
Sweden 21 814 21 567
United Kingdom 34 085 34 085
United States 85 641 74 805
Average 40 538 37 834
Source: Europäisches Parlament: Ausschuß für Geschäftsordnung, Wahlprüfung und Fragen

der Immunität, September 1996; Doc-DE/CU/30844, Review Body on Senior Salaries,
Report 38, Review of parliamentary pay and allowances, presented to Parliament by the
Prime Minister (London: HMSO, 1996), p. 64.
except in Britain and Sweden. Preventing corruption is an important

afterthought of high allowances. No wonder that Italian parliamentari-
ans are among the most highly paid – according to the Eurostat index
of purchasing power their allowances are even higher than those
received by members of the Congress in the United States.
There is increasing criticism of the self-serving mentality of parlia-
mentarians. An appropriate level of allowances is hard to define. The
application of an index increases inflation by its automatic annual
increases, but indices for economic growth, living costs, rate of
inflation and comparable incomes among civil servants are used by
committees inside and outside parliament that attempt to rationalise
increases in deputies’ allowances.
Business elites are often paid according to their performances, but what
are the criteria for successful parliamentary work: the number of speeches
or laws? Criticism is growing particularly in federalist systems. The costs

of the ‘political class’ at all levels are counted together and nobody has
ever calculated the payments for prefects, subprefects and regional assem-
blies in centralised countries without state parliamentarians.
All comparisons of allowances are misleading because they do
not reveal the other privileges that deputies may enjoy, such as free
travel and so on. Moreover the size of the country is important.
Parliamentarians in small countries do not need two apartments. No
wonder, then, that Luxembourg parliamentarians receive the most
modest remuneration.
The above typologies of majoritarian and consensual systems are
hardly reflected in the amount parliaments pay to their deputies. One
might think that majoritarian systems such as Britain, which still
largely follows the doctrine of parliamentary sovereignty, would pay
the most, but the contrary is true. Consensual regimes, according to
Lijphart’s definition (see above), pay the highest allowances, for
example Italy. This makes sense because agreement is easiest on an
issue from which every deputy participating in the game can profit.
Federalist systems pay high allowances in spite of the double burden of
these countries. However Canada is an exception as it follows the
Westminster model which used to divide the time of deputies between
city (working in business) and parliament (political activities) and had
a low degree of professionalisation of the representative function.
3.5 The rise of a new hierarchy in parliamentary work:

plenary and committee work
In early parliaments there was a clear division of labour between the

two chambers. The House of Commons was peopled by a ‘discussing
class’ – despised by conservative writers such as Carl Schmitt and over-
rated in their orientation towards finding ‘truth by discourse’ by leftist
thinkers such as Habermas.25 Work consisted of discussion in plenary
sessions. Committees were created only on an ad hoc basis. The ‘mother
of parliaments’, the British Parliament, has preserved many part-time
elements of a deliberation of non-professional amateurs and was late to
develop specialist committees. Parliaments in the nineteenth century
reflected an elitist bourgeois society with little internal differentiation
and hierarchy.
Parliament has been analysed in studies of democratic development
as a dependent or independent variable.26 But, as shown in Chapter 2,
parliaments have rarely been independent variables in regime change
and they recently played a major role in the peacefully negotiated rev-
olutions in Poland and Hungary. However, elite continuity in most
Eastern European parliaments is only partial because new elites have
entered the arena and even communists no longer wish to be repre-
sented by the old elites. In the Czech Republic only 5–10 per cent of
deputies were once associated with the parliament of the old regime.
Parliaments under normal conditions have been compared to a baker’s
leaven: there are continuous additions but the old substance remains
and influences the newcomers.27 The new deputies in Eastern Europe
after the collapse of communism were mostly individualists with no
experience of party discipline. The moral thrust of the peaceful revolu-
tion nurtured the idea of a fairly apolitical civil society in which the
concept of parliamentary discussion was naive: ‘honest and educated
people will agree on good politics’. Organised interest groups were
largely absent – apart from some ‘business lists’ and ‘beer drinkers’
groups’, disguised middle-class interest representatives – as they were
underdeveloped. No wonder that technocrats such as Václav Klaus
became more powerful than honest men such as Václav Havel. Most of
the latter disappeared completely from the political scene.
In older textbooks and sometimes even in constitutions for example
Articles 75.1 of the 1978 Spanish Constitution symmetry between work
in plenary sessions and committee work was taken for granted. There is
hardly a classical ‘discussing’ parliamentary system left and everywhere
plenary debates have undergone a process of rationalisation and for-
malisation. The standing orders of parliaments have increasingly sup-
pressed individuals and dissenting groups since some minorities and
extremist groups have resorted too often to filibuster and obstruction.
The streamlining and hierarchisation of debates under party control
have made surprising results unlikely. 28 It has been said that a parlia-
ment becomes more powerless the more time it spends on plenary ses-
sions.29 Journalists’ denunciations of the laziness of politicians
normally hint at the emptiness of the chamber during parliamentary
debates. But international comparisons show that this is a deceptive
indicator of the degree of activity of parliamentarians. Since the mid-
1960s debates have become more lively and deputies have become
more active, asked more questions, introduced more bills and worked
harder in the parliamentary committees. But it is also true that the
role of the individual deputy has declined. Parliamentarians have
proved to be less interested in plenary debates than in committee
work. Committees are, however, steered by parliamentary groups.
‘Representation from above’ is growing – and not just in Sweden.30
Parliamentary debates in plenary sessions and committees are the

classic arena for the application of rational-choice approaches. Because
they emphasise the individual actor they are particularly appropriate
for members of the US Congress because party discipline is far less
developed in Washington than elsewhere. But even in the United
States the ‘legislative Leviathan’ has been rediscovered and party
organisations are streamlining the process.31
The consequence of party control over deputies is hierarchisation
and specialisation. But the strength of parliamentary committees
cannot be deduced from the organisational characteristics of the party
system. In the nineteenth century parliamentary cultures were shaped
by and determined attitudes towards the committees.
• Distrust of committees and suborganisations is strongest in Britain.

Specialist committees are seen as mediating the rights of ministers.
Moreover standing committees are seen as an attempt to diminish
the prerogatives of the government. Committees in this perception
function to criticise but not to shape policies. 32 Even in the
Westminster type of parliamentary government, however, allowing
individual deputies room for manoeuvre is seen as compensation for
those in government groups who are not favoured with an execu-
tive office. But the increasing complexity of the policies, the need
for expertise and the need to acquire pertinent information for
rational decisions increasingly necessitates more specialist commit-
tees in Westminster-type systems.33
• In France and the United States, on the other hand, interest groups
and ideological or policy groups are not easily dominated by par-
liamentary group leaderships. For example in France under the
Third and Fourth Republics la république des camarades increasingly
paralysed the system.
The rise of strong committees has been promoted by different factors.

In the United States committees have been strengthened by sectoral
interests and rules of seniority. 34 In European systems the main driving
force behind strong committees are ideological party groups.
The more archaic the legal basis of parliamentary work the fewer the
regulations on committee work. Parliamentary committees only came
to be mentioned in constitutions after the Second World War
(Germany: Article 44; Greece: Article 65.2; Italy: Article 72; Portugal:
Article 181; Spain: Article 75). The privileges of committees vary enor-
mously, ranging from the right to pass laws as in Italy to the other
extreme where they are under the permanent control of parliament (as
in Britain). Procedures are normally put under the provision that the
plenary assembly has the right to veto committee legislation (Italy:
Article 72.3, government, one tenth of the chamber or one fifth of the
committee members;35 Spain: Article 75.2) (Table 3.4).
In parliamentary systems there has been an increasing division of
labour between plenary and committee work. The position of the gov-
ernment is strongest where there is – after the completion of commit-
tee work – only one reading of a bill, as in Sweden.36 In countries with
no second chamber, autonomous committees can perform a similar
function.37 In the Westminster model it is almost impossible to kill a
bill if it has obtained the approval of the house. In Sweden committees
can not quash a bill, but they can delay the final decision.38
The main work of committees from a transnational perspective does
not lie in autonomous decision making but rather in their power to
amend bills. Some committees treat government bills as basic material
to be worked on; others – especially in the Westminster model – only
have a limited right to amend government proposals. The more spe-
cialised the policy the less that individual deputies participate in its
finalisation. In the German Bundestag complicated matters are domi-
nated in the plenary debates by the committee chairpersons and those
who report on the committee work. Social policy, including compli-
cated formulae for retirement allowances, is handled by half a dozen
specialists and amendments from outside the committees are
extremely rare.39 In Scandinavia it has been shown that the outcome of
voting in plenary debates reflects that in the committees.40
Comparative research on parliamentary committees has employed
a large variety of indicators, such as type, size and number of
committees, competences, limitations on membership and speciali-
sation of committees and subcommittees. 41 The first three of these
are most important for indicating the part played by committees in
articulating the will of the parliamentary majority. The following
rough typology contrasts the Westminster committee system with
continental ones:
• In the Westminster type the committees are weak and dominated by

the governing party. Harold Laski recommended specialist commit-
tees as early as 1925 but little was done. Only the Liberal Party was
really interested in specialisation in order improve control. In 1970
the Expenditure Committee of the House of Commons was created.
Innovators also wanted to revitalise the House of Lords by setting
Table 3.4 Committees: legal framework and political competences 56
Committee MPs
Parallel meetings as present,
Number Limitation organization obligatory Legslative Right to Right to Government who are not Right to
of standing of of committees Appointment Appointment stage of initiative of summon demand officials members of summon
committees membership and ministries of members of chairs legislation committees witnesses documents present committees ministers
Australia 23 No Approximately Party Government Yes (with No Yes Yes Yes Yes Yes
leader and parties exceptions) (without
proportion before vote)
plenary
session
Austria 10 Yes (2–3) All Parliamentary Majority Yes (with Yes (with Yes Yes Yes Yes Yes
except groups to exceptions) exceptions)
one to president government before
of parties plenary
parliament session
Belgium 15/14 No Yes Elected Proportion Yes No No Yes Yes Yes de facto
by parliament customary
Canada 20/10 No Approximately Committee Government No, after No Yes Yes Yes Yes Yes
of parties plenary
selection session
Denmark 23 No Approximately Parliament Proportion, Yes, No Yes No No, May Yes

and after before except make a (minister
proportion consultations plenary combination request, may
of session with but refuse
parliamentary ministers without
groups right to
vote
Finland 14 No Imperfect Parliament Concertation Yes, Yes (with No Yes Yes No Yes
if according before only few
unanimous, to plenary exceptions)
otherwise proportion session
45
electors
Table 3.4 continued
Committee MPs
France 6/6 Yes No Parliament Concertation Yes, No Yes Yes Yes Only Yes, de
and according before applicants facto
proportion to plenary
proportion session
Germany 23 No Approximately Parliamentary Proportion Yes, No No No Yes No

Yes
groups before
according plenary
to session
proportion
Greece 19 Yes Yes President Government Yes, Yes No No Yes Without Yes
of parliament parties before right to
according plenary speak
to proportion session
Britain 14 (17 No No Committee Government Yes (with No No No Yes Yes Yes

subcommittees) of selection parties exceptions) (according
after to
plenary committee
session of selection)
Ireland 3/2 joint No No Committee Majority Yes, after No No No Yes Yes Yes
6 of selection vote plenary
and session
proportion
57
58
Table 3.4 continued
Committee MPs
Israel 10 No Imperfect Parliament Negotiation Yes Yes (only No Yes (with Yes Applicants Yes
and between a few exceptions) on
proportion coalition exceptions) invitation
and
opposition
to the
advantage
of coalition
Italy 14/12 Yes (I) Yes Negotiated Yes, No No No Yes Yes Yes
with by before
exceptions government plenary
parties session
Japan 16 Yes (2 in Approximately President Proportion Yes (with Yes Yes Yes (de Yes On invitation Yes
upper of parliament exceptions) facto) without
house) according right to
to speak
proportion
Luxembourg 17 No Approximately Groups Proportion Yes, No No Yes No (with No No (but

to parliament before exceptions) hearing)
according plenary
to proportion session
New Zealand 17 No No Parliament Government Yes (with No Yes Yes Yes Without Yes
parties exceptions) right to
speak
Table 3.4 continued
Committee MPs
Netherlands 30/19 No Yes President Proportion Yes, No No No Yes, if Only if Yes

of parliament before authorised bills are
after plenary by discussed
consultations session minority
and
proportion
Norway 13 Yes (1) Parliament Proportion Yes, No No No No No Yes
on (informal)
advice of before
parliamentary plenary
groups session
Portugal 19 Yes (2–3) Approximately President Proportion Yes (with No Yes No Yes Yes Yes
of parliament exceptions)
after
consultations
of parliamentary
groups
Spain 13 No Yes Consultation Proportion No, after No Yes Yes (with Yes Without Yes
with of plenary exceptions) right to
council two session speak
of largest
speakers parties
Sweden 16 No Approximately Parliament Proportion Yes Yes No Yes Yes No No
(minister
may
refuse)
Source: Parliaments of the World (Aldershot: Gower, 1986), pp. 966ff.

59
up more specialised committees. But only accession to the European

Community made reform of the British committee inevitable.
Policy-oriented committees developed in Britain only in 1979 and
in Ireland as late as 1983.42
• Most continental parliaments have developed strong committees.
With the exception of the Netherlands they are normally under the
efficient control of the party groups. 43 The more a continental
country emphasises the separation of powers by making parliamen-
tary mandate incompatible with governmental office, the more
parliaments and committees are open to the activities of individual
deputies. The weakness of the committees in the parliament of the
Fifth French Republic reflected the weakness of parliament as a
whole.
Quantitative research on parliamentary committees has had to rely

on Interparliamentary Union statistics, which have sometimes proved
to be incomplete or misleading. Many countries readily disclose the
legal situation but not the real parliamentary customs. Some general-
isations are possible, however:
• The power of the parties over committees declines as their number

rises. The average is about 10–20 committees. Denmark and the
Netherlands have more than 20 while France – with six committees
– is below the average.
• The size of committees usually has some impact on the power of the
parliamentary majority. Huge committees, up to 175 members in
France, do not make for a good working climate. Direction of these
bodies by the governing majority is likely.44 Small committees com-
bined with a fragmented party system create a neutral climate that
does not favour steering by the parties. The number and size of com-
mittees has some effect on the degree of importance attributed to
them. In most countries financial committees and committees of
foreign affairs are considered important whereas committees on peti-
tions or electoral procedure are not.45 Where the size of committees is
fixed (Iceland: maximum 7; Portugal: maximum 12; Spain and
Sweden: minimum 15) the working climate is conflict-oriented and
the penetration of the committee by party leaders is likely. In spite of
many complaints about deputies being professional politicians with
little practical experience outside politics,46 professionalism and spe-
cialisation are increasing everywhere. Professional backgrounds are
normally considered when parties allot deputies to committees. In
smaller countries such as Norway deputies are eventually appointed to

the committee of their choice,47 but this is not the case in larger
countries with a greater number of MPs.
• In general there is a certain correspondence between the number of
ministries and the number of committees in parliamentary systems,
although some countries have far more committees than ministries
while others maintain a tight limit on the number of committees.48
• The mode of nomination of committee members influences the
power structure. There may be formal election by the plenary
session, nomination by a designated research committee (as in
Britain) or nomination by the speaker after consultation with the
parliamentary groups. Although the programmes of the traditional
parties have become less ideological and more pluralistic specific
areas of interest remain. Social democrats normally want to chair
social policy and labour committees. Liberals are frequently inter-
ested in economics, education and justice. Greens, however, are no
longer content to limit themselves to environmental protection.
Mediating the competition for membership of specific committees is
most complicated in countries where the parliamentary parties are
entitled to nominate committee chairpersons and members (as in
Austria, Portugal and Spain), a privilege that elsewhere is exercised
only in an informal way.
• The appointment of chairpersons of committees in majoritarian
systems follows the formula ‘winner takes all’, whereas in more
consociational systems the distribution of chairs tends to be more
balanced, as in Germany and Austria. Sometimes committees with
strong controlling functions are handed over to the opposition (in
Germany the chair of the budget committee).49
• In some countries with strong committee systems committees have
the right to initiate legislation (Austria, Finland, Greece and
Sweden). However, committee members elsewhere can always
launch an initiative via their parliamentary group. Sometimes an
initiative launched under this right conflicts with a similar proposal
by an extra parliamentary body with the same entitlement, for
example the National Council of Economics and Labour in Italy
(Articles 75 and 99.3).
• In most systems committee meetings are not open to the public,
except for special hearings (49 countries). Twenty-one parliaments
have committees whose sessions are regularly open to the public.
Twelve parliaments have a mixture of the two, according to
parliamentary majority decision. 50 New democratic waves are
normally accompanied by a demand for full openness in respect of

committee work in order to allow transparency of group influences
and boost the interest of the media in parliamentary work.
Technocratic realists argue, however, that this impedes agreement
between parties and necessitates secret preparatory meetings, thus
imposing an additional workload on deputies.
More important for assessing the strength of committees is their

ability to summon ministers and witnesses and subpoena information
from public and private institutions. In this respect parliamentary com-
mittees in Europe lag far behind their counterparts in the US Congress,
as illustrated by Kenneth Starr’s congressional action against President
Clinton. Ministers in most systems can be summoned by a committee
– in Greece this is even included in the constitution (Article 66.3). In
most cases ministers are obliged to appear, though in some countries
(Denmark and Sweden) they have the right not to accept an ‘invita-
tion’ by a committee. But even in weak parliaments ministers in a
strong position normally have an interest in appearing before a com-
mittee as it allows them to promote their cause.
More important than the occasional presence of ministers is the per-
manent presence of civil servants as once part the ‘iron triangles’ of
actors. Networking is important – even in systems with ‘representation
from above’. Case studies have shown that deputies spend more time
contacting elites outside parliament than they invest in the work of
the chamber, party meetings and committees (13.10 hours per week). 51
The broader their network the less focused they are on committee
work. In such cases power of the committees is declining.52
A typology of networks is relevant to the functioning of parliamen-
tary systems (Figure 3.1). Countries have been classified according to
the balance between state dominance and dominance by societal
forces. Pantouflage (I) is identified mainly with France, although only a
few French arenas function according to this model. The dominance of
party cartels (parentela relations) (II) and clientelistic relations (III) has
been considered as typical of Italy since LaPalombara. Liberal corpor-
atism (IV) is strongest in Sweden and Austria and slightly weaker in
Norway and Germany. Sponsored pluralism, iron triangles (V) and
unlimited pluralism (VI) are most common in the United States. But
with the rise of new social movements this type has also developed a
certain minority position in European parliamentary systems. Whole
libraries have been written about the controversy between pluralism
and corporatism. Empirical studies normally stress one or two cases
Figure 3.1 Typology of networks
Dominance of state Protagonists Dominance of society

State agencies Party cartels A number of large Two conflicting Moderate pluralism Unlimited group
social groups large groups pluralism
I II III IV V VI
Pantouflage, Parentela Clientelistic Liberal Sponsored Pressure
dominance of relations relations corporatism pluralism, iron pluralism
state over triangles,
economy, state subgovernment
corporatism
63
and declare the system typical for one type of network and form of
mediation. Most countries have developed a mix of types, with a
certain dominance of one type in various policy fields.53
Lowi’s typology (regulative, distributive, redistributive) has been
used to measure parliamentary efficiency. Regulative measures are most
efficiently dealt with by parliament. For distributive decisions the deci-
sion-making process tends to shift from parliamentary committees to
round tables and workshops outside parliament. In early parliamentary
systems the main task of committees was to control the executive.
With the growth in the importance of the implementation of laws this
controlling power is eroding. Implementation considerations are
having an increasing influence on the decision making of parliaments
and their committees.54
Modern parliaments are normally steered by the party state
(Germany and Sweden). More traditional societies have preserved
certain traits of parliamentary ‘entrepreneurial factions’, such as Italy.55
These extreme poles and lesser degrees of them are hard to quantify.
Only rarely – or at least in some selected policy fields – have more than
one or two key decisions been compared in a transnational way.56
Indicators such as the autonomy of committees and control of the
agenda of committees do not show a direct relationship between party
control and the strength of the committees. In Denmark, Iceland and the
Netherlands, in spite of a highly fragmented party system there is a high
degree of party control over committee agendas. In Austria and Sweden
extensive party control is correlated with a strong committee system.57
Quantitative studies end where historical description normally begins:
there are various factors that influence a system of strong committees.
Weak as well as strong parties can increase the autonomy of committees.
In spite of increasing party control committees can serve to create
greater autonomy for individual deputies in the committees.
Complicated issues strengthen latent ‘grand coalitions’ as the ‘retire-
ment allowances’ for men. Where the work of parliamentarians
involves many contacts or networks outside parliament or in commit-
tees in order to reach a decision, such as in the case of Sweden’s Statens
offentliga utredningar (SOU), there is a danger of blurring the party lines
between government and opposition. 58
3.6 The steering function of parliamentary groups
During the time of the estates there was no need for parties, though
factions and cliques sometimes prevailed. However, parliamentarisation
was not possible without organised parties (see Chapter 2). Nonetheless
it was not until the period after the Second World War, during the last
three waves of democratisation, that parliamentary parties entered the
formal constitutional text. Even then the formulations were rather
restrictive: ‘Meetings, Conventions of parliamentarians, without
orderly convocation are legally binding for the Chambers’ (Spain,
Article 67.3). Even in the twentieth century parliamentary groups have
suffered from the espousal of individual representation and traditional
condemnation of ‘the mischiefs of factions’ (Madison, Federalist Paper
No. X). Extensive regulations are included in the constitution of
Portugal (Article 183) but most parliamentary systems have left the
regulation of parliamentary groups to the standing orders. In Britain
(no. 65, l2) they are mentioned with regard to the constitution of com-
mittees. In many other standing orders as in Denmark, the position of
the parliamentary groups remains obscure.59 In Germany and Finland
parliamentary groups are not even mentioned in the Party Law.
When parliamentary groups were eventually legally codified new
groups arose, for example working groups, which prepare the work of
members of parliamentary committees,60 although for a long time their
legal status was insecure. The working groups and special committees
prepare bills, bridge the gap between deputies and ministers and serve
to convince backbenchers that they are not just Stimmvieh – an uncoor-
dinated mass who are required to vote as they are told.61
The perception of parliamentary groups was determined by the
genesis of parties in parliament. Bourgeois parties developed out of par-
liamentary groups. In the preparliamentary stages of representative
government they had to meet outside parliament, as did the French
revolutionary clubs and the German groups of the revolutionary
National Assembly in Frankfurt in 1848, which bore the names of the
pubs where they gathered. Socialist parties were mostly organised
outside parliament and when they entered the representative assem-
blies they tried to steer their parliamentary groups through the central
party organisation. The early SPD in the diet of Saxony imposed a rule
on their deputies that they were to speak according to a rotation prin-
ciple in order to avoid specialisation and elite-building. Under
Bismarck’s ‘Laws Against the Socialists’ (Sozialistengesetze) party con-
ventions had to be held abroad and the party was outlawed, where-
upon the parliamentary group in the imperial diet strengthened.62
In most parliamentary systems there is a certain balance between
party and parliamentary groups. But during the ideological renewal of
the 1960s and 1970s the party convention and its steering function via
ideological resolutions gained in strength. In some parties the sover-

eignty of the party convention was proclaimed, as opposed to the fac-
tionalism of parliamentarians, as in the Italian Christian Democratic
Party and even the British Labour Party. The balance varied according
to government and opposition parties. Three types of relationship
between government parties and parliamentary groups have been
proposed:
• The parties are dependent on the government (Britain and France).

• The government is dependent on the parties (coalition governments
in multiparty systems, the Benelux countries and Italy).
• Interdependence between parties and government. 63
Again a caveat is needed in order to list countries independent of

historical conditions under one type. In Germany under Adenauer
(1949–63) the party was dependent on government, but under the
Grand Coalition (1966–9) the government was dependent on the par-
liamentary groups and their steering committees. Under most other
chancellors there has been a shaky balance between party and govern-
mental parliamentary groups – especially under Schmidt (1974–82).
Parties are characterised by two main features:
• Their ideological programmes.

• Their organisation.
Ideological steering in European parliamentary systems takes place

through:
• General party programmes and electoral manifestos.

• Coalition agreements (in many countries).
• Programmes developed in the light of government declarations.
Party programmes, even in the post-ideological climate, have rel-

evance for political action and can be defined as ‘mandate’ or ‘agenda’.
Mandate-type programmes emphasise the preferences of the governing
party (Britain, France and Sweden). Agenda-type programmes are
dependent on the mix of coalitions. The emphasis of policy-relevant
items of the programme is close to a ‘transparty faction’. In some coun-
tries (Austria, the Benelux countries, and Germany) the conventional
cleavages have been preserved. This has been explained by the exist-
ence of a strong Christian Democratic Party, which does not exist in
mandate-type countries. The good news of comparative research is that

programmes matter. Neither Sartori’s fear that polarisation would lead
to increasingly extreme ideologies nor the predicted emergence of face-
less, catch-all parties without ideological differentiation have proved to
be correct.64
‘Partyness’, the degree of penetration of parliament by the parties, is
a concept that arose in a time of loose talk about the rise of an inde-
pendent ‘political class’.65 Institutional links between parliamentary
work and the parties and the degree of party discipline were chosen as
indicators. The new systems in the third wave of democratisation in
the 1970s showed that the two indicators do not develop in a symmet-
rical way. In Turkey there are weak institutional links between deputies
and parliamentary groups but a high degree of party discipline. In Italy
the organisational links were moderate, but in the case of the commu-
nists this does not exclude strong party discipline, whereas in the
Christian Democratic Party – torn to pieces by the correnti (factions) –
discipline is comparatively poor. 66 The classification of models varies
over time: from the time of James Bryce the decline of parties in
Congress was taken for granted until a counter movement rediscovered
the ‘legislative leviathan’, streamlined by the parties.67
Parliament as a whole is not a useful unit of investigation, not even
parliament minus the government. 68 Only rarely does the situation
arise in European parliaments where ministers are ‘grilled in an all-
party atmosphere’.69 This does not even happen very often in commit-
tees of inquiry into cases of corruption and scandal, unlike in the US
Congress.
Party discipline is still the most common indicator for research on
parliamentary groups. The organisational literature since Ostrogorski,
Max Weber and Robert Michels has mostly emphasised ‘leadership’,
which was operationalised by research on the parliamentary roles of
speakers, whips, parliamentary group leaders and cabinet members. 70
But more recent research has urged us not to deduce parliamentary
behaviour simply from the behaviour of leaders.71 Time and again ‘floor
revolts’ have disturbed the picture of cohesion even in the Westminster
type of parliament. In the British parliament cycles have been detected:
after the war discipline was high, while in the 1970s it decreased.
Hardly had this decline become general when discipline began to
strengthen again.72
Party discipline has been linked to the structure of government
(numerically strong governments are more tolerant of dissent)73 and to
the traditions of parliamentary culture. In Britain and Australia, which
oriented itself towards the Westminster model, the literature proudly

reports how many defeats prime ministers have experienced. 74 Party
discipline in various party systems exceeds national traditions,
however. The ‘ideological family’ matters in many parliamentary
systems. According to ideology the deputies’ acceptance of party disci-
pline in France has varied from 70 per cent (communists) to 1 per cent
(Gaullists).75 In countries where the profiles of the major parties have
become rather similar, deputies have even nourished the illusion that
party discipline only exists in the competing party.76
‘Roll call analysis’ is the most commonly used instrument to measure
party discipline, especially in the United States, with its loosely organ-
ised parties. In Germany roll calls have been used in 40 per cent of all
major decisions; in other countries they are rare (as in Denmark) or
restricted to certain procedures of parliamentary control. 77 Therefore
comparisons should be drawn with great caution. The reasons for
deputies’ compliance with party discipline also vary:
• Social background data show that professionals and workers have

more party discipline than artisans and farmers. 78 But social back-
ground lost its explanatory force with the establishment of profes-
sional parliamentarians. Party leaders vote more homogeneously
than backbenchers – as is to be expected.
• National cultures have been used as an explanation.79 German party
discipline fitted into the image of that nation until the 1980s, when
the unruliness of the ecological party transformed Germany into a
‘Mecca of deviant political behaviour’.
• Psychological explanations in terms of feelings of group solidarity
explain a lot in unideological political cultures but fail to deal with
cross-national variations.
• The size of the majority explains some of the variation, 80 although
Scandinavian minority government situations have not necessarily
increased group solidarity.
• An important intervening variable is interest group penetration of
committees and social pressure on the major parliamentary
groups. Sometimes strong solidarity in the major parties is less an
indication of the steering capacity of the parties than of the
mobilisational power of organised interests behind the decision
makers.
• Another variable is the size and character of legislation. In countries
where many issues are split into small private bills and leggini the
causes of dissent within the parliamentary groups are minimised.
• Reelection has been a major factor in American studies of party dis-

cipline since Fiorina. In Europe this concept is less useful because
parties control the reelection process to a greater extent than in the
United States. For example German deputies who enter via party
lists and have less reason to fear failure at the next elections do not
show important deviations in parliamentary behaviour from candi-
dates directly elected to the Bundestag. Individualistic rational
choice approaches prefer indicators beyond the sanctions of party
control that reflect the situation of competition in a political market
among and within parties.81
• Party discipline also varies according to policy arena. Roll calls have
been scheduled most frequently in foreign policy and security
policy, and they become more frequent the more the issue deviates
from the status quo, as in the case of redistributive or coercive deci-
sions in parliament.82
• Party discipline varies according to the frequency of recorded votes.
Votes are frequently recorded in Sweden and Germany but only
occasionally in consociational democracies such as Austria and
Switzerland (Table 3.5).83 Electronic voting equipment may increase
the number of recorded votes. The Westminster parliament, which
still votes in the more archaic way, has not shied away from using
recorded votes to secure party discipline.
• Party control is the most widely used indicator of party discipline.
American studies that see a trade-off between factors such as the
hope of reelection and party discipline underrate the sanctions
available in European situations. There is no formal recall in a
system of free representation, but in many parliamentary systems
parties can remove deputies from the committees (Table 3.6).
Exclusion from formal membership is a real threat though it hardly
ever happens.
• Much more important are the positive incentives of the party state,
such as:
– promotion to preferred committees;
– promotion to the role of rapporteur of committee work or commit-
tee chairman to increase the visibility of a politician;
– promotion to an office in the parliamentary group hierarchy;
– governing parties can even offer cabinet posts or the post of parlia-
mentary secretary of state.
The parliamentary party state has frequently been criticised but the
absence of party steering of the legislative process has proved to be
Table 3.5 Frequency of recorded votes
Frequent Rare
Belgium Austria
Finland Denmark*
France EU parliament
Britain Germany
Ireland Greece
Luxembourg Iceland (until 1992)
Norway Italy
Spain Netherlands
Sweden Portugal
Switzerland (until 1993)
* Deviant assessment.
Source: Thomas Saalfeld, ‘On dogs and whips: recorded votes’, in Herbert Döring (ed.),
Parliaments and Majority Rule in Western Europe (Frankfurt: Campus/New York: St Martin’s
Press, 1995), p. 539.
Table 3.6 Can MPs be removed from committees and/or stripped of tasks?
Yes No
Austria France
Belgium Britain
Denmark Ireland
Finland Italy
Germany Norway
Greece Sweden
Iceland Switzerland
Luxembourg
Netherlands
Portugal
Spain
Source: Erik Damgaard, ‘How parties control committee members’, in Herbert Döring (ed.),
Parliaments and Majority Rule in Western Europe (Frankfurt: Campus/New York: St Martin’s
Press, 1995), p. 319.
much more detrimental. The weaker the control of well-organised

parties the larger the number of leggini to provide favours to small
groups.84 Mancur Olson’s theory of rent seeking has been applied to
legislation. Party government in parliamentary systems diminishes the
dependence of deputies on local and sectoral special interests. The
smaller the constituencies the more independent the parliamentarians.
In new democracies without an established party system – according to

one hypothesis – semipresidentialism has to serve as a functional
equivalent of party control in order to avoid special interest legisla-
tion.85 Whether this hypothesis applies to the Russian Ukazokratiya
remains to be investigated empirically. Some doubts remain.
The praise of party control is mostly based on the legislative func-
tions of parliament. As far as other functions are concerned, such as
articulation of interests and communication, most proposals for parlia-
mentary reform try to strengthen the individual deputies. Primary elec-
tions are often recommended in the light of the Icelandic example. 86
The American example is invoked by recommending increased use of
professional electoral managers and consultants.87 In some systems the
party organisations have an overwhelming influence on candidate
selection, as in France in the early Gaullist years, when candidates were
imposed on provincial constituencies by Paris – the so-called para-
chutés.88 In times of decentralisation and regionalism such abuses have
mostly been overcome. Party determination of parliamentary candi-
dates depends on the size of the constituency and the electoral law. In
countries where party lists of candidates are drawn up – some of whom
do not even run for a direct mandate – party control is greater than in
simple single-vote constituencies (as in the case of Germany). To sum
up: in many respects, the removal of party control over parliamentary
work remains a dream – and in some respects not even an agreeable
one.
4
Functions of Parliaments
The elective function is now the most important function of

the House of Commons. It is most desirable to insist, and be
tedious on this, because our tradition ignores it.
Walter Bagehot
Since Bagehot many catalogues of the functions of parliaments have

been offered. Bagehot considered the elective function to be the most
important one. The expressive function, the teaching function and
the informing function were connected to the relationship between
deputies and their voters. In modern typologies they are condensed
under the rubric ‘the function of representation and articulation of
interests’. The teaching function is no longer vested in the parties,
but rather has shifted towards the media. The function of legislation
was the last to be mentioned by Bagehot, although citizens have
demonstrated in surveys that they associate parliaments above all
with legislation.1 Four functions have to be examined in order to
assess the impact of parliamentary work on government – legislative
relations.
• The relationship between deputies and citizens: the representation

and articulation of interests.
• The relationship between parliament and government: the control-
ling function.
• The relationship to the needs of society: the legislative function.
• The relationship of parliament and government: the recruiting
function.
72
Functions of Parliaments 73
4.1 Representation and articulation of interests
Representatives are in a twofold way related to the electorate:
• To the nation as a whole.

• To the sectoral interests of the people.
The first relationship is combined with the fictitious assumption that

the people of a nation are present in the actions of its government.2 The
symbolic constitution of the ‘whole’3 is not identical with representa-
tion in civil law. Popular talk about the parties being represented in
parliament is wrong because only citizens can be represented.
Representation is a relationship of power: as Max Weber put it, ‘because
the represented accept acts of their representatives as legitimate’.4
When modern parliaments developed out of assemblies of separately
deliberating estates the idea was that the representatives had a
‘mandate’. Many deputies in the French Revolution, for example Lally-
Tollendal, demanded the chance to return home to obtain a new
mandate when the estates transformed themselves into a unified
national assembly. For reasons of efficiency even radicals such as
Robespierre asked for free representation without mandate. The people
– turning away from Rousseau’s ideas – could only veto the laws passed
by the assembly.
One element of this thinking on the mandate was preserved in the
second aspect of representation, the articulation and aggregation of
special interests in a pluralist society. Also in this respect, ‘free repre-
sentation’ was advocated very early on. In 1774 Edmund Burke made it
clear to his voters in Bristol that ‘Parliament is not a congress of ambas-
sadors from different and hostile interests’. 5 The representative owes
his voters ‘close correspondence’, or ‘responsiveness’ in today’s terms.
But Burke made it clear that the deputy would betray and not serve his
electors if he accepted special mandates.
Early liberals developed the idea of free representation because of
their notion of ‘virtual representation’ of the large majority who had
no right to vote. Thus representation was a kind of juste milieu between
an absolutist crown and the masses ‘without political reason’. Absolute
democracy in this concept was as bad as absolute monarchy.
Parliamentarisation of the regime was demanded – not democratis-
ation. In the French Revolution repraesentatio in toto and repraesentatio
singulariter were discussed and used as indicators for the representative-

ness of parliamentary assemblies. 6 Later Lincoln’s famous Gettysburg
formula ‘government of the people, by the people, and for the people’
extended the indicators. Representation, which does not only invoke
an holistic mystique, has to respond to three claims:
• ‘Of the people’ can only mean that in a representative democracy

the people can influence the selection of representatives.
• ‘By the people’ could mean that the representatives have some
social similarity with their voters.
• ‘For the people’ means responsiveness to the wishes and demands of
the electors.
4.1.1 Influence of voters on candidate selection

The influence of voters on candidate selection in European parliamen-
tary system – where there are no primary elections as in the United
States and Iceland – is very limited. Mandates are forbidden in most
constitutions. The responsibility of deputies to their conscience is
emphasised (Denmark, Greece and Germany). Traditional constitutions
have tried to avoid too close a contact between elector and elected:
sometimes it is forbidden to hand petitions personally to a deputy as
this might put pressure on the representative to act (Belgium, Article
57; Luxembourg, Article 67). Neutral zones around parliamentary
buildings in which meetings are forbidden are commonplace on the
continent. The German word Bannmeile has preserved its repressive
character and prevents parliament from becoming a multifunctional
attraction for tourists, as are the US Congress on Capitol Hill and the
Australian Parliament in Canberra.
Contacts between elector and elected are individual – even though
mass petitions sometimes create a collectivist atmosphere. The selec-
tion of candidates in European parliamentary systems is limited to the
party members in a constituency. Primary elections have been
demanded time and again. The extremely low voter turnout at general
elections has been the counterargument levelled by the party establish-
ment in most countries for sticking to the status quo.
4.1.2 Social representativeness

Social representativeness has been demanded time and again but is
nevertheless declining in modern parliaments. Representativeness
differs between the various models, such as the ‘participatory model’
(Belgium and Italy) and the ‘elitist model’ (Switzerland). Styles of
representation are shaped by the size of constituencies, the type of

party organisation, the degree of party density among the electors
and the political culture. 7 There is more research on the role percep-
tion of representatives among deputies than among electors.
Unfortunately there are hardly any cross-cultural studies. There are
three concepts:
• The party principle (party line first, own view second, voters’ opinion
third). In Sweden 47 per cent of representatives but only 13 per cent
of voters are oriented towards the party principle. In the United
States, where the parties play a more limited role, party-oriented
politicians are called ‘politicos’. 8 In a classical partitocrazia such as
Italy, the identification as a party delegate was widespread in all the
parties: most strongly among the communists (65 per cent), but also
among the Christian democrats 50 per cent.9
• The trusteeship principle (own opinion first, party line second, voters’
opinion third) dominates 32 per cent of deputies and 28 per cent of
voters in Sweden. This principle has lost support in many countries,
as studies on the United States, Britain, Italy and France show.10
• The delegate principle (voters’ opinion first, party line second, own
view third). This is the most popular principle among voters (52 per
cent) but not among parliamentarians (14 per cent).
The democratic concept of ‘government by the people’ demands

representation from below, but in reality ‘representation from above’
has increased in many parliamentary systems.11 At no stage have
parliaments represented a balance in social composition between rep-
resentatives and represented. For Britain it is said that MPs are mostly
male, middle aged and middle class. 12 In France there is a preponder-
ance of professionals and higher civil servants. 13 Amateurisme among
representatives is a consequence of this recruitment pattern. 14 German
parliamentary statistics have ceased to include the rubric ‘worker’.
Civil servants make up more than one third of deputies. A further half
are former white-collar workers and professionals.15 In Sweden blue-
collar workers and farmers are declining drastically as a political
category.16 Social backgrounds have become increasingly less diverse
as the social milieus of the parties blur. Class has become less impor-
tant than ‘milieu’. The social structures of bourgeois and labour
parties have converged even in polarised, majoritarian, Westminster-
type systems. Blue-collar workers have been replaced by their white-
collar counterparts.17
Most systems have abandoned social representativeness. With the

new social movements and the new social fragmentation, however,
new demands for recognition have sprung up. ‘Political correctness’
demands the fair representation of women and ethnic groups. In
Germany, however, surveys show that the average voter is rather indif-
ferent about this. Almost one quarter express a preference for a repre-
sentative from the same area (in many regions dialect plays still a
certain role), but local links are less developed in Europe than in the
United States. 18 The localism of American deputies who hardly need
the support of their party for reelection, existed in the early French
parliamentarism of the Third Republic (1871–1940). 19 Some consider
that this type of representation will return if the parties continue to
wither away.
The social links between deputies and voters are also affected by the
size of the constituency. A Swedish parliamentarian represents only
half of the number of constituents of a British MP. 20 Where direct
mandates and list mandates are parallel – as in Germany – the social
links between representative and represented are normally weaker.
Voters have largely accepted the social gap between them and their
representatives. In Germany only 22.4 per cent prefer to be represented
by deputies of the same class, 17.8 per cent by the same generation and
only 9.9 per cent by the same gender.21
Nevertheless the elites – rightly – continue to fight for a fair propor-
tion of women. Between 1945 and 1995 women’s share in parliament
only increased from 2.2 per cent to 9.4 per cent. In the European
Union the proportion of women deputies varies from 40.4 per cent in
Sweden down to just 6.3 per cent in Greece (Table 4.1).
In the early to mid 1990s the quota arrangements ranged from
20 per cent in the Irish Labour Party and 25 per cent in the Belgian
Volksunie to 50 per cent in three Swedish parties, the British Labour
Party, the German post-communist PDS and the Green Parties in
Austria and Germany. Legal regulations have improved the situation. A
Finnish Law of 1987 helped to increase the representation of women
from 25 per cent in 1980 to 48 per cent in 1996.
Political correctness, however, can end up squaring the circle. The
various proportional arrangements are not always compatible. The
number of Turkish representatives may have increased in Germany,
but this has led to a decrease in the proportion of women. Even when
there are more women representatives the bad news is that the social
composition among female deputies is more elitist than among men. 22
Table 4.1 Women in parliament and quota requirements in EU countries

(per cent)
Country Proportion of women in Quota of women in the parties

parliament
Austria (1995) 26.8 Green Party 50%

ÖVP 33%
SPÖ no indication
Belgium (1995) 12.0 Volksunie 25%
Denmark (1994) 33.0 Social Democratic Party 40%
Finland (1995) 33.5 –
France (1993) 6.4 PS 30%
Germany (1994) 26.2 Green Party 50%
PDS 50%
Social Democratic Party 33%
Britain (1992) 9.5 Labour Party target 50%
Greece (1996) 6.3 –
Italy (1994) 11.1 –
Ireland (1992) 13.9 Fine Gael target 40%
Labour Party 20%
Luxembourg (1994) 20.0 –
Netherlands (1994) 31.3 –
Portugal (1995) 13.0 –
Spain (1996) 24.6 –
Sweden (1994) 40.4 Social Democratic Party 50%
Communists Party 50%
Green Party 50%
Liberal Party (FP) 40%
Source: Interparliamentary Union (ed.), Men and Women in Politics. Democracy Still in the
Making (Geneva); Interparliamentary Union (ed.), ‘Women in Parliaments’, World
Statistical Survey (Geneva, 1995).
The social gap between representative and represented is also increas-

ing as a result of professionalisation. 23 This has led to much criticised
consequences, such as:
• The number of years of vocational experience before entering

parliament is decreasing.
• The possibility of keeping in touch with the original vocation while
serving as a deputy is decreasing, except where politicians abuse
their position and earn considerable salaries by sitting on the boards
of public enterprises.
• Readiness to return to the former career after a political career is also

declining. This leads to the creation of a social safety-net of jobs for
former deputies in order to limit the hardships of downward social
mobility.
‘Representation from above’ in modern parliamentary systems contra-

dicts the idea that parliaments are completely democratised. This
development represents a return to early parliamentary systems and
‘virtual representation’ – albeit no longer under conditions of limited
electoral rights where the majority were excluded from voting. Rather
it is voluntary self-exclusion that accompanies representation from
above: diminishing party identification and electoral turnout increas-
ing volatility. This system could end in crisis if growing responsive-
ness does not compensate for the social gap between deputies and
electors.
4.1.3 Responsiveness
Responsiveness rather than representativeness is the device of post-
modern parliamentarianism. Surveys reveal that voters are more inter-
ested in correspondence of views on policy issues than on
representational style. Whereas the social distribution of electors and
elected is increasingly diverging, electors’ and representatives’ views on
policy are converging. 24 Interest representation in parliament is con-
ducted less by direct representatives in parliament and more by net-
works within and outside the legislature (see Chapter 3).
Responsiveness under conditions of ‘representation from above’ in
parliamentary party states is less an individual relationship than sensi-
tivity to the collective needs and demands of the electorate. This sensi-
tivity had led to a ‘migration of interests’. The ecological domain reservé
of the Green Parties has been taken over by the established parties
causing the focus of activity for the Greens to be shifted to disarma-
ment and gender questions.25
In the United States three types of responsiveness have been
differentiated:
• Symbolic responsiveness.
• Policy responsiveness.
• Responsiveness in the form of rendering services to individual
voters.26 The latter plays only a minor role in European welfare
states, where citizens are accustomed to turning directly to the
state.
The responsiveness of parliamentarians is reflected in the confidence

citizens have in various institutions. Parliaments in this respect attract
more confidence than the administration but less than institutions
closer to the citizens, such as the churches and the education and legal
systems (Table 4.2). Only in Denmark, Ireland and France has the
administration attracted more confidence among citizens than parlia-
ment. In international comparisons Germany, a country denounced
for its statist attitudes, has polled top rates for confidence in parlia-
ment (52.52 per cent), above Britain, the mother of parliamentary gov-
ernment (40.46 per cent). Norway came out on top (with 78 per cent
in 1981 and 59 per cent in 1990). In Italy the confidence of citizens in
their parliament was so low in 1981 (30 per cent) that development
could only be upward (32 per cent in 1990). Italy is a deviant case in
many respects: in the light of continuing corruption not even the legal
system seems to be more trustworthy than parliament.
Table 4.2 Trust in institutions in parliamentary democracies (per cent)
Country Parliament Administration Army Legal Church Police Media Business

system
Belgium 1981 39 47 43 58 65 64 35 44
1990 43 42 33 45 49 51 44 50
Denmark 1981 – 47 40 80 48 85 30 34
1990 42 51 46 79 47 89 31 38
Germany 1981 52 33 53 67 44 70 31 34
1990 51 39 40 65 40 70 34 38
Finland 1981 65 53 71 84 49 88 34 –
France 1981 56 53 55 57 54 64 33 49
1990 48 49 56 58 50 67 38 67
Britain 1981 40 48 82 66 47 86 29 50
1990 46 44 81 54 43 77 14 48
Ireland 1981 53 55 76 58 79 86 44 50
1990 50 59 61 47 72 86 36 52
Italy 1981 30 27 56 43 58 65 31 33
1990 32 27 48 32 63 67 39 62
Netherlands 1981 45 45 43 65 40 73 28 35
1990 54 46 32 63 32 73 36 49
Norway 1981 78 58 68 84 50 89 41 45
1990 59 44 65 75 45 88 43 53
Portugal 1990 34 32 47 41 57 44 36 45
Sweden 1981 47 46 61 73 39 80 27 42
1990 47 44 49 56 38 74 33 53
Spain 1981 49 40 63 50 49 64 48 39
1990 43 37 42 45 53 58 51 49
Source: Hans-Dieter Klingemann and Dieter Fuchs (eds), Beliefs in Government. Vol. 1: Citizens and the State
(Oxford University Press, 1995), p. 304f.
More telling than the global figures on confidence is a typology of

the reasons for confidence, such as affective and cognitive reasons. The
first assesses the importance of parliaments in a political system, the
second the imputed influence on political decision making. It can be
shown (Table 4.3) that British citizens have deeply internalised the top
position of their parliament in the light of the doctrine of ‘parliamen-
tary sovereignty’. They are, however, less convinced about its influence
and confidence is even lower in Britain than in Germany or France, the
latter with its extremely weak parliament. 27
On the other hand Italians have little confidence in their parliament
but a high appreciation of its efficacy. Symbolic responsiveness in
countries with a monarch – as in Belgium – is frequently more vested
in the crown than in government and parliament, though the majority
no longer think that the crown is an ‘effective part’ of the modern
constitution.28
The democratic credo has frequently led to a perception of ‘dynamic
representation’, in which policies follow changes in public opinion.29
However, public opinion and published opinion are hardly driving
forces of policy making, and in most cases not even of agenda
setting.30 Representation from above has been deeply internalised by
great leaders, as demonstrated by the bon mot of Theodore Roosevelt: ‘I
simply made up my mind what they [the people] ought to think, and
then did my best to get them to think it’. 31 The responsible party
model, which has served as an ideal for a while in the United States,
seems to be more common in European parliamentary systems than in
the presidential system of the United States.32
Table 4.3 Voters’ esteem of parliaments
Affective confidence Cognitive confidence
Importance in political system Influence in policy-making
Germany Britain Italy

Ireland Germany Netherlands
France Netherlands Sweden
Britain Belgium Germany
Italy France Britain
Italy France
Ireland
Source: Philip Norton, ‘Legislatures’, West European Politics, vol. 13, no. 3 (1990), p. 146.
Policy responsiveness has limits. In some arenas public opinion has

no specific demands – as in routine foreign policy. In other fields par-
liamentarians have to be responsive, as in welfare policies. In some
policy arena, however, they are more enlightened than the majority of
the voters and not inclined to bow to every wave of populist pressure
for rigid laws. Surveys have shown that the higher echelons of the
intelligentsia are inclined to doubt that parliamentarians follow public
opinion.33 Conservative parliamentarians, on the other hand, fre-
quently do not accept the advice of experts (in gene technology for
instance) and hide their distrust behind public opinion polls that indi-
cate that for certain decisions there is no acceptance among the
voters.34 Empirical studies show that in two thirds of cases the elites are
able to change the voters’ opinions.35
Communication flows are not simply between representative and
represented. The participation of the electors starts at the local level
and party organisations aggregate the impulses which normally end up
in a decision that is a mixture of majority building and compromise
with minorities.36 The idea that deputies always follow their conscience
is hardly realistic, but it serves as a normative barrier to make sure that
not every special interest can put the representatives under pressure in
a model of one-way communication.
4.2 Controlling functions
Parliamentary control is the function of legislatures that has declined

most rapidly. Part of this erosion was inevitable: only preparliamentary
constitutional systems functioned in such a way that the majority of
parliament were in frequent opposition to the king’s government. 37
Most parliamentary systems – even non-consociational systems – have
guarantees for minorities in the process of amending constitutions and
the standing orders of parliament in order to protect the possibilities of
oppositional control.38 The danger in modern parliamentary systems is
not so much that majorities will change the rules of the game, but
rather that the complexity of policies will make parliament less and
less amenable to control. Some parliamentary systems do not postulate
the direct accountability of the administration to parliament (Belgium,
Denmark, Germany, France, Japan, Norway, Austria and Portugal).
Efficient parliamentary responsibility of the government indirectly
includes control over the administration, which is responsible to the
minister (Table 4.3, column 1). Technocrats tend to think that efficient
control might weaken the efficacy of the administration, but empirical
studies have come to the opposite conclusion. 39 Originally ‘control’

was conceived as a one-way process. But the reports in parliamentary
democracy, which initially were meant to control the activities of the
ministries, have been used for the opposite of communication: min-
istries use reports not to respond to control but to anticipate possible
criticism by efficient propaganda to show their efficacy.40
In all representative systems the introduction of the annual state
budget is an important occasion for parliamentary control. In dualis-
tic systems, such as those of the United States and Switzerland, this
control can be very efficient. It is least efficient in majoritarian par-
liamentary systems. Bagehot dismissed the idea of a sixth function,
the financial function, and he doubted that the House of Commons
had any special function with regard to finances that differed from
its competence with respect to other legislation.41 Budgetary matters
are controlled by the government and by organised interests, so that
a democratic opening of this process presents the danger of a dead-
lock between the executive and the legislative powers. 42
The instruments of control have been differentiated in most parlia-
mentary systems. On the one hand greater transparency has been
introduced, on the other hand the flood of questions and interpella-
tions has had to be streamlined (Table 4.4, column 3). The introduc-
tion of TV cameras has revitalised the culture of control by questions,
but it can also be used for propaganda purposes, for example the gov-
ernment may invite specific questions from its parliamentary group.
Moreover the instruments of control are frequently misused by
conflicting parties that do not really have control of the government in
mind. Deputies and parties in search of an individual profile, services
of deputies to interests in their constituency and sometimes even the
search for material to prepare a speech are the proportional extrinsic
motives of the use of controlling instruments in parliament.43 In some
countries the relevance of question was analysed and it was found that
only 2 per cent of all interpellations concerned the general policy of
the government. 44 In other countries the number of questions have
been counted but the answers of ministers have rarely been studied in
a systematic way,45 though perhaps the results of such a study would
bear no relation to the effort involved.
The instruments of parliamentary control and their effects
include:
• The French instrument of interpellation, which has frequently and

unexpectedly toppled governments.
Table 4.4 Parliamentary means of control
Administration accountable to Right to put questions Right to interpellate

parliament
Australia Indirectly through ministers Written answer in 15 days No, but right to put questions in debates
Austria No Oral and written, 60 minutes at No, but urgent questions allowed
beginning of sitting of the House
Belgium No Oral and written, one hour weekly in Lower house no, senate weekly. May
chamber, half-hour in senate result in a motion approving or
disapproving government’s action
Czech Republic Under Article 53
Canada Indirectly through ministers Oral and written, 45 minutes daily No
Denmark No Written, answer in No
six days
Finland Indirectly through ministers Oral and written Rare, constitutional motion possible
France No Oral and written without debate. One day National assembly, oral and written,
per week, minister present. Written One tenth of assembly, motion of
answer in one month censure possible
Germany No States on two weeks’ notice. Time is No specific provisions
variable
Britain Upper house yes Regular and urgent, 55 minutes per No, but half hour adjournment debate at
session, 20 minutes per day end of session
Greece Yes 10 minutes per question No, but half hour adjournment debate at
end of session
Ireland Indirectly through government One hour per week in both houses. Oral Adjournment debate, half hour
(Article 28) and written three days
83
84
Table 4.4 continued
Administration accountable to Right to put questions Right to interpellate

parliament
Israel Indirectly through ministers With notice, two hours weekly Where answer is unsatisfactory, ‘agenda
motion’
Italy Indirectly through ministers Oral and written twice per week, written Chamber, yes
answer in 20 days
Japan No Yes, written answers in seven days No
Luxembourg Indirectly through ministers Oral and written, half-hour each Tuesday No
New Zealand Indirectly through ministers 40 minutes daily, written answer in One hour’s debate on questions every two
seven days weeks
Netherlands Indirectly through ministers Any time, written debate once per Yes
month
Norway No Written, five days’ notice, debate 1–4 hours No, but urgent questions with participation
weekly by party leaders
Portugal No One session per day, oral and written, eight No, but each group may initiate an
days’ notice interpellation and debate on two topics
Spain Indirectly through government Once weekly (Article 111), oral and written in Yes, interpellation can raise debates and
(Articles 97. 108) senate, two hours in congress, answer in motions
20 days
Sweden No, but through ombudsman Written with oral answer Interpellation by any MP within four
weeks of notice
Source: Parliaments of the World, vol. 2 (Aldershot: Gower, 1986), p. 839ff.

• Urgent questions (as in Austria, the Scandinavian countries, Portugal

and Spain) have been listed by the Interparliamentary Union under
the rubric ‘interpellations’ – though they do not have the same
influence on the fate of the government.46
• Westminster-type adjournment motions have developed into a system
of responsible (but rare) use of motions of no-confidence.
The Interparliamentary Union has found evidence of individual min-

isterial accountability in 31 states (Table 4.5). Even in Britain, where
the position of the prime minister and party solidarity have been
strong in the twentieth century, quite a few ministers have resigned
after hostile parliamentary votes – most, however, had already lost the
confidence of their party and the prime minister. In Germany, the vote
of no-confidence against individual ministers has been revitalised as an
instrument by the Green Party, which used it seven times in the first
legislature in which it was represented (1983–87), but without success
as the governing coalition had a solid majority.47
In modern, rationalised parliamentary systems, the prevailing con-
vention is that a government or a minister should not have to resign
because of a simple hostile vote. Italy has even codified this principle
in its constitution (Article 94.3). In the Westminster model this princi-
ple was accepted from the outset.48 Rationalised parliamentary systems
have even tried to regulate the deliberate use of the mechanisms of
confidence by introducing the ‘constructive vote of no-confidence’
(Germany Article 65, Spain Article 114.2, Belgium Article 96).
Psychologically this regulation is rather destructive than constructive
because members of the cabinet have to conspire behind the back of
their prime minister in order to negotiate a new majority. The Spanish
idea of ‘constructive opposition’49 is somewhat of a contradiction in
terms. The limitation of conflicts in parliamentary systems found other
milder institutions to regulate votes of no-confidence by imposing a
post-vote time-span in which no second vote is possible (France Article
49.2; Greece Article 84.2; Portugal Article 197). Explicit and regular
votes of no-confidence leave governments with no choice but to
resign, even in semipresidential systems, Russia included.
Most deputies are dissatisfied with the exercise of the controlling
function. 50 The less specialised the committees the weaker the
control.51 In many countries parliamentary control seems to be less
efficient than competing controlling institutions such as ombudsmen,
judicial reviews or institutions for the evaluation of policies. The
details of the assessment of the consequences of new technologies are
Table 4.5 Ministerial accountability and duty to resign from office 86
Ministerial accountability Duty to resign if no

Collective Individual dissolution of parliament
Australia Yes Yes Refusal of budget in senate:

Vote of no-confidence in house of
representatives
Austria National council (Article 76) Constructive Vote of no-confidence in Parliament
Belgium Yes (Article 101.96) Rarely Hostile vote in general politics in both
chambers
Canada Yes, by convention Yes Vote of no-confidence in Commons
Denmark Yes (Article 13) Yes Vote of no-confidence
Finland Yes (Article 36b) Vote of no-confidence
France Yes (Article 49.50), 48 hours after refusal No Vote of no-confidence with absolute
of bill; no bill in the same week majority
Germany Yes Yes (disapproval usually Constructive vote of no-confidence
without consequences)
Britain Yes, by convention Yes Hostile vote, which is evaluated as a
confidential matter
Greece Yes (Article 84) if refused; no new bill for Yes (Article 84.2) Vote of no-confidence
six months
Ireland Yes (Article 28.10) No Withdrawal of confidence
Israel Yes No Not applicable any more, head of state
elected by people (Article 115)
Table 4.5 continued
Ministerial accountability Duty to resign if no

Collective Individual dissolution of parliament
Italy Yes (Article 94) No Vote of no-confidence, not if

government bill is refused
Japan Yes (Article 69) No Vote of no-confidence or refusal of vote
of confidence
Luxembourg Yes (Article 78) Yes Withdrawal of confidence
New Zealand Yes, by convention No Withdrawal of confidence
Netherlands Yes, by convention Yes No-confidence in both chambers
Norway Yes (Article 86, impeachment of minister) Yes Vote of no-confidence
Portugal Yes (Articles 193, 194) No Vote of no-confidence and refusal of
President and parliament refusal; no question of confidence or of
further bill in the same parliamentary government programme (Article 194)
session
Spain Yes (Articles 108, 114) No Constructive vote of no-confidence
President and parliament refusal; no (Article 114)
further motion in the same
parliamentary session (Article 197)
Sweden Yes (Chs. 1.6, 6.5) Yes Withdrawal of confidence in parliament
87
increasingly vested in an office outside parliament, though parliament

and its special committees are responsible for control.52
Although representatives complain about the inefficiency of parlia-
mentary control, countries where control is more efficient, as in the
United States, surveys have found that many deputies do not really
want more efficient control over the administration because the
bureaucracies or big enterprises in their constituencies are afraid of
increased supervision. Great control could lead to a loss of votes
instead of a gain in support. 53 Only public opinion demands greater
parliamentary control and the instruments of control have been
improved in most European countries since the 1970s. 54 But these
improvements have not really improved efficiency because the increas-
ingly complex risks and dangers – ranging from international move-
ment of nuclear waste to gene technology – have rendered all the
controls only partially efficient.
4.3 The legislative function
When asked to name the most important function of parliament, most

citizens would suggest legislation. In a survey in Belgium legislation
was mentioned three times more frequently than control. 55 In many
countries, however, parliament is not the only institution with
legislative functions:
• In many countries there are referenda and popular initiatives.

• In federalist systems the federal units have parliaments of their own.
• In some states regional assemblies sometimes have the right to initi-
ate legislation (the Åland islands in Finland, the Azores and Madeira
in Portugal, the autonomous regions in Spain).
• A few functional bodies have a say in legislation. For example the
Italian Council of Economics and Labour.
• In traditional constitutional systems even the monarch has the right
to play a part in legislation (Article 82 of the Netherlands) and in
semipresidential systems de facto and sometimes even de jure, presi-
dents have an important role to play (Table 3.6).
Delegated legislation of the government by decree is another instru-

ment that competes with the legislative functions of parliament. Even
in semipresidential systems – with the exception of Russia – this type
of initiative by the head of the state is normally subject to the counter-
signature of the government. In France the prime minister signs about
Table 4.6 Participation in legislation
Right of initiative Initiative of people Extra-parliamentary consultation

Australia Majority by government; budgetary laws Possible relevant bodies
not in senate (Article 53)
Austria Government: eight ministers must sign Article 41: 100 000 voters, one Before cabinet decision: chamber
private member bill sixth in three states of labour and chamber of commerce
Belgium Monarch, senate, representatives, all Experts
deputies (Article 27)
Britain All deputies, budgetary laws only by
government
Canada Government and parliament (both Possible
houses)
Denmark government, prime minister, monarch One third of Folketing may Each citizen can demand admission
(§ 21) demand referendum (Article 42.1) committee
Finland (§ 2, 2a) President, parliament Experts
government, president: veto (Article 19)
(§ 18, 2) Budgetary committee, Lutheran
church, Åland (provincial assembly)
France Government and parliament, deputies Referendum (Article 11) Social and economic council,
except for budgetary laws, prime minister statement of council of state
and council of ministers (Article 39)
Germany Government, Bundestag, Bundesrat Government and committees
Greece Government and parliament, budgetary Possible
restrictions
Ireland Seven deputies in parliament, three Referendum (Article 47) Especially if white paper has been
senators, house leader, government in published
89
parliament
90
Table 4.6 continued
Right of initiative Initiative of people Extra-parliamentary consultation

Israel Government, deputies, committees Yes
(Article 83.3)
Italy Government, both houses, regional 500 000 voters and five regional Committees
councils, national economic and labour councils (Article 75: repeal of a law)
council
Japan Government, deputies, committees
Luxembourg Parliament and government Council of state, committees
New Zealand All deputies, budgetary laws only by Obligatory with electoral laws Government
government
Netherlands Government (both chambers), monarch Council of state consisting of
(Article 82), organisations may petition former ministers, senior officials
social-economic council
Norway Monarch, government, members of
Odelsting, veto of monarch (§ 78.2)
Portugal Government and deputies, regional Referendum (Article 170)
assemblies (Azores and Madeira),
budgetary laws
Spain Parliament, 25 senators or deputies, Consultative 500 000 voters
parliamentary groups autonomous (Article 92.1)
regions (Article 92.1)
Sweden Formally Riksdag, de facto Government Consultative (ch. 8 § 4) Legislative council (ch. 8 § 18)
Source: Parliaments of the World, vol. 2 (Aldershot: Gower, 1986), pp. 839ff.
1500 decrees a year, of which the president is said to initiate about 50,
although the Council of Ministers has to approve them.56 In the Third
and Fourth Republics the requirement for presidential decrees to be
countersigned was aimed at limiting the powers of the head of state. In
the Fifth Republic this mechanism was weakened. 57 The president’s
veto gave him the powers to blackmail his government.58 In Russia the
president has the right to issue decrees (ukazy) without the signature of
the prime minister and to veto laws of the parliament. A system of
ukazokratiya has frequently paralysed the legislative competences of the
Duma. Ministers are legally responsible for decrees; the de facto initia-
tive, however, is shifting more and more from political to administra-
tive leaders. 59 In order to stop the shift of legislative powers to
institutions outside parliament some constitutions have tried to secure
matters exclusively for parliament. In Portugal (Article 168) 23 areas
are reserved for parliament. In countries with judicial review of legisla-
tion – as in Germany – the Constitutional Court has defended the
exclusive rights of parliament (Gesetzesvorbehalt). The result, however,
has been an overburdening of the Bundestag and a strengthening of
the ministerial bureaucracy, which has to prepare all the laws and
burdens parliament with petty regulations and details that distract it
from more important issues.
Judicial review in some respects has developed into a kind of colegis-
lation process since parliamentarians tend to anticipate possible ver-
dicts of the court. In a German study of 150 key decisions, 40 per cent
of important decisions were taken to the court and in a further 12 per
cent of parliamentary debates the threat was used by one or other party
opposing a bill that they would ask for a review in the Karlsruhe court.
In Italy too the court system has strengthened the legalistic way to
solve political conflict and thus influenced legislation. 60
Consultation and participation by non-parliamentary institutions is
provided for in some constitutions, as in the case of the Swedish legis-
lation council. The proliferation of legislators has also been increased
by the formation of the European Union. Transnational statistics by
the Interparliamentary Union include parliamentary and governmen-
tal initiatives, but in many cases the search for the political initiative
behind the legal initiative is more interesting. In Germany 20 per cent
of bills and 6 per cent of key decisions are initiated by Brussels, more
than 12 per cent result from court sentences and 8 per cent by advisory
committees.61
Parliamentary initiatives are decreasing in all parliamentary systems
(Table 4.6, column 2). Data from the Interparliamentary Union
frequently need to be used with caution, especially those at the end of

legislature.
In Belgium and the Netherlands bills do not die and there is a danger
of double counting. In Sweden more laws are passed than bills intro-
duced because of the peculiarities of the Swedish counting system.
Döring’s team has improved the data by weighting them, but the
Swedish figures are still not comparable.62 Some countries with a high
proportion of parliamentary bills, such as Belgium, Canada, Finland,
France, Britain, Israel and Spain, do not show high ratios of success. In
some countries private members’ bills are discriminated against
because they are not allowed to entail financial obligations, thus limit-
ing initiatives more or less to costlest regulations and symbolic laws
(Britain, standing orders; Greece, Article 75).63 In Italy government ini-
tiatives are privileged because they are mostly handed over to the com-
mittees for a decision, which is not the case with private members’
bills.64 Comparing the figures on legislative output (Table 4.7) one
would suspect that in the Westminster model there are few private
members’ bills and very few of these have a chance of becoming law.
Canada is an exception in this respect, but although there are many
private initiatives very few are successful. Consociational systems such
as Austria, Belgium and the Netherlands could favour private members’
bills, but in the Netherlands the contrary is true. Prime ministerial
systems that tightly control the agenda of parliament and reduce leg-
islative output should also reduce the number of private members’
bills. This is true in Australia, Ireland and New Zealand but not in
Britain and Canada. Germany is a misleading case. The relatively high
proportion of parliamentary initiatives are an artefact of the legislative
procedure which is only required for governmental proposals – a
reason for the government to induce sham parliamentary initiatives.
Even in Britain not all private members’ bills are truly private initia-
tives. Even in that country procedural advantages are calculated by
governmental majorities.65 More important for parliamentary auton-
omy in legislation is the share of the opposition in initiating legisla-
tion. In the Westminster model the opposition does not aim at
colegislating. Cooperative work in legislation is frequently found in
consociational democracies, such as Austria. Germany is between these
two poles, but with some inclination towards legislative cooperation.66
But again these are not permanent. Especially in German postwar
history cooperative and conflict-oriented periods of legislative behav-
iour have succeeded each other. Germany is not always a ‘grand coali-
tion state’ (M. G. Schmidt). After the Second World War the opposition
Table 4.7 Legislative output, 1978–82; 1980–89 in the lower house
Government Passed Bills filed by Passed Total number

bills deputies passed in 1980–9
Australia 237 229 11 1 n.a.

Austria 74 71 40 20 121
Belgium 55 29 187 11 64
Britain 57 53 100 10 62
Canada 55 33 209 4 n.a.
Denmark 171 151 89 5 165
Finland 259 253 238 3 343
France (senate) 93 77 125 7 94
Germany 79 80 28 16 83
Greece 128 98 19 0 88
Ireland (senate) 52 47 5 0.5 35
Israel 98 89 197 19 n.a.
Italy (senate) 418 214 1005 93 264
Japan 127 97 20 1 n.d.
Luxembourg 63 64 4 1 66
New Zealand 197 193 12 0.5 n.a.
Netherlands 135 139 6 2 134
Norway 75 74 8 1 98
Portugal 126 17 55 26 69
Spain 80 65 57 8 56
Sweden c. 200 Most 2400* Most 375
* Number includes amendments to government bills.

Source: R. B. Andeweg et al., in Herbert Döring (ed.), Parliaments and Majority Rule in
Western Europe (Frankfurt: Campus/New York: St Martin’s Press, 1995), p. 171; Döring,
ibid., p. 598; completed according to the dates of the Interparliamentary Union,
Parliaments of the World, vol. 2 (Aldershot: Gower, 1986), p. 912ff.
was more active in using its right to propose bills, but with the increas-
ing burden of parliamentary work and the decreasing success of oppo-
sitional initiatives the opposition concentrated more on amending
bills – this has been true of the Italian communists as well as of the
German social democrats. In Germany the success of opposition initia-
tives in the 1980s was below 1 per cent for the SPD and zero for the
Green Party.67
In a comparative perspective Germany and the Netherlands come
closest to a ‘cross-party model’, in which the social interests in the two
major parties combine their legislative efforts. But even in Britain not
all arenas are organised in a majoritarian way. In some arenas, espe-
cially in the realm of symbolic politics concerning ‘dignified parts’ of
the constitution, there is also a ‘non-party model’ encompassing the

major parties.68 But in spite of certain sectoral similarities in some con-
tinental countries the low success rate of oppositional activities is seen
as a failure of parliament. In the Westminster model, on the other
hand, the same analysis instead leads to positive marks for a parlia-
ment that has efficiently supported government policy.
The success of oppositional work should therefore not be evaluated
by the number of bills proposed by the opposition but rather by suc-
cessful amendments to government bills. Rarely has this indicator been
analysed in a comparative way. In the 1960s, in Sweden less than
3 per cent, in Britain less than 4 per cent and in Italy – with little
government control over a fairly individualistic parliament – more
than 21 per cent of government proposals were amended following
counter-proposals from the committees and the floor.69
Legislative output has been analysed time and again, but is it really
useful as an indicator? Italy is at top of the output list but the great
number of leggini cannot be counted as a success. Olson’s aversion to
interest group penetration could lead to the conclusion that majoritar-
ian systems are less colonised by private interests, produce fewer laws
and are more amenable to regulation. 70 Lijphart has falsified this
assumption in order to champion consociational systems. 71 Other
studies have shown that in majoritarian systems such as that in
Britain, pressure from small groups produces specialised laws such as
the Motor Cycle Crash Helmets (Religious Exemption) Act of 1976 for
the Sikhs.72 In some countries, for example Sweden, the seemingly
high output of laws is the result of the statistical system used, with
amendments and bills being counted together (see Table 4.7). In
Finland the number of laws passed is considerable, but most of them
are without importance.73
Legislative output is determined not only by the penetration of par-
liaments by interest groups, but also by institutional factors such as
judicial review and its anticipatory impact, and cultures of parliamen-
tary voting (restrictive procedures such as the package vote in the
United States and the narrow limits for debates in France). 74 The same
is true of the reform of the voting rules in Finland in 1992, which
removed the possibility of obstructing the reconsideration of a bill.
Here the opposition lost out in terms of voting power.75
The divergence of some countries from the norm is again explained
individually – comparative research, however, rightly prefers gener-
alised statements. One might think that small countries would have
fewer laws, but this is not true of Denmark, Finland and Sweden.
However, it does apply to Belgium, Ireland and Luxembourg. The

explanation lies not in the size of the country but in tight government
control over the parliamentary agenda. 76 Federalist countries have
fewer laws than many centralised systems because some legislation lies
within the competence of the federal units. This is the case in
Australia, Belgium, Canada and Austria, and to a lesser degree in
Germany (Table 4.7).
In all parliamentary systems there is, however, growing pressure for
normative acts. The most important reasons for this are as follows:
• Rising expectations among citizens and growing responsiveness

among parliamentarians.
• An increase of arenas in which the state acts – in spite of calls for
more deregulation.
• Juridification of political issues, which forces the legislators to
amend existing laws.
• New forms of experimental legislation and sunset legislation (laws
that apply for a limited time).
• Globalisation and Europeanisation of norms.
Democratisation by popular legislation

As a consequence of the unrest of the 1970s in many countries legisla-
tion by the people (popular initiatives, referenda) was revitalised. The
more that parliamentary sovereignty was emphasised the stronger the
resistance to plebiscitarian elements representative democracies. The
danger that appeal to the people as a whole would lead to a kind of
populist ‘delegated democracy’ became less threatening with the devel-
opment of the party state. Empirical data show that the divergence of
parliamentary and popular majorities is the exception rather than the
rule.
This can be shown in the case of abrogative referenda, which in Italy
were used to try to abolish parliamentary laws, ranging from a law on
divorce to the law on party finance. Normally the majorities within the
party state have prevented major repeals of existing legislation. In
other systems, when a majority in parliament (Austria) or even minori-
ties (in Denmark, one third of the Folketing, Article 27.1; in Ireland
one third of the Dáil Éireann) have the right of initiative, parliament is
occasionally willing to organise a legislative competitor.
The huge literature on referenda is out of proportion to the impor-
tance of this popular instrument of legislation. 77 The prejudice against
referenda is strengthened by the fact that most referenda are held in
non-parliamentary systems, such as Switzerland and some American

states, as a true ‘bottom-up model’. Most referenda in parliamentary
systems, and especially in semipresidential regimes, are controlled by
the executive (the ‘top-down model’). 78 Popular legislation attracts
much attention, but it presents less competition to parliament than
some of the abovementioned institutions. The Federal Republic of
Germany has been particularly antiplebiscitarian because of the
‘trauma of Weimar’. The erosion of the first German Republic had
many causes, but these certainly did not include the two popular ini-
tiatives (1926, 1929), which did not find a majority. For a long time
Australia and New Zealand were at the top of the referenda league (a
fact largely ignored in comparative European literature), but even in
these countries referenda were used no more than a couple of dozen
times. In Europe, Denmark followed with about a dozen applications.
Since 1974 Italy has become the leading country of popular democracy
with about 40 referenda – mostly linked together on one voting day.
Italy has disproved all the German misgivings about referenda because
the people have shown reasonable maturity. Abuses are hardly possible
because the majority of the electorate have to vote. In 1990 only three
referenda failed to obtain the necessary quorum. 79 The educational
function, which Bagehot vested in parliament but which migrated to
the parties and the media, has found an instrument in the abrogative
referendum, which has had a ‘civilising impact’ on the system. 80 The
terms referendum (from the Latin referre – to carry back) indicates that
an issue is handed back to the people, but this should be the exception
rather than the rule. Referenda have various functions such as allowing
the people to express their dissatisfaction with the government. In
Scandinavia this function developed as an answer to monarchical
bureaucracies, which sometimes continued to be strong even after the
parliamentarisation and democratisation of the regime.81 In Ireland ref-
erenda have sometimes served as safety valve for the religious majority
against the laicist elites and they have developed a moral and religious
mobilising force.
The initiating function of referenda is attuned to innovation (for
example accession to the European Community) or to abrogation (as
in Italy). The French plebiscite tradition manifests itself rather in the
attempt to legitimise presidential decisions from above. Most wide-
spread, however, is the veto function, as once used by the temperance
movement in Scandinavia and more recently by popular movements
against risky decisions concerning nuclear power stations (Austria and
Scandinavia). The oppositional function has normally privileged the
smaller parties, so in some countries (for example Switzerland) the

quorum has had to be raised in order to prevent abuses.
No institution has been spared from the question ‘does it matter?’,
not even the referendum. Referenda have sometimes been called an
instrument of anticonsociational democracy – but history has shown
that the consensus of elites prevents referenda from breaking up the
basic consensus.82 In times of popular resentment against the party
state referenda are hailed as an instrument to break the independence
of a political class. But on the whole this scenario has rarely worked
out and governments have seldom resigned after a negative result in a
referendum, as in Norway. 83 Governments have sometimes survived
defeat in a referendum, as was the case after the referendum on an
atomic power station in Austria (1978) and with the Italian Christian
democrats in 1974 in the referendum on a divorce law. De Gaulle did
resign after a defeat in 1969 – but his party remained in power. The call
for a referendum is mostly an instrument of the opposition. The social
democrats in Sweden often advocated this instrument when in opposi-
tion, but they rarely mentioned it when they came to power. Radical
democrats may hope that referenda will lead to innovation – but more
frequently they have served as a conservative veto or a kind of ‘third
chamber’.84
Only rarely have referenda helped to change the party system, as in
Denmark and Norway.85 Sometimes the electorate has even prevented
long overdue reforms, such as changing the driving side from the left
to the right of the road in Sweden, and in 1969 a majority of Danes
voted against lowering the voting age to 18.86 Seldom has the popular
will been as decisively opposed to the political will as it was in the
Norwegian referendum on accession to the European Union in 1992 –
parliament would have decided differently.
Referenda are not a safe way towards innovative democracy, as com-
parative studies have shown the referendum is a neutral instrument
that can serve very different interests and functions. 87 Referenda may
also serve to alleviate the feeling of powerlessness among masses. The
price is, however, a very simple formulation of the question in terms of
‘yes’ or ‘no’ which does not always do justice to the complexity of
modern decisions.
A policy-oriented approach finally asks whether referenda make
democracy more efficient. Again the results of comparisons are not
uniform. Italy is a high scorer in referenda, but nobody thinks that
Italy functions better than other parliamentary democracies.
Switzerland – a non-parliamentary regime – has undoubtedly had
enormous success in economic and social policy. But are these results
the consequence of referenda? Some analysts suspect that Swiss refer-
enda mostly serve large organised interests. How otherwise would the
protection of grain farmers or domestic mills and the interests of con-
sumers of flour and bread have entered the Swiss constitution (Article
23 bis)? The clearest finding of comparative research is that direct
democracy acts as a barrier against high taxes. 88 This is true in
Switzerland and some American states. On the other hand parliamen-
tary democracy provides regulations that outlaw popular initiatives to
increase public expenditure (Italy, Article 75.2). But via responsiveness
of the parliamentary elites the trend for reducing the tax burden has
had the same result in many postmodern democracies.
There are many good reasons for revitalising the elements of direct
democracy – but they are more in the realm of symbolic polities than
of efficient policy.
4.4 The recruitment function
In the nineteenth century even the holders of such different views as

Mill and Bagehot agreed on the importance of the elective function,
although Mill restricted it to the designation of the prime minister.
Bagehot criticised the common newspaper slogan that ‘Parliament has
done nothing this session’. This overlooks the fact that the elective
function has been successfully used even if parliament does little, and
that the elective function is the most important function in a parlia-
mentary regime.89 Only in systems with some kind of constructive vote
of no-confidence (Germany, Spain and Belgium) and where the prime
minister is elected (Germany) is the elective function directly exercised
by the parliament – with minimal influence by the head of state over
cabinet formation. In the other cases the contribution of parliament to
the creation of a government varies from zero (in Israel since the
popular election of the prime minister) to voting for the investiture of
the government (France). The new Israeli system has been hailed as a
model for other countries, such as Italy, but it has yet to prove its
merits. Under Netanjahu it caused more crises than even a semipresi-
dential system with a president elected by the people – in which the
parliamentary majority can at least topple the president’s government.90
The formal election of the head of government seems to strengthen
parliament. But even in chancellorships, as in the Federal Republic of
Germany, the real elective function is mostly exercised by the voters
on the one hand and – in cases where there is no clear majority – by
the parties on the other. Even the toppling of a chancellor (so far this
has happened only once – in 1982 when there was a constructive
vote of no-confidence against Schmidt) is hardly a mere parliamen-
tary act. Parliament is mainly involved through the negotiations of
the parliamentary groups, which are formalised by a parliamentary
vote.
The indirect strengthening of the elective function by a vote of
investiture (Belgium; France, Article 49.1; Greece, Article 84; Italy,
Article 94; Poland, Article 154.2; Spain, Article 99.5; Czech Republic,
Article 68.3) gives a parliament as much influence as the direct vote,
especially in fairly symmetrical two-chamber systems, such as those in
Belgium and Italy, where the confidence of the upper house is fre-
quently asked for (see Chapter 3 Section 3.2).91 Also the vote of investi-
ture is normally prepared in advance by party negotiations and
therefore rarely fails. Only in Russia under Yeltsin have relations
broken down between parliament and president. In 1998 the presi-
dent’s chosen candidate (Kiriyenko) was turned down twice and was
only installed because of a threat to dissolve the house. A second can-
didate (Chernomyrdin) had to be withdrawn. This unusual procedure
will probably end up in reparliamentarisation of the system.
The constitutional regulations governing the recruitment function of
parliament are sometimes quite detailed. In 1970 Sweden relieved the
crown of the prerogative to search for a candidate and handed it over
to the Parliamentary speaker. This procedure seems as ‘parliamentary’
as the formal vote on a government. In many constitutions the consti-
tution of the parliamentary president and the parliamentary group
chairpersons is prescribed. Greece (Article 37) has been most excessive
in creating a reserve mechanism of legitimacy when cabinet formation
fails, because the State Council, the Areopag and the Court of Accounts
can act when parliamentary negotiations fail (Table 4.8).
In most systems the power to nominate ministers is left to the head
of government. But there are also restrictions in this area.
• Sometimes the number of ministers is constitutionally limited

(Australia, Article 65.7; Belgium, Article 99.15; Ireland, Article 28.7;
Norway, § 12, minimum of nine). In other systems the size of the
ministerial council is left to the standing orders of government
(Italy, Article 95.3). Limitations have no real importance: in many
cases the prime minister creates offices below the ministerial level
and sometimes these have more employees than the smaller minis-
terial departments.
Table 4.8 The role of parliaments in government building
100
Head of state Consultation Election Vote of investiture
Australia x Governor-general
Austria x Article 70
Belgium x Article 65, appoints and
dismisses x
Canada x Article 10 (governor-general)
Czechia x Article 62a x Article 68.3 (within 30 days)
Denmark x § 14 Chairs of parliamentary
groups
Finland x Hearing of parliamentary
groups (§ 36.2) and
president of parliament
France x Article 8 x Presentation of programme
and vote of confidence
(Article 49.1)
Germany x Article 63
Britain x
Greece x Article 37 Legality reserves: council of x Article 84
state, Areopag, Audit Office
Hungary x Chairs of parliamentary
groups (Article 33.1)
Table 4.8 continued
Head of state Consultation Election Vote of investiture
Ireland x Article 13
Israel Popular election of
prime minister
Italy x Article 92.2 Chairs of parties x Article 94 (within 10 days)
Japan x Article 6 Designation of parliament Designated by
parliament
Luxembourg x Article 77
New Zealand x governor-general, Article 6
Netherlands x Article 43 Chairs of chambers, chairs
of parliamentary groups
Norway x § 12 Chairs of parliamentary
groups
Poland x Articles 144.11, 154.1 x Article 154.2
Portugal x Article 136g Chairs of parties
Spain x Chairs of parties x Article 99.4
Sweden Speaker consults with chairs
of parliamentary groups
x means a role exists.

101
• Incompatibility between ministerial office and parliamentary

mandate (France, Article 21; Luxembourg, Article 54; Netherlands,
Article 57.2; Norway, § 62.2).
• In some Westminster models ministers have to be MPs (Ireland,
Article 28.7, at least the prime minister and his or her deputy and
the minister of finance; Australia, Article 64.3, ministers from
outside parliament have to run for a mandate within three months;
Japan, Article 68, the majority of the cabinet must have a seat in
parliament; New Zealand, Article 6.1). In Greece ministers only have
to be eligible for parliament (Articles 81.2 and 55).
• If the head of government is not the designated chairman of his or
her party, personal problems tend to be more important than policy
debates during the negotiations for coalition building. Sometimes
constitutions have tried to regulate deadlocks in coalition building
and lay down the sequence of persons to be entrusted with govern-
ment building (Greece, Article 37; first the leader of the strongest
party, then the leader of the second strongest party and finally the
leader of the third party in terms of parliamentary seats).
• Even strong party leaders frequently have to consider the leaders of
factions in their party and in those of the coalition partners. Free
choice in these cases has little de facto meaning.
Prime ministers are not free actors, as the theory of mandate in one
concept of representation suggests. The process of government build-
ing involves negotiation between party actors. Quantitative studies of
coalition building therefore cite parties as collective actors to explain
the distribution of ministries according to the ideological preference of
various families of parties. 92 In places where there are frequent minor-
ity governments constitutional restrictions are not very useful. 93 In
extremely fragmented multiparty systems – as in Italy – the faction
(corrente) rather than the party is sometimes the most useful unit of
quantitative analysis. The proportional representation of factions in
Italy works only when no faction has a veto against the proposals of
other correnti. 94 In these circumstances coherent cabinets are unlikely
to be formed. Although a cartel of elites can reach short-term agree-
ments, cabinet stability is not likely to develop in such a system.
Parliaments are ideally non-hierarchical organisations (see above).
They do not recruit themselves and their governments by co-optation
as many bureaucracies do. The predicament of parliament is, however,
that it has little influence over the recruitment of its members.
Planning of the nomination process in the constituencies by the parlia-
mentary group in most systems do not work, not even in countries

where central or regional lists of candidates for a second vote exist – as
in Germany. Even in Germany most candidates have to run for the
direct mandate in a constituency. Control over the sequence of party
candidates on the list is in the hands of the Land party establishment,
but even the ‘controllers’ have to respect the proportional rules of sub-
regions, gender and sometimes even religion. In more centralised
systems such as Britain, the parties sometimes establish competing lists
of preferred candidates. In the Labour Party, list A contains candidates
promoted by the trade unions, list B contains the rest of the candi-
dates.95 The central planning of candidate nominations does not
always work, even under strong leaders such as Adenauer and De
Gaulle. Political correctness in choice of candidates is of some impor-
tance in most parties. Recruitment, moreover, is hard to generalise. In
party systems with large ideological differences the various political
families differ enormously, as has been shown in a comparison of com-
munists and Christian democrats in Italy.96
Career mobility in parliament is no easier to generalise than are the
pathways to parliament. According to the psychological approach of
the ‘politics of ambition’ a prospective member has to ask three ques-
tions. Do I want to run? Do they want me to run? Can I run? 97 The
second question – do they want me to run? – has to be asked with
respect to two different institutional bodies: the constituency elites in
the convention of party delegates who make the selection and the
planning elites in the parliamentary group. The first question – do I
want to run? – is hard to answer in a rational way, but it is easier for a
candidate for the American Congress who has a strong position in his
or her constituency than for a candidate in a parliamentary system. An
American senator normally does not envisage becoming a secretary of
state. Ambitious politicians in a parliamentary system, however, are
already thinking of the possibility of entering the executive when they
start their parliamentary career. They know that it will take about two
terms of office for them to be noticed. Very few backbenchers are not
tempted by the idea of ending their career as a cabinet minister, or at
least a parliamentary secretary of state. But ambitious politicians have
to hide their ambitions. Even British shadow ministers with a reason-
ably secure position after the victory of their party in the elections
have a day of uncertainty. As a (fictional) old hand at the parliamentary
game remarked: ‘I’ve been sitting by the telephone ever since breakfast.
No potential Cabinet Minister ever moves more than twenty feet from
the telephone in the twenty-four hours following the appointment of a
new Prime Minister.’98 In continental European processes of govern-

ment building there is less security and the main party leaders can be
fairly certain that they will be appointed to the cabinet. Negotiation
among parties is frequently more important than the personal prefer-
ence of the prime minister.
When candidates enter parliament in a parliamentary system they
know that they will have to serve at least two terms of office before an
executive post can be hoped for. Only small parties with few MPs can
offer a higher post slightly earlier. There is a paradox of career: the
more attractive the cabinet posts the less powerful the parliament and
the longer an ambitious politician has to engage in legislative work in
order to qualify. 99 Constitutions are mostly silent about recruitment.
The old and venerable Norwegian constitution (§ 30.2), dating from
pre-parliamentary times, demands ‘proud men’ to stand in front of the
monarch’s throne: ‘a minister shall utter his opinion frankly’. The
monarch was obliged to listen to this opinion but had the formal right
not to follow the advice of his councillors. Recruitment processes are
not regulated by legal norms but by traditions and styles of govern-
ment. Majoritarian systems (Britain, France and Spain) usually have a
more political concept of the qualifications of a cabinet member than
is the case in consociational systems (the Netherlands and Austria). A
mixed type is found in Belgium, Finland, Denmark, Germany and
Italy, also in Sweden with some deviations.100
The centrality of the cabinet differs according to party system and
the ideology of the party in power. In Britain there is a rule that the
cabinet counts as long as the Conservatives are in power. In Labour
governments the centrality of the cabinet diminished.101 Germany has
shown, however, that the centrality of the cabinet depends less on the
party of the chancellor than on the personal style of the head of gov-
ernment and the strength of his party in the coalition. Under
Adenauer the cabinet was marginal; under Kiesinger and Brandt during
the Grand Coalition (1966–9) it was central. The recruitment of minis-
ters follows rather old traditions, dating from preparliamentary times.
Even aspects of the ancient absolutist rules have been preserved in
states such as Austria and France. In France, even during the Third
Republic, when the system centred around parliament, the bureau-
cratic careers of ‘mandarins’ who had attended a grande école was pre-
served – irrespective of party composition or perpetually reshuffled
governments.102
In constitutional monarchies and early parliamentary systems non-
political specialists were preferred as ministers in times of crises. In the
Weimar Republic non-political specialists amounted to almost one

fourth of all the cabinet personnel.103 Even after the Second World War
the highest proportion of bureaucratic careers – even when the incum-
bents eventually accepted a parliamentary mandate – was found in par-
liamentary monarchies (Netherlands 58 per cent, Sweden 34 per cent,
Luxembourg 36 per cent) and semipresidential systems – the republican
version of a constitutional monarchy (France 39 per cent, Finland
43 per cent, Austria 73 per cent). In countries where executive office
and parliamentary mandate are incompatible the ‘bureaucratic type’ of
recruitment is encouraged – with the exception of Norway. This excep-
tion has been explained by the close links between local mandate and
party office. Germany during the time of the Federal Republic has
come close to the political career concept of the Westminster-type
democracies. Experience has shown that ministers with a political
office tend to stay longer in office and have a better chance of belong-
ing to the inner circle of power (exceptions are the Netherlands and
sometimes Sweden).
The duration of ministers’ stay in office is highly dependent on the
stability of the government, the frequency of alternating governments
and the number of parties that are necessary for coalition building. In
some semipresidential systems the competences of the president
have meant short-lived ministerial careers, as in Finland and France
(Table 4.9, column 3).
Career mobility presupposes not only good work in parliament, but
also being active in leadership bodies in parliament and parliamentary
groups. An Austrian study has shown that ‘political stars’ have three
times as many positions as the normal parliamentarian. 104 In France
another factor is important for a politician’s career: a combination of
mandates at various levels, such as deputy mayor and parliamentarian.
Lord mayors of big cities have sometimes even become prime ministers
(Chaban-Delmas and Juppé in Bordeaux, Mauroy in Lille). 105 In the
Fifth French Republic the proportion of deputies who simultaneously
held a local mandate rose form 63 per cent (1958) to 80 per cent
(1967).106
In well-organised party states the post of parliamentary secretary of
state has sometimes served as a preparation for ministerial office
(Germany, Italy: sottosecretari).107 In a parliamentary system it is hardly
feasible for a completely new figure to enter national politics by a small
margin as happened with Carter in the United States. After his election
a newspaper asked ‘Jimmy who?’ Governors in the United States are
less well known nationwide – with a few exceptions – than German
106
Table 4.9 Ministers’ career pattern in parliamentary democracies
Political
socialisation Share of Rotation
in long-term Age at Average (1945–84)
parliaments Only minister entering time in Share Professional background 3 and
and party bureaucratic (over 7 (Over office office of Public more
organisations career years) 10 years) (1945–84) 1945–84) women Jurist Teacher servant positions
(%) (%) (%) (%) (years) (years) (%) (%) (%) (%) (%)
Austria 75 73 33 18.7 50.6 6.0 5.2 8.3 6.6 16.7 2.4

Belgium 92 14 16 8.4 49.9 3.8 1.4 25.6 25.1 6.2 18.8
Britain 95 7 21 8.5 53.6 4.8 4.2 17.0 11.3 9.4 25.8
Denmark 85 13 16 5.1 50.3 4.4 11.2 5.9 16.4 15.0 11.2
Finland 78 43 10 2.1 48.9 3.0 8.8 – – – 7.6
France 80 39 11 4.8 50.0 3.6 .43 9.6 15.0 35.3 18.8
Germany 95 10 31 13.2 51.7 5.6 6.6 25.8 6.6 5.8 12.5
Ireland 95 14 33 16.8 46.2 6.6 2.9 19.6 18.6 4.2 32.6
Italy 96 12 16 7.3 54.3 3.8 0.9 30.0 29.2 3.5 33.2
Luxembourg 67 36 39 26.9 51.0 6.8 3.8 28.6 9.5 16.7 8.0
Netherlands 64 58 12 4.6 49.1 4.0 3.9 10.8 23.0 25.0 2.9
Norway 93 16 16 6.0 48.4 3.9 15.0 4.5 11.6 15.6 6.2
Sweden 74 34 25 16.8 49.0 5.9 18.3 6.5 20.4 25.0 10.9
Average 50.4 4.5 16.1 17.3 14.7 15.9
Source: Jean Blondel and Jean-Louis Thiébault (eds), The Profession of Government Minister in Western Europe (London: Macmillan, 1991), pp. 181ff,
122, 71, 75, 25, 27.
prime ministers of the Länder. In European parliamentary systems most

ministers go through a long local and national parliamentary and
party career. The figures range from 64 per cent (Netherlands) to 96 per
cent (Italy).108
Political socialisation is a long process in all governmental systems,
apart from some revolutionary regimes. In parliamentary systems the
top executives tend to enter rather late in life (on average, Britain at
53.6 years and in Italy 54.3 years). The average age at first ministerial
appointment is about 50 years. Ministers normally leave at the age of
56. The share of women is much lower than at the parliamentary level
(6.2 per cent). In this respect Scandinavia has the best performance,
the worst performance being in Belgium, Italy and Britain. The latter
case has been explained by the electoral system of plurality votes,
which creates disadvantages for women. The distribution of vocation is
even less balanced than in parliament. Jurists and civil servants are
traditionally overrepresented in cabinets. After 1945 civil servants
held about 15 per cent of cabinet portfolios. France was on top with
35.3 per cent, followed by the Netherlands and Sweden with about
25 per cent. About 16.1 per cent of cabinet ministers were lawyers, but
in Italy, France, Germany and Luxembourg, the number of lawyers
exceeded 25 per cent. Teachers – a new form of civil servant in many
countries – were also overrepresented: 17.3 per cent on average in
Europe as a whole, almost 30 per cent in Italy and about 25 per cent in
Belgium and the Netherlands (Table 4.9). A high share of bureaucrats
tends to diminish mobility (as in Austria and Sweden). In the
Westminster model ministers have a more political perception of their
office109 than is the case in most parliamentary systems on the conti-
nent. This leads to more horizontal ministerial mobility (see Table 4.7)
and more frequent shifts from office to office. Progress in a ministerial
career can be like rolling Sisyphus’s stone, but the post of cabinet min-
ister is only a transitory job in most democratised countries. The
average stay in cabinet is short and by the end of their fifties ministers
have usually returned to the backbenches. Many withdraw from poli-
tics and take a job outside parliament. Camus warned us, however, not
to overrate the unhappiness of Sisyphus.
The recruitment function fits least well into the gloomy picture of a
decline of parliament. Recruitment in democratic parliamentary systems
functions with less tension than in early parliamentary systems and
constitutional monarchies. But parliament can only take some of the
credit: without the parties behind parliament this function would also –
even more so than legislation – be fulfilled in a less satisfactory way.
5
The Role of the Head of State in
Relation to Parliament and
Government
The popular theory of the English Constitution involves two

errors as to the sovereign. First, in its oldest form at least, it con-
siders him as an ‘Estate of the Realm’, a separate co-ordinate
authority with the House of Lords and the House of Commons.
This and much else the sovereign once was, but this he is no
longer. That authority could only be exercised by a monarch
with a legislative veto. He should be able to reject bills. But the
Queen has no such veto. She must sign her own death-warrant
if the two Houses unanimously sent it up to her.
Walter Bagehot
Walter Bagehot’s drastic statement that the queen ‘must sign her own
death-warrant if the two Houses unanimously send it up to her’ 1
showed the consequences of parliamentarisation for the head of state:
• Legislative power was lost and the doctrine ‘king in parliament’ fell
into oblivion.
• The veto against a sovereign parliament was no longer feasible.
Bagehot’s harsh formulations were necessary because even during his

time the old doctrines in the tradition of Blackstone’s Commentaries on
the Laws of England (1765)2 were stubbornly adhered to by traditional-
ists. The mystique of a monarch in parliament was preserved even in
the constitutions of former British dominions (Canada, Article 17):
‘There shall be One Parliament of Canada, consisting of the Queen, an
Upper House styled the Senate, and the House of Commons’. Even in
108
The Role of the Head of State 109
fairly recent versions of the Australian constitution a similar formula-

tion can be found (Article 1).
The head of state in this chapter is analysed only with regard to his
or her role of balancing the executive and legislative. But this does not
mean that monarchs and presidents have acted as a ‘neutral power’
(pouvoir neutre) – which Constant ascribed to their functions – not even
after the parliamentarisation of the system.
The role of the head of state differs according to the type of regime:
• In presidential systems – dealt with in this study only as a contrast-

ing model to parliamentary systems – the head of state is an active
republican replica of the constitutional monarch, with a wide range
of competences. The concept of congressional government 3 was
originally closer to the system of the founding fathers than the
presidential government that developed later – with remnants of
‘congressionalism’.
• In semipresidential systems the president, elected by the people, is
likewise conceived of as an active power. This system is even closer
to the concept of a dualistic constitutional monarch, and under
republican conditions it reproduced the latent rivalry between the
head of state and the head of government as soon as the latter
secured a parliamentary majority.
• In parliamentary monarchies the prerogatives of the head of state
have been minimised, even where old constitutions continue to
be valid and permit a veto, an independent right to choose minis-
ters and dissolve parliament. The part played by the monarch as
head of state has been downgraded or restricted to the ‘dignified
parts’ of the constitution, but his or her role continues to have
weight because of continuity of office and the power of hidden
persuasion.
• The weakest role exists in purely parliamentary systems, where pres-
idents are elected by parliament or another elective body.
The relationship between the executive and the legislature is affected

by the functions of the head of state in several respects:
• By the role of the head of state in legislation (Table 5.2).

• By the role of the head of state in the formation and dismissal of
governments (Table 5.3).
• By the role of the head of state in the dissolution of parliament
(Table 5.4).
5.1 The creation of a head of state
The power of the head of state has eroded since the nineteenth
century. The role of parliamentary presidents and monarchs in the
twentieth century has interested lawyers more than political scientists,
and others have mainly concentrated on presidents elected by the
people.4 Tocqueville, as a member of the constitutional committee in
1848, was the first to point out the dilemma of creating a republican
president in a society that still felt itself to be monarchistic. 5 The cre-
ation of a head of state in consolidated systems is bound to strict rules.
Even in monarchies there are age restrictions and sometimes parlia-
mentary consent is required for the marriage of the heir to the throne
(Netherlands, Article 28.1; Norway, Article 36.1). Before the marriage of
Princess Beatrix of the Netherlands to the German Claus von Amsberg
painful investigations were made into the activities of the latter’s
family during the Nazi period.
Presidents elected by popular vote are normally subject to reelection
restrictions. Usually they are allowed only two periods of office,
whereas in purely parliamentary systems this question is often left
open because the danger of abuse of power does not seem to lurk in
systems where the head of state’s competences are weak. There are also
restrictions on age (35 or 40 years) and length of residence in the
country, and sometimes higher qualifications are required, comparable
to those of candidates for the upper house (Czech Republic, Article
57.1). Unique is the Israeli solution to appoint a president, elected
by the parliament, facing a popularly elected prime minister. Severe
conflicts between the prime minister and the president in the adminis-
tration of Netanjahu were thus inevitable. In 1998 President Weizman
criticised the prime minister for blocking the Middle East peace process
and asked for a dissolution of parliament, which Netanjahu refused.
In monarchical systems the formula ‘the king can do no wrong’,
dating from early constitutional times, has been preserved under par-
liamentary conditions. The price, however, is that the monarch has
become fainéant, with no right to shape policies and forced to obtain
the consent of the prime minister for public political speeches.
Semipresidential systems still need the impeachment because parlia-
ment has no other instrument of control, but even many purely parlia-
mentary systems, in which the president is restricted to ceremonial
functions, have provided for impeachment. This makes sense because
the impeachment of governments has fallen into disuse because there
is a parliamentary instrument to oust them – the vote of no-
confidence, which does not exist in the case of elected presidents

(Germany, Article 61; Austria, Article 142; Bulgaria, Article 102.6;
Czech Republic, Article 87g; France, Article 68, but only for high
treason; Russia, Articles 93, 125.6). Poland even has a special court for
the impeachment of a president instead of handing over this task to
the constitutional court. Austria has codified a double safety device:
impeachment by the Federal assembly (Article 142) and dismissal of
the president by popular vote. President Waldheim, following accusa-
tions about his Nazi past, might have been a good case to test the
wisdom of such a solution but Austria was wise to reject it – what
would have happened to the country’s international reputation if the
majority of the people had voted for Waldheim?
Between the two world wars there was a tendency to declare the
president – sometimes even the monarch – a ‘neutral power’ in the
system. After 1945 a more neutral collective body took over this func-
tion: the constitutional courts. Parliamentary democracy does not nor-
mally need this instrument to enforce ‘presidential restraint’. Even in
the presidential system of the United States there has been only one
impeachment. Nixon’s voluntary resignation showed that the
impeachment approached parliamentary customs, favouring political
decision rather than a system of formal trial.
5.2 Cohabitation of presidential and parliamentary

majorities in semipresidential systems
Presidents in semipresidential systems are normally longer in office

than their counterparts in purely parliamentary systems (the excep-
tions being Italy with seven years and Finland with six years). Since
the legislatures normally run for four years (sometimes five years,
Table 5.1), presidential and parliamentary elections rarely coincide.
Different electoral cycles for presidents and parliaments can thus rein-
force structurally in built conflicts of a hybrid system. The longer the
term of a president the more likely it is that the American ‘mid-term
election effect’ will happen, whereby US presidents are regularly
confronted with a hostile majority in the House of Representatives. In
France it happened for the first time in 1986, when Mitterrand was
confronted with a hostile majority under Chirac in parliament. The
ambiguous term ‘cohabitation’ was discussed with a degree of zeal that
was barely understandable in regular parliamentary regimes. President
and prime minister began to compete for prerogatives in foreign policy
and flew in separate planes to a conference in Moscow.
Table 5.1 Election of the head of state
112
Hereditary Elected Term of

monarchy by the people Elected by parliament office (years) Re-election Ability to relieve of office/impeach
Australia Represented by
governor-general
(Article 2)
Austria Article 60 6 Once Article 60.6, relievable by referendum.
Article 142, impeachment by Bundes-
versammlung
Belgium Yes
Britain Yes
Bulgaria Article 93 5 Once Article 102.6, impeachment, one
quarter of deputies before
constitutional court
Canada Governor-general
(Article 10)
Czech Republic Article 54, both chambers 5 Twice
Denmark Yes
Finland § 23–23e. In the 6 Once § 59, against minister by ombudsman
past: 300 electors of justice
France Article 6 7 Article 68, only in case of high
treason
Germany Article 54, Bundesver- 5 Once Article 61, impeachment before
sammlung constitutional court, one quarter of
Bundestag or government
Greece Articles 30, 32, recorded 5 Article 49, impeachment by one third
vote of parliament
Hungary § 29 1 4 Once Article 31A, two thirds of deputies
Ireland Article 12.2 7 Once
Table 5.1 Continued
Hereditary Elected Term of

monarchy by the people Elected by parliament office (years) Re-election Ability to relieve of office/impeach
Israel Prime minister, Presidents, Article 37 5 Article 45, president by parliament.

Article 115 Article 122, prime minister with three
fifths of parliament
Italy Article 83, both chambers 7 Article 90, impeachment by
and regions parliament
Japan Yes
Luxembourg Yes Article 82, only impeachment of
government
New Zealand Represented by
Governor-general
(Article 22)
Netherlands Yes
Norway Yes
Poland Article 127 5 Once Article 145, state tribunal on motion
of two thirds by parliament
Portugal Articles 124, 126, 5 Once
Article 131
Romania Articles 81, 83 4 Once Article 84.3, parliament. Article 95,
consultation of chambers in common
assembly with two thirds in favour of
impeachment by constitutional court
Russia Article 81 4 Once Article 93 impeachment by Duma
before federation council
Spain Yes Article 102, impeachment of
government
113
Sweden Yes
When a constitution lists all prerogatives as extensively as they are in

Portugal, conflicts are bound to arise. The president, in his capacity as
president of the Revolutionary Council, had competences in defence
policy but the non-military aspects of security in foreign policy have
stayed with the prime minister. 6 Under President Eanes (1976–86), a
president without party affiliation, conflict was limited. But the social-
ist President Soares (1986–96), who had led a government four times,
was less ready to accept a more passive role. Conflicts with PSD govern-
ments under Cavaco Silva (from 1985) would have been more frequent
if a constitutional reform of 1982 had not reduced the competences of
the president, especially his right to dismiss the government. The
Portugese system developed around the prime minister. 7 A similar
development is to be expected in Poland and some other East
European systems.
Conflicts of cohabitation only arise in semipresidential systems that
have two clearly distinguishable political camps, as in France and
Russia, and also in Poland under Walesa:
• Most semipresidential systems are multiparty systems and the

president has only limited room for manoeuvre in a party politi-
cal sense. However, in Finland President Kekkonen (1956–82),
who had himself been prime minister four times (1950–53), was
able to develop unusual prestige in foreign policy and also to
interfere in domestic affairs (for example income policy in 1970).8
Since the conservatives severely criticised his policies the presi-
dent strove to keep them out of power and promoted his own
centre party (the KESK) in government building. A problem of
cohabitation could have developed if the conservatives had had a
majority in parliament. But even under President Aho (also from
the KESK) in the 1990s the conservatives were rarely in power and
always in coalition with several other parties, so they were hardly
in a position to lead the government into fully fledged conserva-
tive policies.
• In spite of being popularly elected, presidents have few competences,
as in Ireland, and rarely attract active party politicians, as in Austria,
Iceland, so conflicts with the parliamentary majority are unlikely.
Even under Waldheim there were no open conflicts with govern-
ment in Austria.
• In consociational systems with frequent grand coalitions, as in
Austria (1945–66), socialist presidents have frequently been con-
fronted with a Christian democratic chancellor.
Possible conflicts have been smoothed by negotiations beyond parlia-

mentary bodies of corporatist organization making cohabitation
conflicts unlikely.
• If an electoral college exists (in Finland until 1988 the constitution,

§ 23.2, allowed for 300 electors) the party element is strengthened
and the danger of cohabitational conflict is weakened.9 Negotiations
for coalition building can also be necessitated by a presidential elec-
tion with two rounds, especially when the runner-up in the first
round overtakes his or her competitor in the second round (in
Portugal in 1986 Soares won over Diego Freitas do Amaral).
• Conflicts of cohabitation are smoothed when the president has vir-
tually no power to dissolve parliament. If a president has a landslide
election victory there may follow a honeymoon period for his or her
party that continues into the next parliamentary elections, but the
effect of this diminishes the longer the president stays in power. If a
president has the ability to dissolve parliament he or she may try to
capitalize on the honeymoon period by calling an election, as
Mitterrand did in France in 1981 and 1988. 10 But all such tricks and
the manipulation of the electoral law did not prevent France from
becoming the classic example of a country with cohabitational
conflicts.
The party system is the most important variable in relations between the
president and the parliamentary majority. The party system in the nine-
teenth century frequently undermined the power of the monarchs, and
the political activities of popularly elected presidents in the twentieth
century have been likewise circumscribed. Semipresidential systems since
De Gaulle have tried to foster the image of a ‘president above the
parties’.11 Nevertheless even De Gaulle was indirectly the chairman of his
party and expected it to obey his directives. De Gaulle’s successor was
not nominated as a candidate by the party, rather it adopted the self-
nominated Pompidou. From 1971 Mitterrand was first secretary of the
Socialist Party but he kept a certain distance from the party after coming
to power. Likewise Chirac resigned from the presidency of the RPR. Only
Giscard d’Estaing, the first non-Gaullist to hold the highest office, felt
the weaknesses in the first years when he was considered as only a junior
partner of the Gaullists. From 1978–81 his party was as strong as the
Gaullist Party but the latter still had the power to veto certain presiden-
tial initiatives. 12 De Gaulle had refused to grant the name Gaullist to his
party and concentrated his contacts on Prime Minister Pompidou. Under
Mitterrand these contacts were almost institutionalised as ‘working

dinners’.13 All these presidents were not ‘above the parties’, given their
active role in promoting candidates, factions (courants) and electoral
alliances that were close to their views.
In Eastern Europe the party system during the phase of consolidation
was weaker than in France. Cohabitational conflicts were initially the
rule, and not the exception as in France. They also happened in purely
parliamentary systems, as in the Czech Republic (Klaus versus Havel),
Slovakia (Mecîar versus Kovácŝ), Hungary (Antall versus Göncz). There
was strong conflict between Pawlak and Walesa in Poland, and
between Petre Roman and Iliescu in Romania. In Russia until the
autumn of 1998 President Yeltsin had been able to avoid a hostile
prime minister, then he was forced to accept for the first time his
second choice, Primakov, and this may be the nucleus of future cohab-
itational conflicts since the prime minister is likely to consider the
wishes of the Duma majority, composed of postcommunists and
nationalists. In Poland and other semipresidential systems the presi-
dent has been strong enough to oust an unpopular government but
not sufficiently strong to put his first choice into office, 14 a situation
that Yeltsin has had to face since August 1998.
In all the cases, party systems and institutional variables have shaped
the conflicts between the president and the parliamentary majority.
Semipresidentialism has been frequently espoused as an instrument to
minimise such conflicts. Shrewd politicians such as Mecîar in Slovakia
have fared better with a purely parliamentary system. This is one of the
reasons why Slovakia switched rather late to a semipresidential system.
Most east European systems have introduced another ‘neutral
power’, the constitutional court, which plays an important role in
smoothing conflicts between the institutions. Some cohabitational
conflicts have been caused by a restructuring of the party system,
either because of the erosion of a democratic alliance of the ‘forum’
type (Poland, the Czech Republic, Hungary and Slovakia) or because of
a reduction in the strength of postcommunists, who initially had a
dominant position (Romania and Bulgaria). Cohabitational conflicts
have also been exacerbated by institutional consolidation: presidents
have developed a counterbureaucracy in the presidential office to chal-
lenge the autonomy of the government. Security councils – copied
from the United States – have made inroads into the government’s pre-
rogatives in foreign policy.
With the consolidation of democracy cohabitational conflicts tend
to wither away and normal government business resumes. This can
only happen, however, if the market economy is functioning properly.

This is not yet the case in most countries in the CIS and former
Yugoslavia, where a strange mixture of anarchy and autocracy has con-
densed to form ‘anocracy’,15 which makes their semipresidential insti-
tutions incomparable.
5.3 Functions of the head of state in legislation
Rousseau’s confidence in the popular will was not strong enough for
him to believe that the people themselves, ‘a blind mass’, could handle
such a difficulty task as legislation. He therefore invented a grand légis-
lateur, along the lines of Moses or Solon. 16 More liberal thinkers pre-
ferred a collective body, such as Filangieri’s (1798) magistratura, as a
censor of laws. The liberal Robert von Mohl correctly asserted that a
special bureaucracy was alien to the parliamentary system. 17
Conforming to the system was only a kind of ‘commission of legisla-
tion’, which Mill saw as a possible way of improving legislation. 18
Technocratic ideas of a supervisor reentered the debate when the eval-
uation of legislation was systematised. Luhmann proposed an ‘office
for legislation’ as a centre for information on the functioning and dys-
functioning of existing laws.19
In political theory, scepticism about the capacity of legislative
assemblies to produce rational legislation contributed to proposals for
another grand législateur, the president, Carl Schmitt and others
espoused this during the time of the Weimar Republic. In monarchies
the legislative functions of the head of state were eroded, even if they
continued to be listed in some constitutions (Belgium, Denmark and
Luxembourg) (Table 5.2, column 2). The residual legislative function
of the head of the state can be tested with four indicators (Table 5.2):
legislative initiative, the power to issue decrees, the power to veto par-
liamentary bills and functions in initiating popular referenda. Except
in some semipresidential systems all these legislative rights of the
head of state require countersignature of the head of the parliamen-
tary government (Table 5.2, column 1). Some exceptions exist with
regard to the right to initiate a referendum (France, Article 19;
Hungary, Article 30.2).
The right to issue decrees (Table 5.2, column 3) is usually limited to
some policy areas and requires the authorisation of parliament or the
parliamentary government (France, Article 19; Greece, Article 43;
Sweden, Chapter 8, § 7; Israel, Articles 93, 96). Semipresidential
systems in the Weimar Republic and in Finland before the Second
Table 5.2 The head of state and legislation 118
Right to veto
Duty to countersign Legislative initiative Right to decree parliamentary laws Referendum
Australia Yes Government and Parliament delegates to Obsolete

parliament government, can annul
again
Austria Article 67.2, all acts Article 41.1, both Government No Article 44, constitutional
chambers and laws obligatory; Article
government and 43, majority of National
100 000 citizens; Article Council
51, budgetary laws in
National Council
Belgium Articles 64, 106 Articles 36, 74, king in De facto government No No
Parliament in the name of the king
Britain Yes Government and Government in the Obsolete No
parliament name of the monarch
Bulgaria Article 102.2 Article 87, parliament Article 102.2, 108, with Article 101, referring § 4.1, parliament; §
and government, countersignature of back, overruled with 102.6 president
government budget prime minister absolute majority appointed
Canada Yes Government and Parliamentary delegates, Obsolete No
parliament extensive competences
Czech Republic Article 63.3 Article 41, government, Article 78, government, Articles 50, 62 h, No
not president, as well as overruled with majority
self-government units
Denmark §4 § 21, Monarch can have Government , No § 41.1, one third of
laws ‘submitted’ authorised, § 23, parliament can propose
monarch in urgent a referendum to the
cases chairman
Finland § 20.2, § 34 § 18, president, bill of Parliamentary delegates § 19.3, referring back, § 22a, consultative by
government for a limited period, overruled by parliament law
§ 21, § 28, president
Table 5.2 continued
Right to veto
France Article 19 exception, Article 39, prime Article 19, president Article 10.2, referring Article 11, president on
e.g. referendum minister, parliament with countersignature back government’s
of prime minister suggestion
Germany Article 58, chancellor Article 76, government, Article 80, government No No
or responsible parliament, Bundesrat
minister
parliament name of the monarch
Greece Article 50, only No President on suggestion Articles 42, 45, referring No
specially conferred of government, Article back without counter-
competences; Article 43 signature; Article 76.2,
35, appointment of overruled with absolute
prime minister, majority
dissolution
Hungary Article 30.2, exception: Article 25.1, president, Articles 35.3, 37.3, Articles 26.2 and 3, Articles 30A1g, 30A2,
referendum government, committees government objections to parliament president can suggest
overruled with majority, without counter-
in case of breaches of the signature
constitution to
constitutional court
Ireland Yes No Parliament Article 26.1, reference Article 27, majority of
with consent of state senate and one third of
council in High Court lower house can request
referendum from
president with petition
Israel Articles 41a, d, without No Articles 13, 16, No No
exception government authorised
to submit to parliament
119
Table 5.2 continued
120
Right to veto
Italy Article 89 Article 71, government, Article 77, government Article 74, president can, Article 78, parliament
parliament and other with demand new sessions
institutions authorisation of
parliament; Article 87,
president
Japan Article 7, enumerative No Government No No
for emperor
Luxembourg No Article 47, grand duke Article 36, grand duke No No
informs chamber of without repealing
bills; Article 83ff, state laws
council takes a stand
New Zealand Article 18.2, No Delegated to No No
governor-general; government
Article 13
Netherlands Article 48 Article 127, only two Articles 47, 89, Article 130, monarch can No
chambers; Article 82.1, government in the demand new
government in the name of the monarch investigation
name of the monarch
Norway § 31 No § 3, § 7, government in § 78.2 not used, law No
the name of the cannot be submitted
monarch again, new Odelsting
can overrule veto
Poland Article 144.3 Article 144.3, 4, with President in Articles 144.3, 5, with Article 145.2, parliament;
counter signature connection with counter signature Article 118.2, 100 000
government, Articles citizens; Article 144.3, 5,
142, 149.2, 146.2 president with counter-
signature
Table 5.2 continued
Right to veto
Portugal Article 140 reversed, No Article 139.4, Article 139.1, right to Article 170, initiative
counter-signature of government veto overruled with government, parliament
president required absolute majority and parliamentary
groups
Romania Article 99, with Article 79, legislative Article 99, president Article 77.2, president Article 73, initiative
exceptions council; Article 73, with countersignature can demand one government, deputies
government, and government investigation and 250 000 citizens;
parliament, citizens Article 90, president
after consulting
parliament
Russia No Article 84c, president, Articles 90.1, 115, Article 107.3 overruled Article 84c, president
Article 104.1, 104.3 presidential decrees with two thirds appointed, regulated by
budget laws: take priority majority of the Duma constitutional court
government, initiative
also constitutional court
and other courts
Spain Article 64, designation Article 87, government Government demands Article 62.1, approval of Article 62c, regulated by
of prime minister and and parliament (both decrees, norms with laws monarch; Article 87.3
dissolution of chambers) and rank of law, Articles 82, referendum; Article 92,
parliament, autonomous units 83 consultation, refe-
countersigned by rendum suspended by
president of monarch, authorisation
parliament by congress
Sweden No No Ch. 8, § 7, government No Ch. 8, § 4, after law,
enumeratively limited consultative
121
World War sometimes experienced increasing colegislation by presi-

dential decree. Russia, with Yeltsin’s ukazokratiya, has renewed this
ominous tradition.
Walter Bagehot’s blunt statement about the veto, quoted at the start
of this chapter, is an exaggeration for most parliamentary systems. The
head of state has some formal and informal powers of persuasion to
block a bill that is not acceptable to him or her. In some purely parlia-
mentary systems it is possible for the head of state to demand a second
deliberation by parliament. The ‘suspensive veto’ requires different
majorities: simple majorities in Spain and Hungary, an absolute major-
ity in Portugal and a two-thirds majority in Russia. In Russia and
Hungary (Articles 26.2 and 3) the president may take a bill to the con-
stitutional court if his or her veto is overridden. Unlike in the presiden-
tial system there is no ‘item veto’ challenged by the Supreme Court
even in the United States and no ‘pocket veto’ (killing a bill by not
signing it until the end of the legislative period). The Norwegian clause
(§ 78.2) that only a new Odelsting can override the monarch’s veto
comes close to a pocket veto.
The veto has fallen into oblivion in most parliamentary systems,
with the exception of some semipresidential regimes. In Finland the
veto has been used by all presidents but Ryti and Mannerheim. In
1965, 53 bills were vetoed. 20 The weakest president in all the legislative
respects is the president of the Federal Republic of Germany. But even
he has a certain right to delay a bill if there are doubts about its consti-
tutionality. The traditional veto was an instrument of some fictitious
pouvoir neutre. In most parliamentary systems the head of state pre-
serves only auxiliary functions and the real neutral power is the consti-
tutional court, or other courts where the former does not exist
(Scandinavia and Britain).
5.4 Functions in government building
The more that monarchs withdrew from the everyday business of

government and handed it over to their councillors, the more carefully
they had to select a government. Only in defence and foreign policy
were certain prerogatives preserved. These are reflected even in modern
parliamentary democracies in certain competences for emergency
powers and command over the military force of the country (Table 5.3).
In older monarchical constitutions (Belgium, Article 96; Denmark,
§ 14; Luxembourg, Article 76; Netherlands, Article 43) the former
prerogative of the monarch to nominate the government is preserved
Table 5.3 The head of state and government building
Appointment of head Dismissal of head Prerogatives in Direction of council Emergency laws Supreme command
of government of government foreign-policy of ministers of armed forces
Australia Article 65.7, minister No No No Governor general Article 68,

parliament can change governor general
this
Austria Article 70.1, by Article 70, de jure Article 65, minimal Article 69, No procedure Article 80,
president president without competences (e.g. chancellor president
countersignature, legitimisation of
single ministers on illegitimate
suggestion of children)
chancellor
Belgium Article 96, monarch de Article 96, de jure No Prime minister Small procedure, No
jure; Article 99, constitution cannot
maximum 15 ministers, be suspended
proportion of Flemish
Walloons
Britain No No No No Prime minister
Bulgaria Article 99, consultation Article 83.6, people’s No Article 108.2, Article 83.12, Article 100,
of parliamentary groups, assembly elects and prime minister parliament at president
strongest, second dismisses prime suggestion of
strongest party minister president
Canada Article 9, executive No No No Government under Article 16,
for monarch parliamentary monarch
responsibility
Czech Article 62.1 No No No Article 77.1, prime No
Republic minister
Denmark § 14 monarch decides § 14 monarch § 19, bound to § 18, prime Government, measures No
on number of ministers approval of minister; § 17, submitted to
parliament monarch leads parliament
state council
123
Table 5.3 continued 124
of government of government foreign policy of ministers of armed forces
Finland § 36, president, hearing § 36b, president in § 33, president; § 41, § 39, prime President in state of § 30, president
of parliamentary groups; case of no-confidence state council minister, president; war: government
§ 38, number of performs resolutions only in cases has legislative powers
ministers is open of president concerning him
France Article 8 Article 8, if prime No Article 9, President if Article 15,
minister offers president constitutional order president
resignation disrupted, parliament
affirmation after
12 days
Germany Article 63, election by No No Article 65, Emergency Article 115b, in
parliament on chancellor has parliament state of defence,
suggestion of president policy-making chancellor
powers
Greece Articles 82.1, 35, law No No Article 82.1, Articles 44, 48, Article 45,
without counter- government leads president with president
signature (but general politics; countersignature of
conditions, Article 37) Article 82.2, prime government,
minister restores parliament has to
unity approve by two-thirds
majority
Hungary Article 33.3, hearing of Article 33.4, at Article 35.1, council Article 37.1, prime Articles 19b, 35.1i, Article 29.2,
parliamentary groups suggestion of prime of ministers takes minister state of emergency; president
minister part Article 19c, president
if parliament
prevented
Ireland Article 13.1, on Article 13.3, at Prime minister Article 2.5.1, prime Article 28, govern-, No
suggestion of suggestion of prime informs president minister ment parliament
parliament; Article 28, minister on foreign and approval in case of
7–15 ministers domestic policy declaration of war
Table 5.3 continued
of government of government foreignpolicy of ministers of armed forces
Israel Popular election Article 130b, prime No Article 41a4, prime Parliament No
minister can dismiss minister;
ministers except vice president receives
prime minister report
Italy Article 92, president; No No Article 95, prime President after No
Article 94.2, vote of minister parliamentary debate
investiture of
parliament
Japan Article 66, prime No No No Parliament, no No
minister by procedure
parliamentary
resolution; (designated)
Article 6, emperor
appoints
Luxembourg Article 76, grand duke Article 77, dismisses Article 137, de jure Article 33, Article 44.3, Article 37,
regulates organisation, government grand duke, de grand duke alone parliament approval grand duke
minimum ministers; facto prime has executive in case of declaration
Article 77, grand duke minister power of war
appoints government
New Zealand Governor general No No No procedure No
Netherlands Article 42, government Article 43, de jure by No Article 45.2, prime parliamentary No
consists of monarch monarch minister decision, de jure
and ministers; Article monarch and in event
43 de jure monarch of declaration of war
Norway § 12.1, prime minister § 22.1, monarch can No § 12, 13, Parliament § 25.1, de jure
(state minister) and dismiss ministers,. Monarch de facto state monarch,
seven ministers not civil servants by minister responsibility of
younger than 30 judgement parliament
125
of government of government foreign policy of ministers of armed forces
Poland Article 144.11 Article 144.14, in case Article 133.1, Articles 144.15, Article 230, president Article 134.2, in
of no confidence president represents; 141, president at request of state of peace
Article 146, government defence minister;
government leads Article 135,
foreign policy in a state of war
president and
government
appoint supreme
commander of
armed forces
Portugal Articles 136h, 190, after Cut down by Article 133.3, Article 204a, President is authorised Article 137a,
hearing of parliamentary constitutional president is supposed prime minister by parliament president
groups and consideration reform in 1982 to cooperate with
of election result prime minister
Romania Article 85, decides on Article 108.1, Article 87.2, Article 87.2, Article 93, president Article 92.1,
candidate, appoints in government president signs president in when state of seige president
light of vote of responsible only treaties, government sessions in which exists
confidence in parliament to parliament negotiates them he takes part
Russia Article 83, with the Articles 83c, 117, Articles 80.86.1, also No Article 87.1, war Article 87.1,
approval of the Duma dismissal after two in domestic policy powers of president president
votes of no confidence
in three months,
obligatory
Spain Article 62d, suggests Article 62d, dismissal No Article 98.2, prime Government for Article 62h,
candidates of ministers at minister 15 days, monarch
suggestion of prime parliamentary
minister approval
Sweden Ch. 6, § 2, president Ch. 6, § 5, president No Ch. 5, § 1, only if Ch. 13, § 1 ff, No
of parliament, not of parliament necessary speaker and
monarch, consultations dismisses emergency
with chairs of parliament
parliamentary groups
in the text. This does not mean that the head of state has more
influence over government building than a republican president – in
semipresidential systems presidents have wider prerogatives than the
monarchs in purely parliamentary regimes. The head of state has dif-
ferent possibilities to influence the process of government building at
various stages of the process:
• At the moment the government resigns.

• During the consultations between the party leaders.
• During the designation of the prime minister.
In recent constitutions the process has been streamlined by certain

limitations, such as the prescription that the results of elections have
to be considered (Portugal, Articles 136 h, 190), or even that the
president has to call on the leaders of the parties for the purposes of
government building (Greece, Article 37.2; Bulgaria, Article 9.9). The
Fundamental Law of the Federal Republic of Germany excludes
the president from the first two parliamentary votes and only after the
third round can he choose between a minority government or the
dissolution of parliament. In the Swedish constitutional reform
the function of government building was completely removed from
the monarch and handed over to the speaker of the parliament.
During the negotiations between the party leaders the head of state
can serve as a mediator even if he or she is not counted among the
players. In systems with a vote of investiture (Belgium, France, Ireland,
Italy, Romania, Russia and Spain) the head of state seems to have been
reduced to a spectator. But if a designated candidate fails the mediating
functions of the president or the monarch are needed again, especially
in systems where the formation of minority governments happens
quite frequently (Belgium and Italy).21
In consolidated parliamentary systems the actions of the head of
state are only ‘anticipated reactions’. The process in an ideal case
would lead to the same results, with or without the help of the head of
state. In constitutional monarchies, as in Britain and in France after
1814, the monarch became a pouvoir neutre in government building. In
France, Louis XVII was said to have asked the leader of the strongest
group whether he had a majority. If he answered affirmatively the king
declared ‘Je m’en vais me promener’ (I will go out for a walk). If the
candidate was not sure of his majority the king said ‘Allez vous
promener’ (Go away for a walk). This anecdote, however, gives the
impression that the king’s role in government building was less active
than it really was. Even in Britain until the time of Queen Victoria, the
sovereign was fairly active and far from a roi fainéant, ‘a monarch who
could do nothing’. Even Bagehot knew that ‘It is … an accepted secret
doctrine that the Crown does more than it seems.’22
5.5 Indications for government formation
Mediation in the process of government building has a double perspec-

tive: the head of state has to (1) evaluate the reasons for the dissolution
of the last government and (2) consider the prospects for a forthcom-
ing governing coalition. There are five principles that may be applied
as a guideline when governments topple because of a parliamentary
vote, an electoral failure or a conflict within the government:
• The principle of guilt: if the dissolution of government is caused by a

parliamentary vote it is normal for the group responsible for ending
the last government to take over governmental responsibility.
• The majority principle should be normal in a democracy after
elections.
• The plurality principle applies because in multiparty systems no
clear majority is the result of the elections.
• In such circumstances the plebiscitarian principle can be applied:
the group with the greatest increase of votes in the elections is given
the task of government building.
• The principle of gravitation: when the guilt principle and the various
versions of the majority principle are not applicable – which happens
most frequently in polarised, multiparty systems – groups in the
centre of the party spectrum that have the greatest chance of finding
coalition partners are entrusted with forming the government.
First, in classical parliamentary systems with a parliamentary oligarchy

the guilt principle is the most important guideline in government
building. In Britain in the nineteenth century it was considered as
going against the rules if a group that had toppled a government did
not take over governmental responsibility (Wellington versus
Melbourne in 1839, Derby versus Russell in 1852, Disraeli versus
Gladstone in 1873). But between the two parliamentary reforms (1832
and 1867) there were not always clear-cut party alternatives and the
guilt principle was therefore not always applicable. In the twentieth
century (for example in 1924 when Baldwin was toppled) the guilt
principle was discussed again when a less than congenial coalition of
Labour and Liberals was to blame for the end of the government. The
Liberals eventually forced Labour to attempt to form a minority
government.23
On the continent, fluctuating majorities in multiparty systems makes
it difficult to isolate the guilty party. In consociational systems the
guilt principle is hardly applicable because:
• Raising the question of confidence as a means of psychological

blackmail produces several guilty groups. In 1923, when a Swedish
socialist (Branting) combined a bid for certain measures with a vote
of confidence, the leader of the opposition (Trygger) declared: ‘We
vote “no” and we are ready to take the following consequences.’ 24
But the responsibilities are not always taken fully: In 1926 in
Norway the ousted government demanded that a government be
formed according to the guilt principle. But there was no majority
and parliament finally resorted to a non-parliamentary minority
government. In multiparty systems, humiliated ex-governing parties
normally claim that the guilt principle should be applied to prepare
their revenge. The opposition, on the other hand, tends to claim
that refusal to vote for confidence in the government is not tanta-
mount to an explicit and fundamental vote of no-confidence.
• In multiparty systems there are many guilty groups. When Herriot
ousted Briand in 1926 in France, people gathered outside parliament
to boo the guilty Herriot. When he took over and failed in a vote of
investiture, the crowds gathered again, this time to applaud the par-
liamentary punishment of the bogeyman.25
• The guilt principle does not work in systems such as those in the
Netherlands or the Third French Republic where the parliamentary
leaders are only in loose contact with their party and the party does
not accept responsibility for the actions of some of its parliamentary
representatives.26
With the decline of parliamentary votes as a reason for the dissolution

of government (see Chapter 6), the guilt principle lost its importance
because the democratic majority principle became dominant and
governments were ousted by popular vote.
Second, the democratic majority principle prevails in regimes where
hardly any government chooses to serve its full term. This is the case
in Britain, where the two-party-system makes government formation
the most important issue in electoral campaigns. In continental
regimes with a multiparty system there is a certain polarisation of the
parties, even under proportional electoral law (Austria and Germany).

In other countries with a multiparty system the smaller parties have a
tendency to unite against the dominant party (the social democrats in
Scandinavia and the Christian democrats in Italy during the time of
De Gasperi). Under these conditions a lighter version of the majority
principle takes root. But application of the majority principle as the
normal guideline, as in Britain and New Zealand, has rarely been pos-
sible in Continental Europe. In more than 90 elections between 1918
and 1970 only nine times was an absolute majority won by a party.
European parliamentarians have transformed a dilemma into a virtue
and developed minority governments as an alternative to the majority
principle.
Third, under continental party conditions the plurality principle
emerged as a reduced version of the majority principle. It was respected
even by the reactionary President Hindenburg in 1928, when he called
on the unloved social democrats.27 When governments are not obliged
to withdraw after each election and follow the early British customs of
waiting for the votes of the new parliament, the strongest party some-
times calls for the immediate resignation of the acting prime minister,
as happened in 1933 in Norway. The prime minister (Mowinckel,
Venstre) refused and suggested a parliamentary sanction. He was more
ready to accept the guilt principle than the plurality principle. 28
Between the two world wars the plurality principle was favourable for
social democrats in many countries. Where plurality as a guideline is
not strong enough to escape the demands of the majority principle,
the need for a grand coalition is sometimes deduced from the dilemma
that the strongest party has a plurality but no majority, as in Austria
until 1966.
Fourth, in times of crisis when both versions of the majority princi-
ple are difficult to apply, the plebiscitarian principle becomes impor-
tant. The party with the greatest increase in votes is called to form a
government – even if the plurality principle offers an alternative. The
plebiscitarian principle has its limits, however. The head of state in
many early parliamentary systems – when the plebiscitarian principle
favoured radicals and socialists – defended other indications such as
the gravitational principle, in order to avoid to call on a new group. In
1998 Havel was still being blamed for being reluctant to accept the
social democrats in the Czech Republic.
Finally, the gravitational principle in multiparty systems with fre-
quent minority governments has been the last resort of a number of
presidents who have tried to bring a polarised party system towards the
middle ground. In Italy the trasformismo tactics of prime ministers such

as Depretis (from 1876) were an early example of this principle.
Majority building by corruption in order to stabilise governments in an
undisciplined, floating parliament (Walpole in Britain, Guizot in
France) is another semiparliamentary version of this principle.
Sweden has the honour of having created and justified the model of
‘gravitational parliamentarism’. 29 The Weimar Republic was another
example of this, and in the semipresidential system of Finland there
was a similar attempt between the two world wars to adopt the gravita-
tional principle as a point of orientation for the president. 30 This was
mostly justified in terms of the need for government formation under
conditions of crisis.
The practice has serious drawbacks: democratic majorities are not pro-
moted, parliamentary votes lose importance and even electoral results
are sometimes neglected in an undemocratic way. Small centre parties
are privileged under the auspices of a bourgeois ‘block ideology’, directed
against right and left. It strengthens old-fashioned ideas of a neutral
power of the head of state which threaten to develop in a way passing by
parliament and undermining the democratic majority principle in the
long run. In Spain the exclusion of the right under Gil Robles in prefer-
ence for a tipo centro government is thought to have contributed to
Spain’s move towards right-wing authoritarianism.31
No parliamentary system on the continent has shown such a clear
preference for one guideline on cabinet building as Britain has with the
majority principle. In some countries the gravitation principle has
been exchanged for the plurality principle because the party system
has been reshuffled, as in Scandinavia and postwar Germany. Under
conditions of extreme party pluralism some parties have avoided enter-
ing into coalition because they hoped to benefit in approaching elec-
tions from plurality or plebiscitarian principles. This happened in the
Weimar Republic and Finland. The strongest parties would rather live
with caretaker governments than accept governmental responsibility
before the elections.32
Finland was not by chance most interested in research on these five
principles because it was the only country in which all of them
occurred occasionally. 33 Sometimes the parties followed the device:
gravitation should guide government formation before elections. After
elections the plurality or plebiscitarian principle should be applied.
The informal principle of rotating parties in the government is some-
times barely understandable for the electors, as in Sweden before 1936
and sometimes in the Netherlands.
The great ideological battles over the true democratic principles of

government building have withered away in consolidated democracies.
In 17 parliamentary systems, between 1946 and 1990 about half of all
cabinets were built on the principle of democratic majority or plurality
(see Table 5.4 below). Only 18 governments have been dissolved
because of a parliamentary vote, while 70 governments have collapsed
because of the disintegration of a coalition. Only this last group is
sometimes forced to deviate from the democratic majority principle. In
some countries, for example Bulgaria and Greece, the sequence in
which the majority and plurality principles are applied is laid down
in the constitution.
Even in the twentieth century after the full democratisation of par-
liamentarism the head of state has retained some discretion in the
event of unclear electoral results or irrational behaviour by the parties
responsible for government formation. This room for manoeuvre is
common in systems with extremist parties, whereby the leading groups
accept deviations from the democratic principles of government build-
ing in order to keep those parties from power which are not considered
as koalitionsfähig (acceptable for a democratic coalition). After the
decline of communism, communists and postcommunists continued
to be accepted in most countries, from Sweden to Italy. The German
PDS is the only remaining exception. Only right-wing extremist parties
are not accepted coalition partners in most West European countries.
The room for manoeuvre granted to heads of state is limited in con-
solidated democracies, but in early parliamentary systems the head of
the state sometimes tried to promote certain politicians (as Queen
Victoria did with Disraeli), even though this bordered on being uncon-
stitutional. 34 The reversal side of the coin was for heads of state to
avoid politicians they disliked. Queen Victoria disliked Gladstone, who
in Victoria’s view treated her like a ‘public assembly and not like a
lady’. Even in the new democracies there have been many complaints
about presidents avoiding certain politicians,35 for example the case of
Czech President Havel (versus the social democrat Zeman in 1998).
Sometimes the head of the state entrusts a politician with cabinet-
building only under certain conditions. 36 Strong party leaders,
however, refuse all conditions and only accept ‘suggestions’.
In most consolidated parliamentary democracies the constitutional
law does not allow the head of state to influence the selection of minis-
ters on the formulation of government programmes. Nonetheless,
President Heuss of Germany tried to prevent his rival Dehler from
becoming a minister and President Lübke tried to exclude Gerhard
Schröder from his own Christian Democratic Party. In all cases the
president had his way only if the chancellor did not insist on the nom-
ination of a certain politician. In Germany federal presidents have the
right of refusal only in the case of former Nazis or if they have doubts
about the moral integrity of a prospective minister.37
5.6 The process of consultation on government formation
Democratised parliamentary constitutions in the twentieth century

tried to limit the influence of the head of state by making consultation
mandatory in order to avoid the ‘kitchen cabinets’ and camarillas of
early parliamentary monarchies and semipresidential systems. The first
new parliamentary constitution in Europe after the Second World War,
the French constitution of 1946, prescribed only vaguely the ‘custom-
ary consultations’ (consultations d’usage, Article 45). Bulgaria and
Greece finally prescribed not only consultations but also the sequence
of consultations of party leaders.
First, in early parliamentary systems the first person to be consulted
was normally the previous prime minister – many leading statesmen
skilfully used the tactic of resigning in the expectation of being
entrusted again with government building under better conditions. 38
Second, parliamentary speakers were more often consulted than
entrusted with government formation (exceptions being in France in
1914 and 1919). The revised Swedish constitution (Chapter 6, § 2)
removed the function of cabinet formation from the crown and
handed it over to the parliamentary speaker which was the strongest
involvement of a speaker in any parliamentary system. The distrust in
the heir to the throne later proved to be misplaced.39
Third, in a multiparty system the head of state normally consults the
leaders of important party groups. In the Weimar semipresidential
system the father of the constitution, Hugo Preuss, complained that
the parliamentary groups were abusing their right to be consulted and
were distributing the ministerial portfolios among themselves. He
came to the conclusion that this was ‘no longer parliamentarism but
its caricature’. Even true democrats at that time were inclined to
restrict the party state in government formation. 40 Nevertheless the
consultations continued to take place when a clear indication by
democratic majority rules was not visible. With the decline of the
upper house in two-chamber systems the party leaders of the second
chamber have been consulted less frequently, as in the Netherlands.41
With increasing democratisation not only party leaders but also party
conventions have asked to be consulted on government building, as it

was the case with the German Green Party in 1998. In two-party
systems a shadow cabinet can be endorsed before new elections. But
even in Britain there have been times when the Conservatives have
had to promote a prime minister when no clearly designated leader
existed (Baldwin’s access in 1923, Chamberlain in 1937, Churchill in
1940, Eden in 1955, Macmillan in 1963, when he fell ill). But rarely
has a party gone as far as the Australian Labour Party, which elected
not only the prospective prime minister but also the entire shadow
cabinet by caucus ballot.42 In moderate multiparty systems the
strongest opposition party can only afford to designate a nucleus of a
cabinet because it has to respect the interests of a potential coalition
partner. Only once has a German party obtained an absolute majority
(1957), but even then a coalition was formed. New constitutions
(Bulgaria, Article 9.9; Finland, § 36; Portugal, Article 190; Sweden,
1974, Chapter 6, § 2; Hungary, Article 33.3; see Table 5.3, column 1)
have secured the right of party leaders to be consulted. In all these
cases the party system would have enforced such consultations even
without a constitutional obligation.
Finally, in extremely fragmented multiparty systems with frequent
minority governments cabinet formation has sometimes been so
difficult that a mediator has been required, thus the Dutch term infor-
mateur entered the literature. However, informateur is rarely the creator
of a cabinet. Missions of mediators are used:
• When the guilt principle is not applicable because the party leaders
have kept a certain distance from their former government. A Dutch
specialist applied a poem of Heinrich Heine: ‘Do not compromise
me, my beautiful child, and don’t say hello to me under the lime
trees, later when we are both at home everything will be okay.’42
• When the party guilty of a cabinet collapse does not accept
responsibility.
• When the strongest prospective government party has a leadership
crisis and factions have to be consulted.
Belgium and the Netherlands developed this institution most fre-

quently.44 As old as this function was criticism from a democratic point
of view because:
• The existence of an informateur reduces the influence of the head of

state.
• Conversely the head of state may strengthen his or her position,

impose conditions (Germany in 1925, Italy in 1957) and create an
undemocratic atmosphere of secrecy.
• The inflation of informateurs who should be used only in times of
crisis.45
• There is a reduction of the functions of parliament in cabinet
formation.
Since a recent, more benevolent analysis of minority government the

role of the informateur has been seen in a more positive light. 46 The
Netherlands and Belgium have been plagued by failure on the part of
coalition builders (up to eight times in the formation of one govern-
ment). Some of these processes have taken more than three months
(Drees, Den Uyl in 1973, Van Agt in 1977, Van Agt in 1981).
5.7 The head of state and the routine business of

government
In semipresidential systems some prerogatives in foreign policy have

been preserved for the head of state. Sometimes the head of state is
commander-in-chief of the armed forces but normally under the strict
supervision of parliament. In the Federal Republic of Germany, the
president is excluded even in the event of armed conflict, when the
command is transferred from the minister of defence to the federal
chancellor (Article 115 b) (see Table 5.3). In recent parliamentary
systems emergency powers have been vested in parliament, especially
in Germany and Sweden.
The strongest influence on the routine business of government is
vested in the heads of state in semipresidential systems in that they
preside over cabinet meetings. Compromises have been reached in some
semipresidential systems, for example in Finland (§ 39) the president
presides only when ‘matters of his responsibility’ are discussed. The
Romanian constitution (Article 87.2) contains the truism that the presi-
dent ‘presides only when he is present at the meeting’. Representative
obligations increasingly prevent presidents – as was earlier the case with
monarchs – from taking care of normal business in the cabinet.
5.8 The head of state and dismissal of government
Dating from the times of dualistic constitutional monarchies, the

custom of resignation in the event of a change in the office of the head
of state has continued in some semipresidential systems. Between 1946

and 1990 there were only half a dozen cases, most of them in France
(Table 6.5).47
More important is the question of whether the head of state has the
right to dismiss a government. Melbourne (1834) was the last case of
an attempted dismissal of a prime minister in Britain, but the attempt
failed as the Conservative Peel was not accepted by the parliamentary
majority and Melbourne had to be reappointed. Some constitutional
lawyers still believe in the right of monarchs to dismiss ‘their’ govern-
ment. Politicians such as Disraeli and Gladstone accepted such a right
only in the case of a government without a parliamentary majority
trying to stay in office. In the parliamentary systems of the
Commonwealth countries the governors general have more frequently
defended the right of the crown to dismiss a government.
In six European countries with a certain continuity, between 1884
and 1914 only three resignations were the consequence of a conflict
with the head of government (Belgium, one case; Norway, two cases).
The outcome of other conflicts was hidden under the rubric ‘voluntary
resignations’; as with MacMahon in France in 1877. More recently, vol-
untary resignations have disguised pressure by the president, as in
Finland in 1924 under Ståhlberg. 48 In the semipresidential system of
Austria the removal of a chancellor against his or her will is considered
legally possible. 49 But in a party system that has frequently favoured
grand coalitions the exercise of such a right has hardly been feasible.
Not even Yeltsin, with his ‘three-quarter presidential’ system, has been
able to impose government leaders at will, as the dismissal of
Chernomyrdin and Kiriyenko showed in 1998.
5.9 Dissolution of parliament by decree of the head of

state
The dissolution of parliament has changed its function over time. In

dualistic constitutional regimes dissolution has been used against par-
liaments that have openly criticised the crown and its ministers. In
1830 in France the dissolution of parliament proved to be a dangerous
weapon: the regime was toppled by a revolution.
In early constitutional systems the dissolution of parliament was lib-
erated from the need to obtain the approval of ministers.
Semipresidential systems of the republican type normally require the
signature of the prime minister before a presidential decree of dissolu-
tion can be effected (Table 5.4).
Table 5.4 Dissolution of parliament
Legislative period Premature dissolution Dissolution of upper house Self-dissolution of parliament
Australia 3 At request of prime minister Yes No

Austria 4 Article 29, president, only once for the same No Article 29.2
reason
Belgium 4 Article 46, in the case of votes of no confidence Article 46, automatically if Article 46, indirectly, if majority
dissolution of parliament approves to monarch
Britain 5 Monarch at request of prime minister No No
Bulgaria Article 99.5, president in the case of deadlock in No No
government building; Article 99.7, not in the last
three months of the president’s term of office.
Canada 5 Frequently No No
Czech Republic Article 62c, without specification Article 68, no responsibility to No
parliament
Denmark 4 Article 32.2, president de facto initiative of No No
government
Finland 4 §27, president on initiative of government and No No
hearing of parliamentary groups
France 5 Article 12, president after consultation with Yes No
prime minister and president of parliament
Germany 4 Article 68, after failure of vote of confidence; No No
Article 63.4, unsuccessful government- building
Greece 4 Article 41, president if two governments fail No No
and governmental stability is not guaranteed;
Article 41.2 in case of ‘national question’
Hungary Article 28.3, president if four consecutive votes No Article 27.2
of no confidence; new: 2x dissolution possible.
President has to consult prime minister and
chairs of parliamentary groups.
137
Ireland 5 Article 13.2.1, on advice of prime minister No regulation for senate No

Legislative period Premature dissolution Dissolution of upper house Self-dissolution of parliament
Israel 4 No No Article 75
Italy 5 Article 88, not in the last month of the Article 88, hearing of No
president’s term of office parliamentary president
Japan 4 Article 7, emperor with approval of No, but upper house closed No
government; Article 54 motion of government; (Article 7)
Article 69, in case of no confidence
Luxembourg 5 Article 74, grand duke No No
New Zealand 3 Article 18, governor general, de facto with No Yes, if bill is passed
motion of government
Netherlands 4 Article 64, monarch, de facto on initiative of Article 64 No
government
Norway 4 No No No
Poland Article 144.3.3, with countersignature Yes No
Portugal 4 Article 175, president, not in the six months No No
before the end of the presidential term; in the
event of a state of siege
Romania Article 89, president, consultation of president Article 112.4, senators can also No
of parliament and chairs of parliamentary sign motion of no confidence
groups; in the case of a blockade on government
building
Russia Articles 84b, 109.3, not in first year; Article 109, No No
not in case of presidential impeachment; Article
111.4, in case of disapproval of investiture
Spain 4 Article 64, monarch on motion of government; Yes No
Article 115, one year after the first dissolution;
not introduced to motion of no confidence
Sweden 4 Chapter 6, §5, exceptional elections; possible No No
(previously 3) after vote of no confidence
This was the case even in the Weimar Republic. France (Article 12)
seems to be an exception, according to the dominant interpretation.
Nonetheless the president is obliged to consult the speaker of the
parliament and the prime minister.
In Westminster-type parliamentary systems, custom rather than con-
stitutional provision has changed parliamentary dissolution to a strate-
gic instrument in the hands of the prime minister, similar to the tactics
of resignation. In consolidated parliamentary regimes dissolution is no
longer considered as a coup d’état type of action, as in France since
1877. Electors and even the opposition have accepted frequent dissolu-
tions, so that most parliament do not last their full term. Only in
Sweden until the constitutional reform did the dissolution of parlia-
ment not promise an advantage because the new Riksdag terminated
on the same date as the old one.
Five conditions for the dissolution of parliament have been
codified:
• A parliamentary vote of no-confidence against the government. The

people have to settle conflicts between government and the parlia-
mentary majority (Belgium, Article 46; Japan, Article 69; Sweden,
Chapter 6, § 5; Hungary, § 28.3). In Hungary this condition is
applied only when the government is confronted with four votes of
no-confidence in one year. In Spain dissolution is impossible if a
vote of no-confidence is pending.
• Failure of a vote of confidence (Germany, Article 68).
• Deadlocks in government formation (Bulgaria Article 99.5;
Germany, Article 63.4; Greece, Article 41).
• As a substitute for referenda on questions of national importance
(Greece, Article 41.2).
• In early parliamentary systems the dissolution of parliament was
common on the occasion of constitutional amendments (Belgium,
Denmark in 1915, Luxembourg, Article 114) or a change of the head
of state (Britain until the Representation of the People Act 1867;
Belgium, but Article 85 is not applied; applied in Piedmont in 1849).
Constitutional amendments that change the balance of government
–legislature relations, as in Sweden, make premature elections
indispensable.
The fourth condition has frequently been used in Westminster-type par-

liamentary governments. Premature elections are conducted in the light
of certain issues and the electoral results are interpreted as the mandate
of the people. This instrument has to be used carefully. As Balfour

declared: ‘No constitution can stand a diet of dissolutions’.50 In France a
radical concept of parliamentary government is combined with the call
for a life without turmoil. As early as 1872 one of the founding fathers
of the Third Republic, Dufaure, declared in parliament that ‘dissolution
is a synonym of agitation’.51 In Norway there is no dissolution of parlia-
ment. Referenda have to be conducted without detour.52 In France both
possibilities have been available in the Fifth Republic. De Gaulle pre-
ferred the referendum to parliamentary dissolution, but in May 1968,
after the students’ rebellion, he declared that a referendum was not
feasible. The leftist parties called for premature elections but De Gaulle
won an absolute majority. Referenda have the advantage that a decision
on a clearly formulated alternative is possible without deciding at the
same time the touchy question of the continuity of government.
Sometimes reform of the electoral law leads to the dissolution of par-
liament. Experiments with electoral law and the introduction of pro-
portional representation led to frequent dissolutions of parliament at
the beginning of the twentieth century, especially in Belgium (1848,
1894 and 1900), Luxembourg (1918, 1919 and 1954), Italy (1870, 1882,
1913, 1919 and 1933), Sweden (1919, 1921 and 1970) and Denmark
(1918 and 1920). These special circumstances have to be considered in
calculations of governmental stability in the period before the First
World War. The mandatory dissolution of parliament on the occasion
of constitutional amendments is hardly a good solution because it
invites governments to postpone necessary constitutional changes.
The delay in resolving the languages conflict in Belgium was explained
by the conjunction of reform and the threatened dissolution of
parliament.53
Other reasons for dissolving parliament have fallen into oblivion,
such as dissolution to resolve a conflict between the two chambers. The
decline of second chambers and the development of other instruments
of mediation between the two chambers rendered the dissolution of
one or both chambers unnecessary. In federalist countries this instru-
ment is excluded anyway because the representation of the federal
units cannot be made subject to the democratic principle of elections
without violating the rights of the concurrent majority.
Since the democratisation of parliamentary regimes dissolution has
been constitutionally limited in several respects.
First, there is the legal rule ne bis in idem – no second dissolution for
the same reason as the first (Weimar Republic, Article 25; Austria,
Article 29.1). The clause ‘no dissolution for one year after premature
elections’ has a similar aim (France, Article 12.4; Spain, Article 115.3).
In other systems frequent dissolutions are possible, sometimes even in
the same year (Britain in 1910, Greece in 1915). More frequent are sub-
sequent dissolutions for different reasons (Britain in 1922, 1923, 1924,
1950, 1951, 1965, 1966). In Canada, Diefenbaker dissolved parliament
for the second time after just 10 months and he had not even suffered
a parliamentary defeat.54
Second, in some countries young parliaments are protected, for
example there can be no dissolution in the first year of a Duma (Russia,
Articles 84 b, 109.3).
Third, dissolution may be prohibited during periods of emergency
law (Russia, Article 109.5) or when an impeachment against the presi-
dent is pending. When Yeltsin threatened in April 1998 to dissolve par-
liament if his prime ministerial candidate did not obtain a majority in
the third round of voting the postcommunists considered impeach-
ment to prevent the president from dissolving the Duma. Finally,
however, a majority decided it would be better to accept an undesirable
prime minister than to run another electoral campaign.
In two-chamber systems the upper house usually has no right to
topple the government (see Chapter 3). Therefore parliamentary reason
would suggest that the upper house should not be dissolved with the
first chamber. But in Belgium (Article 46) there is the rare exception
that the second chamber is dissolved automatically with the first. This
provision may be democratic but it is hardly federalistic. In most feder-
ations the federal chamber cannot be dissolved by the head of state.
An alternative to dissolution by the head of state is the self-dissolu-
tion of parliament. This exists in Israel (Article 75), Austria (Article
29.2) and Hungary (Article 27.2). In Germany dissolution is so
restricted (only in the event of a deadlock in cabinet formation and
after the loss of a vote of confidence) that self-dissolution has been dis-
cussed – but it has never been accepted, though it does exist in the
biggest Land (North Rhine-Westphalia). Self-dissolution is hardly an
equivalent. Parliamentarians are not interested in shortening their
mandate and it is therefore unlikely that self-dissolution can solve
conflicts between the constitutional powers. In France it was consid-
ered in 1946 by the Socialist Party in order to weaken the president of
the republic, 55 but it was not accepted and in the Fifth Republic moves
have been made in the opposite direction: to strengthen the president
against the powers of the chambers.
In parliamentary democracies the dissolution of parliament needs
the counter signature of the government. This was not the case in early
parliamentary monarchies, but monarchs usually legitimised their

actions by finding a minister to sign their decree to dissolve parlia-
ment. In 1830 even the presence of a counter signature did not legit-
imise the dissolution of parliament in the eyes of the people, so they
revolted and toppled the regime.56
Dissolution – with or without a counter signature – in early parlia-
mentary regimes was deemed to be justified for various reasons:
• The pretext that the government needed a broader majority was

used to dismiss governments and occasionally to dissolve parlia-
ment (Britain in 1784, 1807 and 1834; Piedmont Italy in 1849, the
‘proclamation of Moncalieri’; the Netherlands in 1866).
• Sometimes the autonomous actions of the crown were accompanied
by a government that dared to confront the parliamentary majority
(Kampfregierung) (the Netherlands in 1868, France in 1877, Denmark
in 1920). In democratised parliamentary regimes this was consid-
ered illegal. In non-consolidated systems such a procedure was nor-
mally the first step towards dictatorship (Lithuania in 1926, Bulgaria
in 1934, Yugoslavia in 1929). After some delay the same thing took
place in Estonia, Poland, Latvia and Austria, and in 1932 in the
Weimar Republic.57 Only occasionally did this not usher in authori-
tarianism, as under President Ståhlberg in Finland in 1924, when
the 24 communist deputies were arrested. The social democrats
accepted this coup because they hoped to win the communist con-
stituencies during the forthcoming elections. 58 This operation was
considered necessary in order to stop the latent civil war and save
democracy.
The right to dissolve parliament then shifted from the head of state to
the prime minister. There were some doubts about whether prime
ministers should consult their cabinets on the matter. Only in the
French Fourth Republic was this constitutionally required (Article
51), and in most parliamentary regimes it was left to the wisdom of
the head of government. In Britain the precedents were not quite
clear and weak prime ministers consulted their cabinets. In 1841
Melbourne was outvoted on this question by his colleagues in the
cabinet.59 Strong prime ministers such as Disraeli did not even ask
their cabinets and the British mainstream doctrine did not require
cabinet consultation. In weaker continental systems the head of gov-
ernment had to discuss the prospect of dissolution (Sweden in 1887
and Italy in 1953). In France during the Fourth Republic, where dis-
cussion by the cabinet was required the cabinet disintegrated over

this question in the only dissolution that ever took place under this
regime (Faure in 1955).
The role of the head of state in most regimes – except some semipres-
idential systems – in this process of deliberation was reduced to that of
advisor and if necessary a dissolution could take place without consent.
The debates are now out of date whether the head of state could refuse
a prime minister’s demand for dissolution. Queen Victoria did not dare
to refuse in certain cases. In 1910 George V was reluctant to endorse a
second dissolution within a short space of time. He did it only to avoid
a constitutional crisis and to remove the opposition of the House of
Lords to the Parliament Act. Even Churchill later agreed with the doc-
trine that the crown’s function was to ‘to advise, to encourage and to
warn’.60 In the Commonwealth countries there were more instances of
proposed dissolutions being refused. By the outbreak of the Second
World War 110 dissolutions had been granted and 51 refused.
This deviation from the British precedent has been explained by the
more fragmented party system in the dominions, which gave the gov-
ernor general more room for manoeuvre. 61 Justifications for refusing
dissolution were:
• A vote of censure had not yet been decided upon (in Spain this rule
was inserted into the constitution – Article 115 b).
• Other parliamentary coalitions had promised a working cabinet.
• Premature elections would be detrimental to the economic develop-
ment of the country.
Left-wing writers such as Harold Laski did not accept any active role on
the part of the monarch.62 As long as the two-party system worked this
debate remained, however, purely academic. This was shown in
Belgium, where the monarch refused to endorse a dissolution only
once (in 1841). The monarch’s room for manoeuvre grew, however, in
the twentieth century in multiparty systems. 63 Even in Italy and
Sweden in 1905 – which were not fully parliamentary systems at that
time – the monarch occasionally tried to resist.64
In semipresidential systems the discretion of the president was much
greater. During the Weimar Republic, the social democratic President
Friedrich Ebert caused the resignation of an important imperial chan-
cellor, Stresemann, by refusing to dissolve the imperial diet. His succes-
sor, Hindenburg, who was much less democratic, later used this
precedent to justify his presidential initiatives. To one of his favourites,
von Papen, the president gave full discretionary power to declare a

dissolution in the event of a hostile parliamentary vote.65 More demo-
cratic presidents in Finland used their influence in debates on the
dissolution of parliament (1953 was a much debated case). Full discre-
tionary powers were developed in early parliamentary systems, even in
Britain. Queen Victoria occasionally resisted such demands (with
regard to Peel in 1839, Russell in 1851 and Derby in 1858) but granted
it to her favoured prime minister, Disraeli, in 1873.66 In countries with
uncertain majorities the prime minister had a better chance of coercing
the head of state; discretionary powers of dissolution were exchanged
for governmental responsibility (Belgium in 1845 and 1857, Italy in
1878 and 1969, Sweden in 1911 and 1917).67
In most constitutions there was no obligation to motivate the disso-
lution of parliament.68 But in order to avoid the suspicion that dissolu-
tion was being used to manipulate the majority, decrees of dissolution
were normally accompanied by political justifications. When none
were mentioned – as in 1866 in the Netherlands – this was considered
at best as ‘unfair’.69 In the nineteenth century about one half of disso-
lutions were caused by a conflict between government and parliament
(eight cases in Britain, five in the Netherlands, three in Belgium). In
the twentieth century, with the democratisation of parliamentary
systems, the ratio changed. In 60 years in Belgium (1900–60), of the 13
dissolutions of parliament not one was caused by a conflict between
the executive and the legislature; in Britain there was only one case
among 16 dissolutions (1924) while in the Netherlands there were
three out of 10 cases (1904, 1933 and 1958). However, over time
Britain became the classical example of a country where conflict
between the two powers was the reason for premature elections (10
out of 33 dissolutions between 1832 and 1963).70 In Britain, parlia-
mentary defeat was normally followed by the dissolution of parlia-
ment. In the French Third Republic (1875–1940) parliamentary defeats
were frequent, but the abuse of the dissolution of 1877 made further
dissolutions impossible. In the Fourth Republic (1945–57) there was
one dissolution (1955), but it was unpopular because only a small
majority was in favour.71
In Scandinavia the dissolution of parliament is rare. In Norway it
does not exist, in Denmark it has rarely been used and in Sweden there
was only one case between the introduction of universal suffrage and
the total revision of the constitution (1919–70).72 Italy has had a tradi-
tion of dissolution since 1860. In Germany dissolution has only
occurred in the wake of questions of confidence under conditions with
manipulated majorities (1972 and 1982) (see Chapter 6). In these cases
dissolution was not used to end a conflict between the executive and
the legislature but to legitimise a parliamentary majority by popular
vote. Thus the parliamentary manipulation had at least some democra-
tic legitimation.
The dissolution of parliament is declining in importance because
most governments are terminated not by parliamentary votes but by
regular democratic elections. A quantitative comparative analysis is
difficult because there are countries where dissolution does not exist
(Norway and Israel) or is restricted (Federal Republic of Germany), or
where dissolution is unattractive because of the short parliamentary
term (Sweden until 1970). Of the remaining regimes it seems advisable
to differentiate between two types (Table 5.5):
• Westminster-type regimes (Britain, Ireland, Australia and Canada).

Here there are frequent discretionary dissolutions by the prime
minister. Premature dissolution of parliament is defined here as
taking place a year or more before the normal end of a mandate
(five years, except in Australia). Out of 63 elections (1945–95)
almost one quarter of the parliaments were dissolved prematurely,
and about 15 of these took place before the designated end of
the legislature. Canada, a parliamentary regime that combines
the Westminster model with a multiparty system and occasional
minority government, naturally has the highest proportion
of early dissolutions (six out of 16), followed by Ireland (five out
of 15).
• Continental parliamentary systems with some elements of consocia-
tional democracy. In 50 years (1945–95) Belgium, Denmark,
Finland, France, Italy, Luxembourg, the Netherlands and Austria
had a combined total of 122 elections. Denmark was on top with
20 elections in 40 years. The average was about 15 elections. Almost
half of them (54 cases) were due to the premature dissolution of
parliament. In one third of these cases (33) dissolution took place
two years before the end of the mandate. There have been more
dissolutions in this group than in the Westminster-type regimes
and as many as two elections in one year (Denmark in 1953, France
in 1946, Ireland in 1982); in 12 cases there were two elections
within a period of two years. Though minority parliamentarianism
does not normally produce great changes in party composition,
minority governments occasionally resort to dissolution to resolve a
deadlock.
Table 5.5 Early dissolution of parliament as indicator of a crisis
Countries Legislative Number of Early More than two Two elections in

period (years) elections dissolution years before one year
normal election
Westminster model
Britain 5 13 2 2
Ireland 5 15 5 5 1
Australia 3 19 4 2
Canada 5 16 6 6
Total 63 17 15 1
Continental parliamentary systems
Belgium 4 17 4 3
Denmark 4 20 20 9 1
Finland 4 15 4 1
France 5 14 8 7 1
Italy 5 13 4 4
Luxembourg 5 12 3 3
Netherlands 4 15 4 4
Austria 4 16 7 2
Total 122 54 33 2
‘Country families’ and regime similarities determine the use of parlia-

mentary dissolution, but there are other circumstances that lead to fre-
quent dissolutions:
• In the phase of consolidation after 1945 many regimes had frequent

elections as a consequence of the constitution-making process and
certain initial crises of the regime. Two regular elections are said to
be an indication of the consolidation of democracy. This rule
should be qualified as two regular elections without a premature dis-
solution of parliament.
• Dissolution is more frequent in times of unrest and ideological
mobilisation (the end of the 1960s and the early 1970s).
• In cases of constitutional reform (France, Sweden and Italy).
• In cases of referenda unfavourable to the government (Denmark and
Austria). If referenda on further integration into the European
Union are spreading, forthcoming waves of premature parliamen-
tary dissolution are to be expected.
• Broad presidential powers in semipresidential systems can result in

more frequent dissolution of the legislature. This has been the case
in France, but not in Finland. Austria and Ireland have had many
premature elections, but these were the consequence of conflicts in
the coalition and not of the discretionary powers of the president.
The early 1950s and early 1960s, as well as the 1990s (except in the
new democracies in Eastern Europe), were comparatively quiet periods
in parliamentary terms. Criticism of dissolution is still common, but it
is no longer directed against the head of state, but rather against the
government. There are no longer ‘confessional wars’ on this question,
as in early parliamentary regimes. The topic seems to have fallen into
oblivion and literature on the subject has become rare.
Finally, what effect does the premature dissolution of parliament
have on governmental stability? Generalisations are hard to make for
several reasons:
• The impact of dissolution depends on constitutional restrictions (in

Germany, and in the short term for new parliaments in Sweden
until 1970).
• The organisation of a two-chamber system is important. Only when
dissolution is occasionally used to end a deadlock between the two
chambers is governmental stability increased (Belgium and Italy).
• The power of the head of the state to dissolve parliament in early
parliamentary monarchies and semipresidential systems has some-
times increased governmental stability (Piedmont/Italy) or exacer-
bated the existing instability (Belgium under Leopold I and Leopold
II). In the Weimar Republic dissolution worked in both directions.
• The impact of dissolution depends on the reason for the dissolution.
If parliamentary defeat or the disintegration of a coalition is the
reason for the premature dissolution of parliament, in the long run
dissolution can add to the stability of governments.
• The consequences of dissolution are determined by the party
system. In fragmented multiparty systems, dissolution rarely con-
tributes to the stabilisation of the government (Finland, the Weimar
Republic, the Netherlands, the Republic of Italy).
• Different countries have different attitudes towards parliamentary
dissolution. In Britain, premature dissolution is seen as normal,
whereas in France it is considered as a kind of coup d’état. In most
systems a call for dissolution is combined with the hope of winning
the subsequent election. In Britain and Belgium, as early as the
nineteenth century it was considered unfair to ask for the dis-

solution of parliament when an electoral victory could not be
expected.73 In such cases many constitutional lawyers considered
that the monarch was entitled to refuse to dissolve parliament.
How could a monarch in the nineteenth century know how the elec-
tions would turn out? Only in democratic societies with sophisticated
public opinion polls could this question be realistically answered. But
even in the twentieth century there have been many miscalculations.
Every second British prime minister has failed to get the results he or
she expected from a premature dissolution. Even Churchill, the
‘saviour of the nation’ in the Second World War, was hailed in 1945
wherever he campaigned – but he was not elected. In multiparty
systems many dissolutions have been of little benefit to the govern-
ment that asked for it (Denmark in 1947, 1953 and 1973, Finland in
1955 and 1971, France in 1975, Italy in 1958, 1972 and 1976).
The doctrine that dissolution is necessary to governmental stability
is no longer true. 74 Norway, which lacks the possibility of dissolving
parliament, is no less stable than the other Scandinavian countries.
This argument has frequently been used in Norway to block the possi-
ble introduction of dissolution.75
6
The Government and
Parliamentary Majority
It has never been thought desirable that Parliament should itself

nominate even the members of a Cabinet. It is enough that it
virtually decides who shall be prime minister or who shall be
the two of three individuals from whom the prime minister
shall be chosen.
John Stuart Mill
6.1 Cabinet solidarity
In absolutist periods there was no government proper – even if a

cabinet was sometimes mentioned – but rather the ‘closet’ in which
individual councillors met the monarch. In confrontation with the
crown a certain solidarity among the individual councillors devel-
oped, but the more autocratic the monarchical rule the less solidar-
ity there was among the councillors. 1 Solidarity grew when a council
of ministers as a collective body was accepted. Paradoxically this
development needed a hierarchy, headed by a prime minister. In
Britain the cabinet had some difficulty in developing parallel to the
privy council. Only in 1746 was the first collective resignation of a
ministry possible, though the king nominated and dismissed his
ministers individually. Solidarity was hard to develop if the monarch
did not assemble the ministers together but invited them individu-
ally to his or her ‘closet’, and not all councillors had the right to ask
to be invited. Only in 1740 was a body developed that deserved the
term cabinet. There was no single event that changed the laws, but
rather a smooth change of customs on the basis of party govern-
ment. 2 Solidarity grew out of a gathering that was held before the
ministers individually met with the monarch. The monarch was no
149
longer able to divide and rule as the councillors all gave roughly the
same advice.
Governmental organisation was modernised and a hierarchy devel-
oped under a prime minister. The monarch was no longer able to take
care of the details of government and the governmental machine had a
certain degree of autonomy vis-à-vis the monarch. The differentiation
between crown and government was promoted by the increasing
autonomy of parliament. Oddly enough the dependence of the govern-
ment on the parliamentary majority strengthened the prime minister
before the monarch.
The council of ministers was a de facto achievement in Britain, but
de jure it was not recognised on the continent. In France only the con-
stitutional laws of the Third Republic recognised its existence (1875). 3
In Belgium – the first continuous parliamentary system on the conti-
nent – the council was rarely mentioned in laws and decrees until
1918.4 Partially parliamentarised constitutional monarchies, such as
the German Empire (1871–1918), did not recognise the existence of a
ministerial council because of the constitutional fiction that the federal
council – a collective body of German princes – was the governing
body. The imperial chancellor had a superior position in that he was
also prime minister of the biggest state, Prussia. Bismarck vehemently
opposed his secretaries of state (not even ministers existed) giving
direct advice to the emperor and collective resignation of the cabinet
was beyond his imagination. When he was dismissed in 1890 by the
emperor, oddly enough he was resentful about the lack of solidarity
shown by his secretaries of state, some of whom continued to serve in
the government.5
6.2 The organisational power of government and the

proliferation of offices
In constitutional monarchies the organisation of government was the

prerogative of the monarch. Only in the US presidential system was
the creation of offices from the outset dependent on the assent of the
Senate (Article 2, Section 2). With the increasing parliamentarisation of
regimes, parliaments developed a general distrust in the organisational
power of government and tried to prevent the proliferation of offices
via their right to approve the state budget. One of the main liberal
doctrines was no permanent office without a law.6
Only in modern parliamentary democracies was the power to create
offices again vested in the government. Parliament had a veto only in
The Government and Parliamentary Majority 151
budgetary matters and it usually endorsed the faits accomplis of the

executive. Parliaments in constitutional monarchies were frugal, but in
parliamentary systems they created lavish offices in order to exercise
patronage. This evolved because of two developments: an increase
in offices, and a hierarchisation of previously equal government
colleagues.
Party government, which grew with parliamentary regimes,
increased the number of governmental offices. When factionalism
within parties was strong, as in the case of the Italian correnti, the gov-
ernment apparatus expanded. As a rule it was said that coalition gov-
ernments increased the number of offices. But prime ministerial,
one-party governments of the Westminster type contributed still more
to the proliferation of offices, up to the point where one third of the
governing parliamentary group in Britain also held an executive office.
The ‘executivisation’ of parliamentary personnel had some repercus-
sions on parliament. When all the capable deputies held an office the
remaining parliamentarians were weakened and it was not easy to
organise parliamentary activities independent of the government. In
1900, of the 670 MPs 33 were ministers and nine were parliamentary
private secretaries. In 1966 there were fewer MPs (630), but the number
of ministerial offices had increased to 88, plus 28 parliamentary secre-
taries of state. 7 In continental countries the number of ministers
remained lower – especially in Germany, where it has not exceeded
17–19 on average (in 1998 only 15). But the introduction of parliamen-
tary secretaries of state according to the British model increased the
possibility of party patronage. This proliferation of offices led to regula-
tions on the matter:
First, constitutional restrictions were put on the number of offices.
Most constitutions in parliamentary systems preferred a flexible solu-
tion. Cromwell’s ‘Instrument of Government’ (1653) fixed the number
of council members at 13–21. The oldest constitution on the conti-
nent, which remained valid even in parliamentary times (from 1917),
was the Swedish Regeringsform (1809). The state council did not fix the
number of ministers – which was governed by a parliamentary law –
but required at least three state councillors without portfolio. In 1918 a
law limited the number of ministers to between eight and 20; in 1947
this number was reduced to 11 and in 1968 it was raised to 12.8 These
limits were severely criticised and the argument was forwarded that in
other parliamentary systems the executive had the right to create min-
istries according to need.9 Norway limited the number to seven (§ 12 of
the constitution) but from 1955 the government increased to 14
departments. Luxembourg required a minimum of three ministers

(Article 76), Ireland 7–15 (Article 28.1) and Australia seven (Article 44).
In France (the Fourth Republic) constitutional limitation for the power
of the government was refused with the argument that a scarcity of
ministries is normally accompanied by a lavish proliferation of offices
below the ministerial level. 10 The United States could serve to support
this hypothesis.
The theory of organisation suggests that a ministerial council works
best with 7–9 members but coalition theory does not allow narrow
limits. Party systems and internal factionalism in the parties determine
the number of necessary portfolios as much as considerations of group
cohesion. The bigger the cabinets the more hierarchical the structure,
as Britain has shown.
Second, in federalist countries constitutions frequently change the
competences of the central government. This causes the head of gov-
ernment to adjust the number of ministries to the number of federal
powers. Rarely, however, have federal constitutions enumerated the
federal ministries to the extent to which the constitution of the former
Soviet Union did (Article 77) because every organisational change
needs a constitutional amendment.
Third, in revolutionary periods parliaments have tried to monopolise
the executive’s organisational powers. Radical French deputies in 1791
deprived the king of the right to nominate ministers and the radical
convention even abolished the title of minister. Some founding fathers
in the United States wanted to entrust Congress with the creation of
executive posts, for example Roger Sherman of Connecticut ‘wished
the number might not be fixed, but that the legislature should be at
liberty to appoint one or more as experience might dictate’. 11 The
Second French Republic reserved the creation of ministers for parlia-
ment (§ 66) and the communist draft of a constitution for the Fourth
French Republic tried to renew this tradition. 12 The leading constitu-
tional lawyers were vehemently opposed to the idea, as well as a law of
1920 (Article 8) that postulated that ministries could be established
only by parliamentary law, on the ground that this Republican device
violated the principle of separation of powers.13 De facto this provision
was not often respected. Germany too has occasionally adopted a doc-
trine of genereller Gesetzesvorbehalt (no ministry without a law), which
has also been criticised in the name of division of powers and likewise
not respected.
The limitation of offices in democratised parliamentary systems is an
impractical vestige of the dualistic constitutional monarchy. With a
parliamentary majority behind the government it is no problem to

create laws ad hoc. Requiring a law for the establishment of portfolios is
no longer an effective barrier against the expansion of executive offices.
Even indirect limits, such as those Britain laid down in the House of
Commons Disqualification Act (1957), which restricted the number of
offices compatible with a parliamentary mandate to 70, were ineffec-
tive. In the Ministers of Crown Act (1964) this number was increased to
91. The experience during the Italian monarchy (1860–1943), with par-
liamentary participation in the creation of ministries, shows that legal
limits did not hamper the permanent increase of offices.14
The inflexible restrictions on the compatibility of mandate and office
were a boon to the patronage power of parliament: leftover posts were
sometimes entrusted to non-parliamentarians, which was the opposite
of what most backbenchers wanted.
Fourth, effective restraints on the proliferation of offices today can
only be political restraints. An effective opposition is more important
than legal limits. Democratisation restricted the proliferation of offices
because the creation of new ministries is always unpopular, though cit-
izens mostly have an eye on the costs, which are out of proportion and
certainly without insight into the organisational requirements of
modern government.
Talk about the ‘self-serving mentality of the political class’ arises
after every cabinet formation and there are complaints about the
number of ministries. But comparisons show that in most parliamen-
tary systems with a well functioning opposition it is not only reasons
of patronage and coalition building that influence the creation of min-
istries. As well as the five classical portfolios most countries more or
less simultaneously created certain ministries for new policies, such as
Post and Telegraph, Colonies, Development and Environmental pro-
tection. This suggests that rational reasons lay behind the creation of
new offices in most cases. It does not mean, however, that party ideol-
ogy did not play a role. Ministries of Labour were mostly created when
social democrats and socialists entered the government. Centre parties
sometimes managed to create a special portfolio for the support of the
middle classes, mostly under more neutral labels. Sometimes certain
ministries were created that only continued for a short time (Art and
Sciences in France, Refugees in Germany, Women’s Affairs in many
countries). If the number of portfolios varied from 13 to 26, as in the
short-lived Fourth French Republic (1945–57), 15 there was little
confidence that the ministries were all contributing to efficient policy
making.
The head of state in most parliamentary systems has no veto against

the creation of offices and the nomination of ministers because a presi-
dential veto would represent an infringement of the government’s
competences, especially in Germany, which has created one of the
weakest presidential offices in history as a result of Germany’s trau-
matic experiences under the Weimar imperial president, Hindenburg.16
6.3 Ministers without portfolio
Rational reasons can be found for the creation of a ministry, but it is

less easy to see why there should be ministers without portfolio. They
normally lack an organisational basis and tend to be treated as second-
class ministers, unless their political weight within the most important
governing party puts them in a better position.
In early parliamentary systems ministers without portfolio served
parliamentary ‘linkage’ functions, especially in protecting the govern-
ment against attack from the opposition. 17 The moderate anarchist
Proudhon held that ministers without portfolio had ruined the July
monarchy in France (1830–48).18 For parliamentary purposes even on
the continent the British model of a lower executive rank such as par-
liamentary secretary of state has been imitated – in Germany since
1965. The grand coalition was able to distribute lavishly the new office
among the two parties. They also functioned as supervisors of the min-
isters of the coalition partner.
In preparliamentary systems when party government was still imper-
fect, ministers without portfolio served as a kind of advisor to the first
minister (Imperial Germany before 1918). In some parliamentary
systems ministerships without portfolio were allotted to elder states-
men. The latter also served as advisors to the younger ministers who
did all the work. In rare cases they acted as specialists for the govern-
ment. In Sweden they were even provided for in the constitution (until
1970, § 7). In early systems the office of minister without portfolio was
created for the prime minister in order to leave room for coordinative
work in the cabinet. But by far the most important function was
patronage. In Britain the more ceremonial offices sometimes had
important sounding names such as ‘lord privy seal’, ‘first secretary of
state’ or ‘chancellor of the Duchy of Lancaster’. As long as the prime
minister was recruited from the Lords, the leader of the house was
vested with a dignified office without bureaucratic obligations. 19
Though ministers without portfolio served important functions in the
inner circle of the cabinet they were never popular. When in 1956
Adenauer created four ministers without portfolios the leader of the

media office said ‘Mister Chancellor, a cabinet with four ministers with
special tasks without portfolio cannot be made popular among the public
since nobody in the population knows what they are doing.’20 Sometimes
such an office was awarded as a kind of compensation for an important
interest group. It was cheaper to nominate as minister without portfolio a
person who enjoyed the group’s confidence than to create a whole min-
istry as the pressure group demanded.21 Sometimes ministers without
portfolio served in special missions in the area of foreign policy
(Germany, Sweden); sometimes they acted as reserve personnel to replace
individual ministers who had resigned. When in 1951 three socialist min-
isters left the cabinet of de Gasperi in Italy, ministers without portfolio
took over in order to avoid a cabinet reshuffle. The professionalisation of
politics is linked to a profile in certain policy fields and this has strength-
ened the desire of the elites to serve as the head of a ministry.
6.4 Cabinet hierarchy and ministerial solidarity
Ministerial solidarity was originally linked to the equal status of all

those who served in a cabinet. But the proliferation of offices entailed
the imposition of a certain hierarchy. The five classical departments are
everywhere considered more important than the mere ‘technical
offices’, but nowhere on the continent has the hierarchy developed to
the extent that it has in the British cabinet. Sometimes certain minis-
ters have veto functions, for example the minister of finance in the
Federal Republic of Germany, and there is a tendency to combine
the Foreign Office with the vice chancellorship (Germany). In Britain
the term ‘corporate responsibility’ was developed to demonstrate that
certain ministers have a certain coresponsibility for the general policy
of the cabinet during times of crisis – as in Churchill’s cabinet during
the Second World War. Churchill declared that only ‘a few ministers
had the right to be beheaded on Tower Hill if Britain did not win the
war’. 22 The development of certain ‘overlords’ was, however, treated
with much suspicion by many commentators.
The relative weight of a department depends not only on the per-
sonal qualifications of its minister but also on its function in the
governmental system. Certain ministries have limited weight in the
hierarchy of cabinets:
• Some ministries are less political than technical and bureaucratic agen-
cies (Communications, ministries for certain branches of industry).
• Other departments were created because the classical ministries

became too big. Ministries of Domestic Affairs sometimes handled a
range of concerns from internal security to environmental protec-
tion, some of which were handed over to a specialised ministry.
• Certain departments have been created to please powerful interest
groups. Their heads are usually pressure group activists without any
real interest in general government policy.
• Some ministries have obviously been created to satisfy the demands
of a grand coalition. In the German Länder strange cabinet posts
sometimes appear for a couple of years and disappear with the coali-
tion, such as a single department for Women, Family, Advanced
education and the Arts (Baden-Württemberg 1992–96), which, as its
name suggests, combined policy fields with little coherence.
All these departments of secondary importance strengthened the hier-

archisation of cabinets. Parliamentary cabinet government, with its
moderate hierarchy, is somewhere in the middle of a scale ranging
from the collective government of the Swiss type, with no hierarchy,
to the US presidential system, where the cabinet lacks solidarity and
individuals are dependent on the president, who can hire and fire at
will. Because there is no parliamentary socialisation of secretaries of
state the cabinet has been called a ‘government of strangers’ because
they are called from various parts of the country and are united only
by the confidence of the president. 23 Among the parliamentary
regimes, prime ministerial systems such as that in Britain are fairly
monocratic. This is true even of the German chancellor system,
though the Basic Law tries to guarantee a certain harmony between
three principles: a strong position for the chancellor, a certain auton-
omy among the individual ministers and solidarity among ministerial
colleagues in the cabinet (Article 65). The degree of hierarchy in
Germany, however, has differed under various chancellors. Adenauer’s
cabinet lived under monocratic leadership, while under Brandt there
was a certain aim of equality among colleagues. Similar shifts between
an egalitarian and a hierarchical style have occurred in Finland. 24 This
is one of the reasons why attempting to explain a non-hierarchical
style by a high level of welfare and acceptance of the system by the
citizens is doomed to fail.25 The citizens of Switzerland are wealthy
and satisfied, but this is hardly the result of the type of governmental
organisation. The United States is said to have a hierarchical leader-
ship style, but this does not preclude a high degree of wealth and
satisfaction among the citizens.
Parliamentary government needs coordination in order to improve

cabinet solidarity. In some countries cabinet committees work to
coordinate the divergent interests of the various ministers. The more
hierarchical the cabinet the less that formal votes have to create a con-
sensus of the cabinet. In an interview Prime Minister Attlee boasted
that he never allowed votes: ‘You don’t take a vote. No, never. You
might take it on something like whether you meet at 6.30 or 7.30, I
suppose, but not on anything major.’ 26 The same cannot be said of
consociational democracies with a high degree of party fragmentation,
such as Finland, Ireland, the Netherlands, Norway, Italy and to a
certain extent Belgium and Austria.27 The mechanisms of disagreement
in many cases include the possibility of a minister who is in conflict
with a cabinet colleague appealing to the cabinet. This is more fre-
quent in Britain than in Germany, and more frequent still in certain
consociational democracies such as the Netherlands, Austria and
Norway.
6.5 The office of prime minister
The development of governments responsible to parliament needed a

coordinator and party government increased the need to create a first
minister. In absolutist systems suspicious monarchs avoided the
appointment of a first minister. Louis XIV, after Mazarin’s death, chose
not to nominate another first minister and demonstrated that he
himself was willing to make decisions.28 Ministers in preparliamentary
autocracies were individual advisors of the crown. Only the secretary of
the cabinet, who prepared the minutes of the cabinet gatherings,
sometimes developed into a quasi prime minister. In Prussia the politi-
cally most powerful minister, Hardenberg, mocked his secretary of the
cabinet, Carl Friedrich von Beyme: ‘He de facto is a Prime Minister and
if this is to continue he will get even officially this title.’29 Hardenberg
was wrong – he himself later served as president of the ministerial
council in Prussia. The first ministers in preparliamentary regimes were
completely the creatures of the monarch. It was not by chance that
monarchs on the continent frequently favoured persons from the
bourgeoisie or lower nobility as this served to avoid the higher aristo-
crats’ inclination towards insubordination and their tendency for
latent opposition or fronde.
Real prime ministerships could only develop in parliamentary
systems on the basis of party solidarity. In Britain this was the case
only after the second electoral reform of 1867. A further condition for
the development of a prime ministerial office was the growing com-

plexity of governmental business. Monarchs were no longer willing to
dig into the daily business of government, but were anxious to
demonstrate that they had the right to preside over cabinet meetings
whenever they chose so to do. In countries where the monarch had a
poor knowledge of languages – for example George I of England and
the first Bernadotte in Sweden (Carl XIV, Johan 1818–44) – the
monarch was more likely to leave the routine ministerial work to a
first minister.
Even in semipresidential systems the president – elected by popular
vote – sometimes left the prime minister to preside over the cabinet
(Weimar Republic, Article 55; Finland, Article 39; Iceland, Article 17).
In Finland the president only presides over matters that relate to his or
her competences and in the Weimar Republic the president was occa-
sionally invited to preside over the ministerial council.
Budding prime ministers had to fight on two fronts to gain recogni-
tion of their superior role in the cabinet: against the monarch and
against their ministerial colleagues, who frequently joined forces to
limit the influence of the prime minister. Monarchs usually defended
their right to nominate their ministers and did not leave this task
completely to the first minister. Bismarck was able to prevent too many
contacts between his secretaries of state and the crown until the end of
his career, when he complained about the disloyal behaviour of his
cabinet colleagues. 30 In the most autocratic system in the twentieth
century, Russia until 1917, cabinet solidarity against the monarch
never developed, according to a former first minister in exile.31 Vestiges
of this double loyalty towards the head of state and the prime minister
can be found in some semipresidential systems. De Gaulle, who
emphasised his domaine reservé, sometimes behaved like an American
president and summoned his favourite ministers without the knowl-
edge of the prime minister.32
The predominant position of the prime minister was often endan-
gered when he was less well-known than one of his colleagues, for
example Disraeli under Derby. Co-prime ministerships developed
when parliamentary support for the prime minister was weak, as in the
case of Baldwin and MacDonald when the prime minister was excluded
from his party. A critic mocked this cabinet: ‘Baldwin supplied both
the legions and the power that goes with the legions.’ 33 Early parlia-
mentary systems on the continent frequently developed a kind of
double leadership (France: Soult and Guizot; Italy: Zanardelli and
Giolitti, Cairoli and Zanardelli, Sonnino and Salandra). In difficult
times foreign ministers sometimes enjoyed greater continuity of office

than prime ministers, as was the case with Briand (France) and
Stresemann (Weimar Republic), who revelled in taking major decisions
after the resignation of their leader and knew full well that they would
serve in each new cabinet. The real leading figure in such cases was not
the president of the ministerial council. When Briand resigned in 1921,
Lloyd George sent a telegram announcing that he wanted to travel to
Paris to see the ‘President of the ministerial council’ ‘in case that there
is one’.34 After the Second World War grand coalitions sometimes
resulted in one of the ministers having greater prestige than the
nominal head of government (for example, Kiesinger in relation to
Brandt in 1966–69 in Germany).
The term prime minister has been accepted in the comparative liter-
ature though most countries have a special name for this top position,
ranging from Statsminister (Sweden) to chancellor (Germany) and
Taoiseach (Ireland). ‘President of the council’ was a widespread title in
French terminology until France, under the Fifth Republic, went over
to the British title of prime minister.
Even in Britain the term prime minister developed rather late.
Clarendon was one of the first to be dubbed ‘first minister’ but he con-
sidered that this title was ‘not English’: ‘under no other title or pre-
tence but of being First Minister (a Title so newly translated out of
French into English, that it was not enough understood to be liked),
and every man would detest it for the Burden it was attended with’. 35
Walpole was probably the first parliamentary prime minister but even
he called the term a ‘mock dignity’.36 Melbourne understood his posi-
tion as being primus inter pares, and only in the era of Disraeli and
Gladstone did the image of a modern prime minister develop. The title
appeared only in 1917 in law (the Chequers Estate Act) and it was not
until 1937 that the office of prime minister was fully constitutionalised
(Ministers of the Crown Act).37
In France after 1814, in spite of the imitation of many British institu-
tions the introduction of the office of president of the ministerial
council was opposed by most parliamentary groups.38 When powerful
leaders tried to secure this title King Louis-Philippe resisted. The latter is
reported to have said: ‘Why do you need a president of the council? Are
you not in agreement among the councillors?’ Every attempt to assem-
ble in the council without the king was vehemently opposed by the
latter.39 Conservative writers called the title ‘a ridiculous vezirat’, and
liberals complained that such an office would undermine the collective
responsibility of the ministers.40 Only at the beginning of the Third
French Republic did Dufaure receive the title ‘vice-president of the

council of ministers’ (1876). When the constitutional laws were passed
in 1875 a motion to legalise the title ‘president of the council of minis-
ters’ was voted down. ‘La République des Camarades’, with its cliques of
elites, stuck to the fiction of a council of peers. 41 In 1934, the title ‘min-
ister, charged with the presidency over the ministerial council’ was
chosen. Leftist heads of government tried to strengthen the office of
first minister, and eventually it came, without legal authorisation, to
the fore ‘like a mushroom’.42 The Fourth French Republic constitution-
alised the office. According to an official history of the office it was a
‘French invention which became an English institution’.43
This development was not unique to France. In Belgium, the oldest
parliamentary system on the continent (from 1831, or 1833 according
to some observers), the title was mentioned as early as 1831 but was
formalised only in 1918.44 In Italy – a parliamentary system from 1860
– the founder of the ‘United Kingdom’, Cavour, de facto had an equiva-
lent position to a British prime minister. After his death there were ups
and downs in recognition of the office but eventually the Republic of
Italy defined the office in detail (Article 92ff.). De facto the position
was, however, always important as long as strong personalities such as
Depretis, Crispi or Giolitti led the cabinet.45 In other systems the head
of government was sometimes privileged by special circumstances.
Norway was linked to Sweden by the union of two crowns. Therefore
the constitution included a prime minister from the outset because the
‘state minister’ – his official title – had important functions as the king
lived in another country.46 In Sweden the concept of government was
one of equal councillors. Originally ‘state minister’ was rather a formal
title with little political weight that was sometimes given to the foreign
minister but more frequently to the minister of justice. In 1876 a
reform of the office of leading minister was carried out. But because
of many technical Ministers without political standing the office
remained far from being an effective coordinator of governmental
work – though Sweden first consitutionalised the office.47
Parliamentarisation of the government allowed the function of
prime minister to develop. The Netherlands was parliamentarised at an
early date (1868), but the declaration of a permanent president of the
council was considered illegal by many lawyers and politicians.48 Party
government was more important than merely responsible government.
But party government was impeded by extreme fragmentation of the
bourgeois camp and extremely late acceptance of social democrats into
the government.
Even after the Second World War the idea did not die out that prime
ministerial government could only develop under a British-style
constitution and electoral system. Adenauer (Germany), de Gasperi
(Italy), Gerhardsen (Norway), Erlander (Sweden) and Ben Gurion
(Israel) proved the contrary: proportional representation was also con-
ducive to strong prime ministers with long periods in office. Prime
ministerial government was hailed by advocates of party government
and condemned as ‘popular dictatorship’ by conservative writers. 49
Clarification of the strength of British prime ministers in the light of
research is hardly appropriate. Time and again it has been shown that
even strong prime ministers suffer from a host of conflicting
pressures.50
The endless legal debates are forgotten. Comparative politics has
shown that legalisation of the prime ministerial office is of minor
importance and that other variables determine the strength of a head
of government, for example:
• The competences of the head of state compared with those of the

prime minister (see Chapter 5).
• The organisational basis of the prime ministerial office.
• The normal parliamentary support of the office holders.
• The homogeneity of the parties in a governing coalition.
• The personal leadership qualities of the incumbent.
6.6 The organisational basis of the prime ministerial office
Concomitant to the hierarchisation of the cabinet the prime minister

was liberated from ministerial routine. In the early days of British par-
liamentary government the office of first lord of the treasury gave the
prime minister the power of patronage. Later nominal offices with few
obligations, such as lord privy seal, were chosen, and in the twentieth
century the prime minister was liberated from bureaucratic work in a
ministerial department.51 In the oldest parliamentary regimes on the
continent, such as France, Belgium and Italy, prime ministers at first
preferred to head the Ministry of Domestic Affairs. One reason for this
was the need to control middle-level administrators such as ‘prefects’.52
However, with the growing importance of foreign policy some French
presidents of the ministerial council took charge of the foreign office
(Briand and Laval). 53 During periods when social democrats were in
power the prime minister sometimes took a portfolio for which the
party had struggled, such as minister of labour (Nygaardsvold in
Norway). Coalition research has systematically studied the distribution

of portfolios to ideological party families and shown that prime minis-
ters’ and other party leaders’ choice of ministry varies according to
party ideology.54
In early parliamentary regimes, when the prime minister was still
charged with a portfolio, he sometimes carried a triple burden because
of ‘cumulation of offices’ (Theux in Belgium in 1837, Crispi in Italy in
1889, Kekkonen in Finland in 1952). In most cases, however, this was
an emergency measure after the resignation of an important minister.55
As difficult as the development of a prime ministerial position was
the organisation of his office. When prime ministers combined the
function of head of government with leadership of a ministry (as
Adenauer did in Germany until 1955 and Fanfani did in Italy) this was
criticised as poor compensation for an effective prime minister’s
office.56 Even when an effective office was organised a ‘cabinet office
ethos’ was hard to develop because of the competition between jealous
incumbents of important ministries.57 The personal leadership qualities
of prime ministers and their ability to coordinate when there was inter-
nal fragmentation of the governing party or coalition proved to be as
important as the existence of an organisational structure for this work
of coordination.58
Even in a one-party government there was no guarantee of effective
leadership. Powerful British prime ministers frequently suffered set-
backs as a result of cabinet revolts, including Gladstone, Asquith, Lloyd
George, MacDonald and probably even Churchill if he had had the
chance to become head of government after 1945.59 There was a lot of
talk about the authoritarianism of the German postwar chancellorship.
Hardly had Adenauer stepped down when his successor, Ludwig
Erhard, was toppled by an internal revolt among his coalition. 60
Margaret Thatcher was accused of ‘elective dictatorship’ but her succes-
sor, John Major, was forced to muddle through like a head of govern-
ment in a fragmented multiparty system on the continent.
Bagehot discovered the Cabinet as an efficient part of the constitu-
tion. In the meantime it has been counted among the ‘dignified parts’
of the constitution.61 It has been said that prime ministers are becom-
ing increasingly like an American president.62 But similar to presiden-
tial government which sometimes suffers from a roll-back into
congressional government modern prime ministers are far from a
uniform basis of power. Party government is – contrary to the
American equivalent – the most important variable explaining the
effective power of a prime minister.
6.7 Coalition research in the light of rational-choice

approaches
When comparative political scientists became tired of individual his-

torical explanations, advocates of the rational-choice approaches began
to look for regularities. The influence of the head of state has normally
been neglected, though it can be considerable (see Chapter 5).
Politicians are not treated as individual actors in the quantitative
approach but as agents of their respective parties.63
This approach is fruitful in terms of quantifying the distribution of
portfolios according to ideological preferences. Recently, rational-
choice approaches have been combined with neo-institutional research
and actors who control the agenda ex ante have been included, such as
the head of state and his or her role in interparty consultations and the
obligations parties accept before elections (with reference to their
voters or to their potential coalition partners). Moreover, ex-post poss-
ibilities to veto the results of the negotiations of coalition builders have
been discovered (the votes of investiture involve the whole parlia-
ment). A seminal discovery was made: ‘comparative theorists of gov-
ernment formation are only beginning to appreciate the importance of
institutional and other constraints on bargaining. And this lesson is
critical. It is not just that adding institutions makes our theories richer
and more realistic; it changes them completely.’64
There are two types of coalition theory:
• Numerical theory was developed by William Riker and starts from a

zero-sum game. All the actors try to maximise their benefits and are
rational insofar as they have perfect information on the rules and
strategies of the game.65 Minimum winning coalitions are predicted
since the actors want to share the benefits only with a minimal
number of coactors. Actors are power-oriented and policy-blind. In
this predominantly American perspective ideologies do not play a
major role.
• Policy-oriented theories are less interested in the conquest of power
and more in the implementation of policies. Minimal winning
coalitions in this model are parties that hold a kin position on an
ordinal policy scale. 66 In a ‘normal coalition’ there should be no
‘ideological holes’ – an assumption that has frequently proved to be
wrong in multiparty systems with grand coalitions. Similar policy
concepts among the coalition partners lead – according to the
Axelrod model – to the most stable governments.
The logic of both approaches can be combined when the inclination of

parties to ‘rent’ certain offices is included in the analysis. The ‘colonis-
ation’ of portfolios is hardly interesting in one-party systems unless
internal factions are chosen as the focus. But usually the Westminster
type of parliamentary government is not included in quantitative
studies. On the continent certain regularities have been demonstrated
– as might be expected:
• Conservative and liberal parties are more multifunctional in govern-

ments than other groups and prefer classical portfolios such as
Foreign Policy, Domestic Affairs and the Ministry of Justice.
• Liberals also have a preference for Education.
• Social democrats insist on portfolios for Labour and Social Security.
• Christian democrats concentrate on economic affairs and social
policy.
These findings do not ignore changes in preference over time. The

German liberals were the first to insist on environmental protection,
but it was not until the Green Party entered the scene that a special
ministry was cut out of the huge Department of Domestic Affairs.
Social democrats originally detested the ‘repressive’ Home Office, but
later – in cooperation with the police trade union – were rather effec-
tive in promoting law and order policies via their minister of domestic
affairs and even the minister of defence. In the Weimar Republic the
name Gustav Noske became synonymous with such changes of mind,
and this was used by left-wingers to demonstrate the ‘treason of the
social democrats’.
The approach of studying parties as office-seekers with policy prefer-
ences has brought satisfying results. Quantitative research has been
able to prove that ministries – apart from during the Fourth French
Republic – are distributed roughly in proportion to the seats held by
the parties in parliament. Small parties have a slight advantage (the
smaller religious parties and the liberals). Socialists and social demo-
crats in many continental countries are the largest groups. They nor-
mally receive the lion’s share and can afford to renounce the precise
numerical share to which they are entitled according to the electoral
results. Efforts to stabilise a forthcoming government can be more
important than the shortsighted advantage of maximising portfolios.
The coalition building between social democrats and the Green Party
in Germany in 1998 is a good example of this shift in rationale.
Statistical studies tend to underrate the relative weight of a ministry in
the cabinet hierarchy. This weight is not the same for all the parties
involved, as the ideological policy preferences have shown.
Some portfolios can hardly be weighted as they are tailored ad hoc
according to the proportional distribution of parties, interest groups
and genders. Statistical studies normally overlook the distribution of
posts below the ministerial level. Some presidencies of parastatal offices
are more important than appointment to a ministry. Coalition build-
ing also involves consideration of the possibility of patronage, as in the
case of the coalition between the SPD and the Green Party in 1998. The
office of a parliamentary speaker and the forthcoming vacancy of
the federal presidency were included in the calculations of the parties
and groups.
Less effective than forecasting the numerical distribution of min-
istries is the prognostic power of coalition theory in evaluating the dis-
tribution of offices according to the preferences of the parties involved
in government building. The predictive power of coalition theory is
hardly above 50 per cent. A high correspondence between party ideol-
ogy and portfolio was found for the Socialist Parties in Israel and
Luxembourg, where they have been the governing coalitions for most
of the time. In other countries, such as Iceland and Ireland, the corre-
spondence is, however, rather weak. In these countries the equivalent
parties have benefited from a bonus for small parties. 67
Research on parties has revealed that the party systems in frag-
mented countries are rather complex in structure and that the poles as
well as the centre point are not always located at the same place on the
scale. There are aspects of Weltanschauung and religion, of economic
views and national credos that are usually incongruent and create
various shifting majorities. This problem has been solved by construct-
ing a typology of coalition systems in terms of multidimensional
policy space (Table 6.1). There are four main groups:
• Bipolar systems (Germany and Austria).

• One-dimensional, unipolar, centre-oriented systems (Luxembourg).
• Unipolar off-centre systems (Norway and Sweden).
• Multipolar systems (Belgium, Finland, Italy and the Netherlands).
The static picture presented in Table 6.1 is misleading in that it over-

looks the fact that some highly fragmented systems, such as Belgium,
Denmark or Italy after 1945, have occasionally shifted from one type
of coalition to the other. After 1994 Italy seemed to develop in a
bipolar way and with the end of Prodi’s government in 1998 it looked
166
Table 6.1 Typology of coalition systems in terms of multidimensional policy space
Type of system Unidimensional median Multidimensional core
Bipolar Austria (typically ÖVP median) –

Germany (typically FDP median) –
Unipolar Luxembourg (typically CSV median) Ireland (no core)
(centre)
Unipolar Norway (labour or liberal median) Denmark (no core: cycle set generated by SD against
(off-centre) right-wing parties)
Sweden (SD or centre median) Iceland (no core: cycle set generated by three parties)
Multipolar Finland (SD or centre median) Italy (DC core)
Netherlands (KVP or CDA core)
Belgium (1981 on) (PSC median) Belgium (1946–61, no core: cycle set generated by PSC, PSB, PRL)
Belgium (1961–81, PSC core)
Source: Michael Laver and Norman Shofield, Multiparty Government: The Politics of Coalition in Europe (Oxford University Press, 1991), p. 136.
rather similar to the old regime. There was no sign of the ‘second
republic’ hailed by Berlusconi’s coalition in 1994. Belgium, on the
other hand, showed that ethnic and regional conflicts can disrupt the
traditional patterns of coalition building in a consociational parlia-
mentary democracy. Multipolar systems seem to have the most unsta-
ble government – to nobody’s surprise. The duration of government in
this model ranges from 27 months (Netherlands) to 13 months (Italy).
The most stable government is to be found in centred unipolar systems
(Luxembourg 45 months, Ireland 39 months), followed by the
German-speaking countries (Austria 38 months, Germany 37 months).
The differences within these subgroups are explained individually by
institutional variables.
Party ideologies, according to quantitative studies, have to be kept
constant over time. Occasionally this assumption has proved to be
incorrect. Austria’s Liberal Party under Haider drifted to the right of the
party spectrum. The Christian democrats (ÖVP) could be treated as the
‘median’. All constitutional parties tend to move towards the median
when extremist polarisation shifts the balance among the established
parties.
Coalition theories are problematic because of the small number of
cases. Among the more than 20 parliamentary OECD countries with
some continuity, the Westminster-type systems can only be included
when they have coalition governments. Australia has had 1.8 parties
in government with 58.5 per cent of parliamentary support – a
deviant case in the Anglo-Saxon family. Canada has stuck to the
British no-coalition model. The price, however, has been high in
terms of frequent minority governments (Table 6.3). Ireland seems to
have followed the Westminster model, but only rarely, in the 1960s,
have one-party governments been possible. In a comparative perspec-
tive Ireland corresponds best to the theory of minimal winning coali-
tions: 1.6 parties per coalition with 51.2 per cent of parliamentary
support.
What are normal coalitions? According to one calculation more than
two thirds of cabinets (68 per cent) can be called ‘minimal winning
coalitions’. Luxembourg was counted with 95 per cent among them
though it is characterised by oversized coalitions, which distorts the
whole balance. 68 According to my own calculations – by decade and
120 parliamentary periods – almost 50 per cent of coalitions are not
normal because they are over- or undersized (Figure 6.1). Most
Westminster-type systems are atypical. The US presidential system
cannot be counted. After the mid-term elections presidents are
frequently in a minority position, but this has no impact on the dur-

ation of the presidential term of office.
The new democracies in Southern Europe – not to speak of Eastern
Europe – only consolidated in the 1990s in terms of producing normal
coalitions. Ireland and Germany usually seem to be normal, and two
major parties had to select one small party as a possible coalition
partner over a long period in Germany (from 1961–83).
The definition of a normal coalition is oriented towards the
‘minimum-size principle’. The existing studies show that this crite-
rion applies only to 35–50 per cent of cases. Minimum-size coali-
tions are considered more stable than others, in spite of deviations
in small European democracies such as Luxembourg. Predictions are
limited by further caveats: stable governments can be expected from
a minimum-size coalition only if factionalism remains limited. 69
Such caveats further reduce the prognostic value of coalition
theories.
Coalition theories are less interested in the detailed reality of their
assumptions than in the accuracy of their predictions. 70 Empirical
research could live with this credo if the accuracy of the predictions
was convincing, but as an Italian study has demonstrated 14 coalitions
have functioned according to the rules of the theory but 13 others
have not – not a very impressive result.71 Riker’s rules have been tested
in the case of Denmark and Israel – also with moderate success.72 These
rules have proved partially valid for Denmark and Iceland, but not for
the other three Scandinavian countries. 73 According to the usual
Popper criteria for falsification this does not mean that a theory is
completely out of consideration. The next step is not to disgard certain
hypotheses but rather to attempt to improve their precision.
Neoinstitutionalists have attempted this. The danger is that one-party
governments are considered preferable in a normative way because
they endure for 55 months on average, whereas the mortality of multi-
party coalitions has been high (lasting only 25 months on average
between 1919 and 1974). 74 Of Laver and Schofield’s sample, 35 per
cent were minimal winning coalitions. Bogdanor, Pridham, von Beyme
and others see this as a blatant failure of coalition theory, while others
consider the result to be ‘respectable’.75
Not only are the judgements on minimal-size coalitions on shaky
ground in Europe, so too are the assessments of governmental stability.
Most studies have concentrated on the period 1946–80 and excluded
the uncertain times between the two world wars, which seems reason-
able. The findings were that one-party governments lasted 35 months,
coalitions only 19.7 months. 76 In general the predictive capacity of

coalition theories declined because many marginal conditions changed
considerably over the time of coalition research:
• Parties eroded in terms of organisation and compensated for this by

responsiveness to their voters. Coalition building thus has to
consider new criteria for rational behavior.
• New cleavages sprang up and falsified the assumption of a decline in
the impact of party ideology. The ecological movement has shown
this.
• Constitutional reform in some countries – for example Sweden and
Israel – affected the behaviour of coalition builders.
• The reasons for dissolution of government have been excluded by
almost all the competing hypotheses (see Chapter 5). These reasons
have changed and influenced the criteria of rationality among the
party leaders. Parliamentary reasons for government disintegration
declined, while democratic reasons for government dissolution by
elections increased in importance and affected the results of the
logic of government formation.
• New extremist groups that were not considered acceptable for coali-
tion building have changed the scene (ethnic radicals in Belgium
and neofascists in Italy).
6.8 Oversized coalitions
There are two types of coalition that cause problems for coalition
theories: oversized coalitions; and undersized coalitions and one-party
minority governments. Coalitional behaviour changes with the number
of parties involved. The average number of coalition parties per cabinet
in most countries is about two. Strong deviations are found in Belgium
(4.3 in 1970–94), Italy (4 in 1980–94) and the Netherlands (4.3 in the
1970s). Only Italy, with about four parties, has not had considerably
oversized coalitions (54.8 per cent of parliamentary support for the
average government). In Belgium and the Netherlands, on the other
hand, the large number of coalition parties has led to oversized
coalitions. Luxembourg, with two party coalitions, is on top with
60–75 per cent of parliamentary support. This endorses the hypothesis
that the number of parties is less important than the size of the parties
eligible for coalition. Until 1994 Italy had a certain number of small
parties available for various coalitions, for example, the Republicans,
social democrats and liberals.
Grand coalitions of two large parties, as in Luxembourg and Austria,

are inevitably oversized. Moreover, the tradition of consociationalism
is more important than the number and size of parties considered as
koalitionsfähig (acceptable for coalitions). In an extreme case such as
Austria, where the liberals are no longer acceptable to the two major
parties, grand coalitions are hugely oversized, but are nevertheless the
only feasible minimum-sized coalition.77
The decline of hegemonic parties (in Israel, Italy, India, Japan and to
a certain extent Sweden) has also changed coalition behaviour. A
purely numerical theory can hardly calculate the irrational motive of
revenge against a former hegemonic party – which has been fairly
obvious in Italy since 1994 in the treatment of the Christian demo-
crats. Only in Sweden has the decline of the social democrats not
caused huge fluctuations in parliamentary support for the government
because even when the SAP was at its strongest (the 1950s) it was
forced to participate in coalitions or minority governments. In Norway
the one-party rule of the social democrats in the 1940s and 1950s was
the only period in which minority governments were not a permanent
feature of the country (Table 6.2).
Oversized coalitions have prevailed in times of crisis and consolida-
tion in new democracies, with the exception of Spain. In Greece and
Portugal oversized coalitions have been frequent. A hegemonic group
that leads the transformation is often weakened after some years, as
with the UCD in Spain and the forum-type parties in Eastern Europe.
Eastern Europe in the 1990s was a deviant case, however, because the
group that preferred the old regime – the post-communists – remained
strong and sometimes had a majority, even though they had only par-
tially internalised the new democratic rules (in 1990: Bulgaria 47.1 per
cent, Romania 66.3 per cent, Albania 56.1 per cent). The majority
enjoyed by most of these was eventually lost, but the post-communists
remained a powerful group. In other new democracies, disappointment
with the market economy caused a return to favour of the post-com-
munists (Lithuania in 1992, Poland in 1993, Hungary in 1995). The
elites in the peaceful revolutionary groups of the forum type were het-
erogeneous coalitions that quickly disintegrated (Poland, the Czech
Republic and Hungary).78 The assessment of oversized coalitions faces a
predicament. If governmental stability is the main criterion of assess-
ment they are highly desirable. Countries with frequent oversized
coalitions, such as Austria and Luxembourg, and to a lesser extent
Belgium and the Netherlands, have a considerable longevity of govern-
ment (Figure 6.1).
Table 6.2 Parliamentary basis of cabinets, 1945–94
Number of Number of parties

governments in government and
parliamentary support,
1945–94 (%) 1940s 1950s 1960s 1970s 1980–94
Australia 27 1.8 2.3 2.0 1.8 1.0 2.0
58.5 61.7 58.6 60.0 59.7 56.1
Austria 19 1.8 2.3 2.0 1.8 1.0 2.0
75.8 95.0 92.9 84.8 50.7 67.0
Belgium 32 3.1 2.2 1.3 2.0 4.3 4.3
61.6 57.0 52.2 67.7 60.6 63.6
Britain 19 1.0 1.0 1.0 1.0 2.0 1.0
Canada 20 1.0 1.0 1.0 1.0 1.0 1.0
55.1 58.6 61.8 50.0 47.6 58.2
Denmark 30 2.0 1.0 1.7 2.0 1.1 3.0
40.9 35.8 43.0 48.5 36.1 39.3
Finland 42 2.9 3.3 2.5 3.0 2.9 3.7
56.2 64.8 49.4 58.4 58.4 60.2
France 47 4.1 4.5 5.5 2.6 3.4 2.6
59.0 64.0 55.0 66.9 59.3 56.7
Germany 18 2.2 3.0 3.0 2.0 2.0 2.0
58.3 51.7 63.1 64.9 53.5 55.1
Greece 41 1.1 2.0 1.1 0.6 1.0 1.4
62.7 74.6 52.9 61.0 73.8 61.9
54.5 61.4 53.5 55.3 50.7 58.3
Ireland 21 1.6 3.0 1.5 1.0 1.3 1.6
51.2 50.4 50.9 50.2 54.8 49.5
Italy 48 2.8 3.8 1.8 1.9 2.7 4.0
52.5 69.4 48.9 48.4 50.1 54.8
Japan 38 1.3 1.2 1.0 1.0 1.0 2.0
51.9 42.9 48.3 60.4 52.6 53.7
Luxembourg 13 2.0 2.0 2.0 2.0 2.0 2.0
68.2 65.4 74.6 67.0 60.4 64.6
New Zealand 22 1.0 1.0 1.0 1.0 1.0 1.0
57.4 54.6 56.6 55.6 59.7 58.4
Netherlands 20 3.3 3.0 3.8 3.3 4.3 2.3
61.0 68.5 70.0 58.0 55.4 58.3
Norway 24 1.7 1.0 1.0 2.8 1.4 1.8
46.9 53.7 52.8 50.4 41.9 43.3
Portugal 15 1.6 – – – 1.3 2.0
60.0 70.3 54.1
Spain 7 1.0 – – – 1.0 1.0
49.9 47.6 50.8
Sweden 24 1.5 1.0 1.6 1.0 1.8 1.6
47.3 49.6 53.8 51.2 40.8 43.9
USA 15 1.0 1.0 1.0 1.0 1.0 1.0
49.6 53.5 44.7 56.2 47.6 45.2
Source: Calculated from data in Jan–Erik Lane et al., Political Data Handbook OECD Countries,
2nd edn (Oxford University Press, 1997), p. 123ff.
172
Figure 6.1 Party fragmentation and duration of governments, 1946–94
Number of parties in coalition

Above average (above 2.5) Average (1.5–2.5) Below average (up to 1.5)
Duration Above-average (more Netherlands Australia Canada
of than 30 months Germany Britain
government Ireland
Luxembourg
Austria
Above-average Australia New Zealand
(24–29 months) Sweden
below-average (less Belgium Denmark
than 24 months) Finland Norway
France
Italy
Source: Based on data in Political Data Handbook Jan Erik Lane et al., 1997. Oxford University Press, 2nd edn.
6.9 Undersized coalitions and minority governments
There are two types of minority government:
• Minority government of one party, usually the strongest group after

an unsuccessful attempt to form a coalition and in application of
the plurality principle to government formation (see Chapter 5).
• Minority coalition of several parties.
The second variety was treated with less suspicion during the democra-
tisation of parliament. If several parties cooperate there is a certain
guarantee that the head of state and the party leaders will try to find a
fair solution.
Only since the Second World War have minority governments been
liberated from the suspicion of launching a kind of coup against the
democratic rules of government building. In early parliamentary
systems minority governments frequently comprised combative cabi-
nets relying exclusively on the confidence of the head of state (see
Chapter 6). Chateaubriand – the first conservative of intellectual stand-
ing on the continent to advocate that government should be account-
able to parliament – criticised minority governments as a ‘côterie
driven by a faction’. 79 He also outlined the necessary criteria for the
parliamentary majority body: it has to be compact and show some
continuity. Majority government is not given when a ministry collects
heterogeneous majorities at random for different laws. The majority by
corruption – which prevailed under Walpole in England, under Guizot
in France and under Depretis’ ‘Trasformismo model’ in Italy – was not a
legitimate form of majority government. To test the stability of the
majority, from time to time parliaments have resorted to a vote of
censure. But it has been shown that this was not done in many pre-
and post-parliamentary constitutional regimes so that minority
governments could not be counted in a quantitative way.
In Britain there were no minority governments before 1832, the year
of the first great parliamentary reform. Since then there have been
about 11 minority governments, mostly in the period between the two
parliamentary reforms (1832–1867) when the parliamentary system
was not functioning normally. Those minority governments (under
Derby in 1852 and 1858–59, Russell in 1846–52 and Derby in 1866–68)
were tolerated because both major parties had problems with party dis-
cipline. Many parliamentarians did not accept the authority of the
whips and did not even join in the deliberations of their parliamentary
group. Under these conditions the custom developed that a govern-

ment did not resign after a parliamentary defeat. In many countries –
with some exceptions in Scandinavia – minority governments were an
indication that the party system was in crisis. In Britain there was
another period of minority rule between the two world wars, when the
Labour Party began to take the place of the liberals as a major force
(1910–15, 1924, 1929–31), but the Labour minority cabinets under
MacDonald were only able to exist with Liberal Party toleration. 80 The
Anglo-Saxon tolerance for occasional parliamentary defeat made
minority government more possible than in France under the Third
Republic (1871–1940). Other Westminster-type systems followed the
British example. A minority government under Deakin in Australia
ignored parliamentary defeat and was able to stay in power for almost
a decade (1901–9).81
In Scandinavia, minority governments were the rule rather than the
exception. In Norway in 1888 and later, minority governments were
preferred to shaky coalitions. Some minority governments in
Scandinavia proved to be more stable than coalitions, and they were
more effective because of their homogeneity.82 In Sweden the existence
of minority governments was supported by the absence of a vote of no-
confidence in parliamentary statutes (Chapter 4). Tingsten and others
warned against introducing this ‘British instrument’ because it might
destabilise governments without there being a majority to replace
them. This ‘negative parliamentarism’ was most common in Denmark.
Coalition bargaining has often less to do with finding a majority than
exploring the circumstances in which the other parties would tolerate a
minority government by the strongest party according to the plurality
principle. There were durable cooperative ventures between parties –
such as between the radicals and the social democrats – but when a
formal coalition was impossible they instead formed a ‘winning coali-
tion’. This model had the advantage that the degree of symbiosis was
limited. The junior partner sometimes voted against the government
but supported it when its existence was in danger. 83 From 1901–70 in
Denmark, minority governments were in power about 50 per cent of
the time (1909–18, 1920–28, 1945–57 and 1964–68) and even since
then minority government has been part of a stable political culture. In
Finland from 1919–51 there were nine minority governments, eight
caretaker governments, seven majority coalitions and only five one-
party governments. The tendency to accept caretaker governments
and cabinets without parties (‘ministries of expedition’) under
Cajander facilitated minority rule. In the 1950s and 1960s many
Finnish governments were caretaker governments, and quite often

minority ones to boot (under Tuomioja in 1953–54, Sukselainen in
1957, von Fieandt in 1957–58, Kuuskoski in 1958, Sukselainen in
1959–61, Lehto in 1963–64 and Virolainen in 1964–66).
Institutional variables (lack of the ability to dissolve parliament in
Norway, lack of votes of no-confidence in Sweden before parliamen-
tarisation, semiparliamentarism in Finland) explain the special cases.
But institutionally Denmark barely deviates from the average parlia-
mentary system. Only the existence of a tolerant political culture can
explain why permanent minority governments have been accepted,
whereas the same phenomenon in the Weimar Republic was seen by
crisis mongers as the first sign of the failure of the parliamentary
system. The Netherlands, in another tradition of consociationalism,
has also developed a special form of minority government. Caretaker
governments (under Cort van der Linden in 1913, a government
without party) have been frequent and half-parliamentary govern-
ments without formal commitment of the parties to their party
members who served in the government are hard to differentiate from
the minority governments in other systems.
The parliamentary doctrine on the continent has frequently discrimi-
nated against minority governments. In a moderate form this was done
by liberals who believed in a majority system. In a more cynical way it
was done by conservative opponents to the parliamentary system, from
Carl Schmitt to Rudolf Kjellén, and the many Italian writers before the
First World War who took the frequency of minority governments as
proof that the bourgeois parliamentary system lacked vitality and
efficiency. Coalition theory after 1945, on a solid democratic ground,
was still discriminating against minority governments because the rules
of the Riker school did not apply in Europe. Denmark’s party system
after Glistrup’s progressive party had entered the scene in 1973 was so
fragmented that from 1980 to 1994 even three coalition parties, on
average, could only gather about 40 per cent of the parliamentary votes
(Table 6.2). In Norway, with the decline of the social democrats after
Gerhardsen, coalitions of three parties commanded only a small major-
ity in parliament (50.4 per cent). Bourgeois coalitions under Lyng (four
parties), Borten (four parties), Korvald (three parties), Willoch (three
parties) and Syse (three parties) were short-lived. The weakness of both
camps led to a pendulum swing of alternating governments without a
solid majority basis. Of the new democracies Greece was the only excep-
tion: Portugal had many minority governments (five out of 13 from
1976–96) and Spain (six out of eight governments), both in the era of
the UCD as well as under González and his PSOE when its majority
withered after 1989. A recent study looked at 356 governments in the
OECD countries and found that more than one third (35.1 per cent)
were minority governments. In some countries they were a temporary
phenomenon. In others (Canada, Italy, Ireland and France) they
amounted to 40 per cent of the cabinets (Table 6.3).
As long as minority governments are coalitions they can be included
in coalition studies. But the toleration of one-party minority govern-
ments by other parties is more difficult to assess because their motives
do not follow the office-seeking model and only partly fit into the
policy-orientation model because the ideological policy preferences of
such parties can hardly be maximised under conditions of minority
government. There are other rational criteria for a policy of toleration,
such as to avoid a crisis and to avoid damaging the prestige of parlia-
ment by long delays in coalition building. Some minority coalitions
are facilitated by the ‘gravitation principle’ in government building
(see Chapter 5). One study of 18 minority coalitions found that 13
included a central party. This is most frequently the case in Denmark
and Finland. 84 In systems with a central party that operates on the
basis of the principle of gravitation, the majority and minority systems
function in a similar way so the differences are slight.
Table 6.3 Minority governments, 1945–87 (per cent)
Country Minority governments Parliamentary basis
Belgium 13 61.4
Britain 11 53.4
Canada 47 54.3
Denmark 88 40.2
Finland 28 55.2
France (4th Republic) 40 51.0
Ireland 41 50.3
Iceland 21 52.7
Israel 10 63.5
Italy 42 51.7
Netherlands 16 61.2
Norway 57 47.5
Portugal 12 61.8
Spain 60 50.6
Sweden 57 47.1
Source: Kaare Strøm, Minority Government and Majority Rule (Cambridge University Press,
1990), p. 58.
Despite these insights, minority governments are still not popular

with comparative researchers because cabinet stability is a main value
in most studies and minority governments have a shorter duration
than majority cabinets. In countries with frequent minority govern-
ments (Finland, Italy, Denmark and Norway), periods of governmental
stability tend to last about two years. Sweden (more than two years)
and Canada (more than two-and-a-half years) fare slightly better. The
correlation of minority government with unstable cabinets therefore
has to be reduced to chronic cases (Denmark and Norway).
Short duration of government is frequently equated with inefficient
government. Researchers have posed the question – but rarely answered
it.85 There is no unanimity on how to measure efficiency – number of
laws passed, government longevity or the improvement of social and
economic indicators in the lifetime of a government? The latter crite-
rion is preferable, but all measures of efficiency are illusionary in
systems where the average life of a cabinet is less than two years. Even
without comparative studies we can see that the Scandinavian parlia-
mentary systems, with frequent minority governments, are hardly less
efficient than other systems. Otherwise these countries would not be at
the top of the ladder in terms of welfare and liberal lifestyle. These
achievements have not come about by accident, rather they are the
result of intense parliamentary combat. In spite of this, minority gov-
ernments have been seen as second best and fragmented systems have
been recommended to return to the rules of a minimum winning coali-
tion at the earliest opportunity.86
In many countries the constitution seeks to prevent minority gov-
ernments, especially in the case of Germany after the Weimar experi-
ence. Minority government is possible only after two attempts to find a
majority for the chancellor and even then the federal president can
only gain room for manoeuvre in cabinet formation by opting to dis-
solve parliament. In other systems minority governments are accepted
on condition that they are not antiparliamentary and are directed by
parliamentarians – which has sometimes not been the case in Sweden
and Finland.87 The latter criterion is too severe – the governments of de
Geer and von Sydow in Sweden and Cort van der Linden in the
Netherlands presented no danger to their respective countries.
The rise to hegemony of the workers’ parties in Scandinavia has been
explained by the fact that the electors became tired of permanent crises
during minority governments. Allegedly the latter were not able to
solve major problems. According to one French parliamentarian: ‘si le
ministère ne s’en va pas, c’est le gouvernement qui s’en va’ (if the
cabinet does not leave, it is the government which disappears).88 If this

hypothesis about Scandinavian electoral psychology is correct, why
have Danish voters been tolerant of minority government and
strengthened their support of the social democrats, and why in all the
Scandinavian countries has this tendency withered since the 1980s?
6.10 The dissolution of government by parliamentary vote
Cabinet termination and survival have preoccupied political scientists

less than cabinet formation. One of the reasons for this may be that
rational choice methods are less applicable in this field. Nevertheless
probability hypotheses on government termination have been sug-
gested.89 Again most of the statistical studies cover only the years after
the Second World War, which is quite understandable because in
earlier periods there were more crises and fewer stable parliamentary
systems. Limiting the study to a short period, however, obscures to the
extent to which the reasons for the dissolution of government have
changed, thereby also affecting the rules of cabinet formation. In the
development of parliamentary government the parliamentary reason
for dissolution (the vote of no-confidence) stands at the centre. In
democratised parliamentary systems it is in a minority position.
The importance of the vote of no-confidence is not the same in all
parliamentary systems:
• In the British model, a formal vote of censure can be moved after

the debate that follows the royal address at the opening of the par-
liamentary session. In Britain the practice of interpellation with the
threat of a motion of no-confidence has not developed.
• The French ‘simple or motivated motion’ (ordre de jour, ordine del
giorno) is prevalent in many continental countries.
• Postwar systems have rationalised and restricted the procedure for
votes of censure (see Chapter 3) as the British procedure proved
unsuitable under the conditions of diffuse party cleavages in conti-
nental systems.
Originally the vote of censure in Britain took the form of a petition. In

1791 parliamentary requests for ministers to be toppled were expressed
in a very humble way: ‘that they [the ministers] may be no longer able
to deceive Your Majesty … that you will be pleased to remove John
Somers, Edward Earl of Oxford and Charles Lord Halifax from your
Council and Presence for ever’. 90 The vote of censure has been traced
back to the ‘Grand Remonstrance’ of 1641, when the ‘Long Parliament’

criticised the councillors of King Charles I.91 Robert Walpole is consid-
ered as the first prime minister to resign deliberately after a vote of
censure. The opposition declared that they did not want to annihilate
the person of Walpole, only his power. This precedent was not taken as
an obligation for all prime ministers to resign as long as they retained
the confidence of the crown. Even Walpole was not toppled by a single
vote but by a long crisis in his relation with the parliamentary majority.
Peel’s resignation in 1835 was the last case in which just a few hostile
votes caused the end of a government.92 In 1868 Disraeli created a new
precedent – after the dissolution of parliament he lost the subsequent
election and resigned without waiting for the vote of the parliament. In
1923 a vote of censure against Baldwin was the last example of a pre-
dominantly parliamentary crisis leading to the demise of a government.
British prime ministers had to fight for their position only in the
event of a formal motion of censure. French presidents of the minister-
ial council, however, were permanently under threat from an ordre du
jour and looked at the British customs with envy.93 Nevertheless many
of them endangered the existence of the government by abusing ques-
tions of confidence and overreacting to hostile votes by a majority who
had no intention of trying to topple the government.
Belgium originally followed the British example and tried to ignore
hostile votes. When the first government was toppled by a parliamen-
tary majority (Theux in 1840) the resigning prime minister pretended
that the reason was not a hostile vote but a king’s decree that had been
issued earlier. 94 There then followed the problematic pretext of a
conflict with the monarch in order to avoid a vote of censure. Further
cases (for example Rogier 1864) established the obligation to resign
after a vote of no-confidence. But on the whole it played a minor role
as in the second half of the nineteenth century the majorities in an
almost two-party system were relatively clear.
In the Kingdom of Italy the formal vote of censure was less well-
established and the country instead followed the French model of inter-
pellation. Many prime ministers – even the founder of the system,
Cavour – showed a certain cowardice in the face of their parliamentary
enemies and resigned even before a vote of censure could be introduced.
Parliamentary reasons for government termination include the
following:
• Refusal to accept a government in the debate following the address,

which was a kind of early equivalent of formal investiture.
• Refusal to accept the state budget of a government.

• Impeachment, culminating in a vote of censure (see Chapter 2).
• A hostile vote provoked by the prime minister linking a vote on a
material question or a bill with a question of confidence to decide
the fate of the government,
• A hostile vote on an important matter without a formal question of
confidence.
The formal vote of censure was unpopular on the continent. Even

Constant – who has frequently been hailed as the father of the theory
of parliamentary government in Europe – considered votes of censure
as a kind of destructive revenge. 95 Continental Liberals such as
Laboulaye tried in vain to convince the people that a vote of censure
could be a normal and undramatic event because it only meant that
the chamber and the ministers had different views. 96 Even conserva-
tives such as Heinrich von Treitschke criticised ‘bureaucratic bias’ to
discriminate votes of censure.97 Clemenceau was right in mentioning
in a parliamentary debate in 1879 that parliamentary votes are only as
significant as the significance attributed to them by parliamentary
convention.
The real meaning of a vote, however, was in some cases doubtful.
There was no formalised reading of a motion, which could vary from a
formal declaration of no-confidence to a rather vague criticism of gov-
ernment policy without mentioning the expectations of the hostile
majority. In the Netherlands, with its loose relations between parties
and government, weak formulations of censure were common, such as
‘lacking confidence’. Italian prime ministers in the nineteenth century
were skillful in interpreting hostile votes as ‘neither explicit confidence
nor explicit censure’.98 The question of confidence always contained an
element of psychological blackmail because deputies had to accept bills
if they wanted to avoid a cabinet crisis. Sometimes the element of
blackmail was reinforced by seeking the homogeneous vote of the
coalition parties, raising a question of confidence in the second
chamber when this was not required by the constitution, or demand-
ing a qualified majority for certain decisions.
The most absurd use of the question of confidence has been made in
the Federal Republic of Germany. Twice (in 1972 and 1982) the ques-
tion of confidence was used contrary to the intentions of the founding
fathers and mothers of the Basic Law. The chancellors in question had
to ask members of their own coalition to abstain in order to open the
road to the dissolution of parliament. In both cases they did not ask for
a vote of confidence but rather for the withholding of confidence. In

the second case the Constitutional Court had to make a judgement on
this procedure, but it saw no reason to declare it unconstitutional. The
most problematic variation was the resignation of government after a
normal hostile vote. In great parts of the constitutional literature this is
assessed as a ‘pathological phenomenon’ because it significantly con-
tributed to government instability in the French Third and Fourth
Republics.99 In Britain too the authorities did not accept an automatic
duty to resign.100 The Republic of Italy (Article 94.3) tried to get rid of
the consequences of this French sensitivity towards hostile votes.
Quantitative evidence shows that the parliamentary reasons for gov-
ernment termination are declining. In the oldest parliamentary
systems, those of Britain and Belgium, between 1832 and 1914 one
third of governments (17 out of 50) were toppled by parliamentary
votes. For the period 1884 to 1914 several new parliamentary regimes
can be included in the study (those of France, Italy, the Netherlands
and Norway). In this limited period the proportion toppled by parlia-
mentary vote increased to 38 per cent of all governments. France was
on top with two thirds (21 out of 33 cabinets), followed by Britain and
Italy (Table 6.5).
Between the two world wars the Weimar Republic was characterised
by many votes of no-confidence but few successes (the exceptions were
Luther in 1926 and Marx in 1926). However, because of its premature
end in January 1933, when the Nazis came into power, this system has
been excluded from my analysis. The parliamentary termination of
governments during this period of crisis rose to almost 40 per cent,
with Norway, France and Sweden at the top.
These experiences led to a rationalisation of the parliamentary
system after 1945. France (Article 50 of the constitution of the Fourth
Republic) was the first country to streamline the procedure of motions
of no-confidence. Nevertheless the tradition was not completely
changed: there were 14 motions of censure between 1946 and 1957,
but only five were put to the vote and none led to the dissolution of
government. An unexpected ‘lethargy of votes of no-confidence’ devel-
oped in France.101
Germany went far in rationalising the vote of censure. The contra-
dictory ‘constructive vote of no-confidence’, requiring agreement on a
new chancellor, sounds like positive thinking but psychologically it is
rather destructive as dissenters in the government have to conspire
behind the back of the acting chancellor in order to find a new major-
ity. It is hardly surprising that the only successful case of such a vote
(against Schmidt in 1982) caused a kind of ‘trauma of treason’ because

the liberals betrayed their chancellor and entered immediately into a
new coalition. Several leading figures did not accept this procedure and
left their party to join the SPD.
The constructive vote of no-confidence has correctly been compared to
cutting the tops off weeds and leaving the roots untouched.102 Most of
the rationalisation measures after 1945 proved to be mezzucci and had no
major impact on governmental stability.103 Nevertheless others have
imitated the German model (Spain, Article 114.2; Belgium, Article 96).
6.11 Non-parliamentary reasons for government

termination
In democracies electoral failure should be the main reason for govern-

ment termination. But it is only in Australia, Britain, Germany, Austria
and New Zealand that governments run their full term. 104 In systems
where the dissolution of parliament is frequent the electorate has long
acted as an arbiter of conflicts between the government and the parlia-
mentary majority. Thus the dismissal of government by the sovereign
was replaced by the termination of government by the people.
The influence of elections on the stability of government depends
less on constitutional provisions than on the party system. In this
respect the early parliamentary systems can be divided into several
groups:
• Countries with close to a two-party system, where elections frequently

led to a change of government (Britain in 1868, 1874, 1880 and 1886;
Belgium in 1845, 1847, 1852 (indirectly), 1870, 1878 and 1884).
• Multiparty systems with weakly organised groups, where govern-
ments frequently ended because of a conflict within the coalition.
Sometimes this was expressed by hostile votes in parliament (France
in the 1920s and 1930s, the Weimar Republic in 1920 and 1928).
• Systems with weak parties but strong antisystem groups (in France
from 1814–30, ultra-royalists and republicans; in the Kingdom of
Italy, clericalists and republicans). In this type of system elections
had little influence on the composition of the government.
• Systems in which governments of the centre were in office in
slightly varying combinations (France until 1914, apart from the
government under Combes; the Weimar Republic, 1920–28;
Belgium, the Netherlands, Sweden and Norway between the two
world wars).
Table 6.4 Causes of government downfall, 1832–1939
Number Parliamentary Elections Breakup of Voluntary Conflict with Sickness, Resignation

defeat coalition resignation head of state death of protocol
1832–1914:
Belgium 24 5 6 6 – 3 3 –
(Lebeau–Broqueville)
Britain 26 12 4 2 2 1 5 –
(Grey–Asquith)
Total 50 17 10 8 2 4 8 –
1884–1914:1
Belgium 10 1 1 4 – 1 2 –
(Frère–Orban–Broqueville)
France 33 21 1 2 7 – 2 –
(Ferry–Doumergue)
Britain 10 4 1 1 1 – 3 –
(Gladstone–Asquith)
Italy 28 9 2 4 11 – 2 –
(Depretis–Giolitti)
Netherlands 9 2 6 – 1 – – –
(Heemskerk–Cort van der Linden)
Norway 14 3 4 2 2 2 1 –
(Sverdrup–Knudsen)
Total 104 40 15 13 22 3 10 –
Average (%) 38.5 14.4 12.5 21.1 5 8.5 –
183
184
Table 6.4 continued
Number Parliamentary Elections Breakup of Voluntary Conflict with Sickness, Resignation

defeat coalition resignation head of state death of protocol
1919–39:
Belgium 21 3 3 11 4 – – –
(Delacroix–Pierlot)
Denmark 8 – 3 1 2 1 1 –
(Zahle–Stauning)
Finland 19 8 1 2 6 1 – 1
(Castrén–Cajander)
France 40 22 3 5 9 – 1 –
(Clemenceau–Daladier)
Britain 10 1 4 1 2 – 2 –
(Lloyd George–Chamberlain)
Netherlands 9 2 6 1 – – – –
(Ruys–Colijn)
Norway 13 10 1 – – – 2 –
(Knudsen–Nygaardsvold)
Sweden 15 7 4 1 2 – 1 –
(Edén–Hansson)
Total 135 53 25 22 25 2 7 1
Average (%) 39.22 18.5 16.2 18.5 2.7 3.55 7.35
Notes:
1. The causes of the downfall of the last cabinets are included, even if the time of the dissolution of government was no longer in the period in
question, because otherwise there would be one cabinet fewer than counted in the total number.
2. If France is excluded the average falls to 22.6 per cent.
The more fragmented the party system the less that elections are the
normal reason for a change in government (Germany in 1924, 1930
and 1932, Finland in 1953 and 1961, and Belgium in 1925 and 1932
offer cases that demonstrate this hypothesis). A survey of the reasons
for cabinet termination (Tables 6.4–6.6) shows that in the oldest parlia-
mentary regimes (Britain and Belgium) between 1832 and 1914 only
one fifth of governments (10 out of 50) were terminated by elections
(Table 6.4). From 1884 onwards France, Italy, the Netherlands and
Norway can be included in the sample, whereupon the proportion of
governments ended democratically by elections falls to 14.4 per cent.
Between the two world wars the eight remaining parliamentary
systems – the Weimar Republic not included because it ended in 1933 –
had been fully democratised in terms of universal suffrage since 1918–19
(see Table 2.3). Nevertheless elections and democratic votes were only
second in importance in the termination of government (18.5 per cent).
The voluntary resignation of the prime minister was as frequent as the
termination of government by popular vote (18.5 per cent), while termi-
nation by parliamentary vote remained on top (39.2 per cent).
The democratisation of parliamentary systems had paradoxical conse-
quences: when combined with proportional representation, universal
suffrage increased the fragmentation of European party systems.
Government stability was affected and polarisation increased. Italy, the
Weimar Republic and Spain were transformed into dictatorships.
Apparently consolidated parliamentary democracies struggled with
large right-wing extremist groups and were on the brink of civil war
(Belgium and France).
Only after 1946 did a larger number of consolidated parliamentary
democracies begin to develop, and between 1946 and 1990 half of all
government terminations were caused by democratic elections (181 of
348 cases) (Table 6.5).
There were a number of reasons for the end of government that had
no parliamentary basis, such as:
• The death or illness of the prime minister.

• The voluntary resignation of the prime minister.
• The resignation of the prime minister because the head of state had
changed.
• Conflicts with the head of state (see Chapter 5).
All these reasons have hardly any systematic value. Only one type
of government termination is interesting: party conflicts within a
coalition.
6.12 Conflict in the governing coalition as a reason for

government termination
In early parliamentary systems many governments came to an end as a

result of quarrels among parliamentary cliques. With increasing
democratisation organised parties penetrated the parliamentary scene
(Chapter 3) and the breakdown of coalitions became more than the
result of individual rivalry among certain parliamentary leaders, for
example:
• Individual ministers left the government. This happened mostly in

systems with a loose connection between the governing parties and
the government itself.
• Party leaderships outside the government did not approve of
cabinet decisions.
• Party conventions outside parliament criticised the government’s
policies and the ministers of that group had no choice but to resign
or leave their party. The latter cause of termination of government –
‘steering from outside parliament’ – happened most frequently
when new ideological forces entered the governing coalition. It hap-
pened during the time of ‘ministerial socialism’ in France and Italy
in the first decade of the twentieth century, when the Socialist Party
would not accept collective responsibility for the decisions of its
ministers in government. 105 It also happened when Green Parties
entered government in the 1990s, as the fate of some Länder govern-
ments in Germany shows.
In early parliamentary systems the disintegration of coalitions was

responsible for government termination in only 12.5 per cent of cases.
Between the two world wars (1919–39) this rose to 16.2 per cent but
still held fourth position. If tactical resignations to broaden the coali-
tion are counted in this rubric, 91 governments out of 348 between
1946 and 1990 were ended by party conflict, or roughly one fourth of
all cases. Thus conflict within coalitions under democratic conditions
was the second most important reason for government termination.
6.13 Party systems and governmental stability
Continental parliamentary systems are multiparty systems. It is tempt-

ing to correlate the number of parties with governmental stability, but
there is little regularity. Two-and-a-half party systems, such as those in
Austria, Germany and Luxembourg, in certain periods have shown

considerable governmental stability. Some systems with three dom-
inant parties – such as that in Belgium between the two world
wars – experienced a high degree of instability. When a third party is
continuously linked to one of the major groups – such as the Australian
Country Party – stability is high because there are no alternative
options. Among the four-, five- or six-party systems there are hardly
any general rules. The size and location of parties in the spectrum of
parties eligible for coalition, and the political culture of bargaining
have proved to be more important than the number of parties. It also
makes a difference whether coalitions are led by quasi-hegemonic
parties, such as the CDU under Adenauer, the DC under de Gasperi
and the Swedish social democrats under Erlander, or whether several
approximately equal partners have to coexist, which is what made
Scandinavian bourgeois coalitions so unstable. When a government is
formed by heterogeneous groups that try to consolidate a not yet fully
legitimised system, such as the Weimar Coalition of 1918–20 (social
democrats, the Catholic centre party, leftist liberals) and the French
tripartisme at the beginning of the Fourth French Republic (socialists,
communists, Christian democrats), the coalition tends to be unstable.
When several religious parties coalesce, such as the three Dutch parties
before the foundation of a unified Christian Democratic Party (CDA),
stability can be greater than in the French tripartite model.
Sartori can be credited with ending global discrimination against
multiparty systems. Only highly polarised and fragmented party
systems in his typology were unstable.106 But even his type of polarised
multiparty system proved to be an exaggeration during the Cold War.
He never accepted that long before 1994 the communist PCI in Italy
had grown into a social democratic party and functioned to stabilise
the system. Empirical studies on the stability of government in relation
to the number of parties in a coalition encourage us to deduce conclu-
sions from the mere number of coalition partners. Oddly enough, from
1965–85 coalitions of three parties were less stable than coalitions of
four or five parties. Only six or more parties proved to be unmanage-
able and unstable.107
It is not the number of parties that is decisive for governmental
stability but rather the traditions of conflict resolution in the various
parliamentary systems. Moderate multiparty systems can work in a
centripetal way, as in Sweden, or in the tradition of consociationalism,
as in Belgium. Extreme multiparty systems work either in a centripetal
(Norway) or in a centrifugal way (Italy). Some are also consociational
(the Netherlands). These typologies explain long-term developments.

Short-term conflicts have to include the calculations of the prevailing
reasons for government termination. Consociational democracies have
shown that they can have as much governmental stability as a plural-
ity system with strictly majoritarian patterns of conflict resolution.
6.14 Reasons for government termination and

government stability
Between 1831 and 1967 there were 547 parliamentary ministries in ten
of the most important parliamentary regimes (Belgium, Denmark,
Germany, Finland, France, Britain, Italy, Norway, the Netherlands and
Sweden). Table 6.5 shows the causes of government dissolution.
Such global figures, however, are more revealing if we break them
down into various periods:
• Pre-democratic parliamentary systems, 1832–1918.

• Democratised parliamentary systems in a consolidation crisis,
1918–39.
• Consolidated parliamentary systems, 1946–90, Table 6.6.
Of all the causes of government termination voluntary resignation is

the most difficult to classify. In many cases it is due to anticipation of a
breakdown of the governing coalition or a pending vote of censure.
The parliamentary reasons for government termination include a
formal vote of censure, a negative response to a question of confidence
and normal hostile votes.
It was not easy to select a representative time span before the Second
World War. Since 1832 there have only been two continuous parlia-
mentary systems (Britain and Belgium). France can be included for the
years 1821, 1830 and 1879 onwards, after the MacMahon crisis, but
there have been quite a few interruptions. Italy followed in 1860, and
Table 6.5 Causes of government dissolution, 1831–1967
Resignation Conflict Death or Voluntary

because of with the illness of resignation Disintegration
Parliamentary change of head of the prime of the prime of cabinet or
vote head of state state Elections minister minister coalition
181 12 22 99 28 108 97
Table 6.6 Causes of government dissolution in Western democracies, 1946–90
Conflict
Parliamentary Breakup of Expansion Voluntary Death or Resignation with head Number
causes Elections coalition of coalition resignation illness of protocol of state of cabinets
Australia – 16 – – – 2 – – 18
Austria – 11 4 – 1 1 – – 17
Belgium – 9 18 2 – – 1 – 30
Britain – 9 – – 2 3 – – 14
Canada – 12 – – 2 1 – – 15
Denmark 1 14 2 1 – 3 – – 21
Finland 3 11 10 6 4 – 1 1 36
France1 – 7 – 2 2 – 3 5 19
Germany2 – 11 2 – 1 – 1 – 15
Ireland 1 13 – – 2 – – – 16
Iceland – 10 3 1 – 2 – – 16
Italy 8 7 21 7 3 – – – 46
Luxembourg – 6 3 1 – 1 – – 11
New Zealand – 10 – – 3 2 – – 15
Netherlands 1 12 4 – – – – – 17
Norway 3 9 1 – 2 1 – – 16
Sweden 1 5 3 1 – 2 – – 12
Total 18 172 71 21 22 18 6 6 334
Average (%) 5.4 51.5 21.2 6.3 6.6 5.4 1.8 1.8 100
Notes:
1. 1959–90.
2. 1949–90.
189
showed a certain pattern after the trasformismo (1876). The Netherlands

began in 1868. For Norway (1884) the variation was broad enough and
the regimes sufficiently stable to compare the governments between
1884 and 1914. During that period, on average 38.5 per cent of the
governments of the countries listed in Table 6.4 ended because of par-
liamentary defeat. Between the two world wars the average for eight
countries was 39.2 per cent. The French figures, however, distort the
overall picture because of the frequent abuse of the question of
confidence that took place in that country. Without France parliamen-
tary defeat declines to 32.6 per cent. After 1946 parliamentary defeat as
a cause of government downfall was marginalised (about 7 per cent).
Voluntary resignation was second in importance before the First
World War (21.1 per cent) and elections were third until 1914 (14.4 per
cent). The latter did not increase to the extent that might be expected
after the democratisation of the parliamentary regimes (18.5 per cent).
Only after the 1946 elections did they become by far the most impor-
tant cause of government termination in about half of all cases. The
democratisation of parliamentary regimes strengthened the party state,
which had its impact because the disintegration of coalitions increased
continuously from 12.5 per cent (1884–1914) to 16.2 per cent
(1919–39) to more than one quarter (27.5 per cent). This does not
mean that there were fewer internal conflicts in early parliamentary
regimes, rather that they were more frequently resolved by a parlia-
mentary vote. The death or illness of the prime minister declined as a
reason for government termination as fewer elderly and/or unhealthy
men ran for the most important office under democratic conditions.
Assassination as a reason for government termination also decreased
with the consolidation of parliamentary government.
Governmental stability also changed over time. Before 1914, on
average cabinets lasted about two years. This decreased between the
two world wars to 1.25 years and rose after 1946 to 1.7 years. Oddly
enough, with the exception of the years of permanent crisis (1919–39),
the differences are fairly slight (Table 6.7).
Advocates of dualistic constitutional monarchy once criticised parlia-
mentary regimes as detrimental to cabinet stability. Mohl was one of
the first to oppose this argument with empirical evidence from Britain
and Belgium. 108 Conservatives considered that only autocratic monar-
chies could create stable government. The Metternich government
(1814–48) seems to have been stable per se, but its reactionary politics
led half of Europe into the revolution of 1848. On the other hand, as
soon as autocratic regimes encounter a crisis they tend to become
extremely unstable, as the last monarchical autocracy in Europe,

Russia, showed with the change of policies under prime ministers such
as Vitte, Goremykin and Stolypin. Parliamentary regimes can some-
times be almost too stable, for example the governments of Briand,
Ben Gurion, Adenauer, de Gasperi, Gerhardsen, Menzies, Thatcher and
Kohl. What determines governmental stability?
First, the easiest and most technical answer is the normal duration of
the parliamentary period. A five-year parliamentary mandate can
promote stable government, as in Britain and Canada, but Italy and
Ireland are deviant cases. The degree of party fragmentation and the
mechanisms of coalition building are more important than the dura-
tion of the parliamentary period.
Second, another more technical variable is frequently mentioned:
the electoral system. The Hermens school and other critics of propor-
tional represention have argued that the plurality system contributes to
Table 6.7 Duration of cabinets
Number of
governments Duration in months 1940s 1950s 1960s 1970s 1980–94
Australia 27 22.4 23.3 31.8 17.6 19.3 24.5

Austria 19 32.6 29.3 32.0 27.0 39.2 34.5
Belgium 32 17.7 10.2 21.5 32.0 13.6 16.2
Britain 19 30.6 55.0 25.3 26.7 31.4 35.3
Canada 20 29.9 32.0 31.3 25.2 30.0 32.6
Denmark 30 20.0 29.0 18.8 22.5 17.4 19.1
Finland 42 13.5 19.7 10.5 17.7 11.7 22.8
France 47 12.3 5.1 8.6 24.2 21.2 15.8
Germany 18 31.8 49.0 49.0 26.6 31.7 26.3
Greece 41 11.6 6.7 10.7 5.7 17.5 26.3
Ireland 21 30.2 42.5 31.0 34.0 33.0 23.0
Italy 48 12.1 10.5 12.0 15.0 10.3 12.8
Japan 38 15.9 9.4 13.6 24.0 18.0 15.2
Luxembourg 13 43.2 52.0 28.6 60.0 60.5 60.0
New Zealand 22 28.5 31.0 27.5 33.8 23.6 28.6
Netherlands 20 30.1 35.0 32.5 32.0 30.5 30.8
Norway 24 25.0 36.0 30.0 26.6 23.8 21.7
Portugal 15 14.2 – – – 7.3 23.5
Spain 7 31.5 – – – 21.5 36.5
Sweden 24 25.7 24.7 21.6 30.0 25.4 27.0
Source: Data from Jan-Erik Lane et al., Political Data Handbook OECD Countries, 2nd edn
(Oxford University Press, 1997), p. 123 ff.
governmental stability and hence to regime stability. This hypothesis

was built on the trauma of the Weimar Republic. After 1945 the much
praised British system produced governments that lasted about two-
and-a-half years (from 1945–94 the average was 30.6 months).
However the stability of Germany, with its proportional electoral
system, was even greater in the same period (31.8 months per govern-
ment). Austria developed an almost British party system, but with pro-
portional representation. The deviant cases were explained by the
minimum thresholds for entering parliament in proportional systems,
such as in Germany. In the Netherlands the plurality vote was even
recommended against the fragmentation of the system – in blatant
ignorance of the functioning of consociational democracy.109
Third, governmental stability seems to correlate with the number of
parties in the coalition. The experiences of Belgium, Denmark, France
(Fourth Republic), Finland, Italy and the Netherlands seem to support
this hypothesis. But the reverse conclusion is not acceptable:
Luxembourg, Austria and Germany have more stable governments, in
spite of their being coalitions, than Britain with its one-party govern-
ments (Table 6.2).
Fourth, the existence of extremist parties can certainly have a neg-
ative effect on governmental stability. But sometimes the radicalisation
of one party, such as the Austrian FPÖ, which changed from a liberal
party to a populist right-wing extremist group, can strengthen the
cohesion of the established parties so that governmental stability is not
weakened.110
Fifth, governmental stability correlates with the degree of parliamen-
tary support for the governing parties. If we exclude oversized coali-
tions and grand coalitions of the two major parties in the system (as in
Austria, Germany and Luxembourg) the deviant cases are Belgium and
Finland, and occasionally Italy. Undersized minority governments
have a relatively low life expectancy in Scandinavia, but not in
Canada. Again the correlation between size of coalition and stability of
coalition is far from indicating in one direction (see above).
Finally, it is a truism that governmental stability weakens in times of
crisis. The crises in the late 1940s and the late 1960s/early 1970s
(except in Ireland) shortened the life-span of governments. In France
the crisis started in the 1950s in connection with the process of
decolonisation, which even caused a regime change in 1958. The years
1980–94 were fairly stable in most European countries, with the excep-
tion of Belgium (ethnic problems) and Germany (the consequences of
reunification).
Times of crisis have been measured by certain indicators such as

strikes and protest movements. But normal strike waves have not
shortened the life of governments. This has been true only of political
strikes and unrest that entailed political sanctions.111
There are many factors that determine government stability. But
their enumeration is unsatisfactory for all those scientists who want
explanatory instead of descriptive science. According to Kant, he ‘Who
mentions many causes has no sufficient explaining cause’, or, in more
contemporary terms, those who mention many variables have no inde-
pendent variable. The best explanation of governmental stability is
provided by the degree of parliamentary support and the number of
parties in a coalition.
After the Second World War stability was of great political value and
governmental instability was considered an indicator of crisis. This was
not completely wrong, and as Karl Schiller said in relation to the stabil-
ity of currencies: ‘Stability is not everything, but everything is nothing
without stability.’
The glorification of stability and the critique of instability of govern-
ments needs, however, to consider four counter arguments:
First, the degree of parliamentary support is more important than
the number of governments. In some countries the frequent
reshuffling of coalitions increases the number of cabinets without any
real change in the basic composition. Parliamentary support for the
government fell in recent years in Scandinavian countries with minor-
ity governments, but it remained fairly consistent in other systems
with minority governments, such as Canada and Italy.
Second, governmental instability sometimes obscures a high degree
of continuity among the personnel: the saying ‘plus ça change – plus
c’est la même chose’ (the more things change, the more they remain
the same) is applicable to the Third and Fourth French Republics.
Briand headed nine governments, two other ministers served in eight
cabinets, two others in seven, six served in six governments, 21 served
in five cabinets and 38 in four different ministries. The continuity of
personnel from cabinet to cabinet varied between 60 per cent and
80 per cent.112 La chorégraphie ministérielle did not allow a great
turnover. There was rarely a clear alternation, although certain minis-
terial cycles indicated a change among the executive elites (1879–85,
1885–87 and 1889–93). Similar findings can be found in studies on
Belgium and Italy.113 Only for the Netherlands was the picture slightly
different. There governmental stability was accompanied by high
turnover of ministerial personnel – more than two thirds of ministers
between 1848 and 1958 served in only one cabinet. 114 This can be
explained by the loose connection between the government and the
parliamentary parties, reinforced by the incompatibility of parliamen-
tary mandate with governmental office.
The turnover of politicians is only one indicator of stability. Another
is subsequent service in other departments. From 1945–85 Italians
(33.2 per cent) and Irish (32.6 per cent) showed the greatest readiness
to serve in various offices. Germans were in a medium position (12.5 of
ministers consecutively held three or more portfolios) and the greatest
inertia was found in consociational systems such as those in
Luxembourg, Finland, Norway, the Netherlands and Austria.115
Third, cabinet stability can be complemented by a high degree of
continuity and political competence in the administration. The
Westminster model has created the perception that ministerial activi-
ties are more or less political. Continental systems, including those in
Finland, Austria and France, are still influenced by the traditional
prevalence of the bureaucracy, and ministers are more administrators
than politicians. 116 In Austria and some other consociational systems
the constant negotiations between politicians and major organised
interests have led to a modernised, non-bureaucratic but nevertheless
fairly technocratic variation of this tradition.
Finally, governmental instability according to the rules of an elitist
‘ministerial choreography’ is less detrimental than endless negotiations
with potential coalition partners in a system that normally needs an
informateur to explore the possibilities for building a cabinet, a perma-
nent reshuffling of ministries as in Belgium and the Netherlands (see
Chapter 5). In fragmented party systems with an unsafe governmental
base, as in the Netherlands, cabinet stability is often not the result of
trust and parliamentary support but rather of fear because the parlia-
mentary groups do not want to run the risk of a premature govern-
mental disintegration and the consequent negotiations for another
coalition.117
6.15 Alternating governments
After 1945 cabinet stability was the main consideration in government

formation, but when the parliamentary democracies had successfully
consolidated another ideal came to the fore: alternation. In reaction to
the turmoils of the interwar period many European governments
became overly stable and their leaders entrenched. Statesmen such as
De Gasperi, Adenauer, Gerhardsen, Erlander and De Gaulle dominated
the scene for so long that the feeling grew that an alternative govern-
ment was necessary. Even in countries with many changes of govern-
ment there was change without alternation, and the question arose of
whether alternative government was limited to the Westminster model
of parliamentary government and possible only on the basis of a plu-
rality voting system and according to the winner-takes-all formula. But
again there are examples to disprove this: the Irish Westminster system
produced little alternation, until the 1980s, while certain countries
with proportional representation experienced many alternations of
government.
Under continental conditions not all alternations have had a posi-
tive impact on the system. First, in countries with a high degree of
instability and frequent minority governments, such as Denmark,
Norway and more recently Sweden, frequent alternation has not been
a sign of competitive democracy but rather that none of the camps
could produce a durable majority.
Second, in non-consolidated systems in Southern and Eastern Europe
there has been a to-ing and fro-ing between democratic forum parties
and post-communists (Lithuania 1992, Poland 1993 and Hungary 1995
in one direction, and Romania 1996 and Bulgaria 1997 in the other
direction). In all the new parliamentary democracies, the volatility of
votes in parliamentary elections was enormous: in Greece it was 19.1 per
cent in 1977, 24.1 per cent in 1981 and 5 per cent in 1985; in Portugal
11 per cent in 1979, 2.7 per cent in 1983 and 25.7 per cent in 1987; in
Spain 10.8 per cent in 1979, 42.5 per cent in 1982 and 11.9 per cent
in 1986; in the Czech Republic 15.8 per cent in 1992 and 17.4 per cent
in 1996; in Slovakia 20.6 per cent in 1992 and 25.5 per cent in 1994; in
Poland 33.8 per cent in 1993; in Romania 43.0 per cent in 1992 and in
Hungary 22.7 per cent in 1994. 118 Nobody would interpret these
changes in votes and their consequence – government recomposition –
as a kind of alternation in the Westminster tradition. Rather they were
proof of a consolidation crisis.
Third, in semipresidential systems an alternation in government can
lead to a deadlock between the head of state and the prime minister.
Cohabitation in purely parliamentary systems is normal, even if it is
not always as idyllic as one French author suggested. 119 Conversely
cohabitation in France has not proved as disastrous as many French
writers feared – but it certainly has not promoted effective govern-
ment. Under such circumstances alternation cannot be hailed as a
Westminster-type system. In Poland, under Walesa the differences
between the president and the government from 1993 were detrimen-
Table 6.8 Alternation of governments or coalitions
Countries Decades
1940s 1950s 1960s 1970s 1980s 1990s
Australia 1946 – – 1972 1983 1996

1975
Austria – – – 1970 1983 –
Belgium – 1954 – 1974 1982 –
1958
Britain 1945 1951 1964 1970 – 1997
1974
1979
Canada – 1957 1963 1979 1980 1993
1984
Denmark – 1950 1968 1971 1982 1993
1953 1973
1975
France – – – – 1981 1993
1986
1988
Germany – – 1969 – 1982 1998
Greece – – – 1974 1981 1993
1989 1997
Ireland 1948 1951 – 1973 1981 1994
1954 1977 1982 1997
1987
Italy – – – – – 1994
1996
Japan – – – – – 1993
1994
Luxembourg – – – 1974 – –
1979
New Zealand 1949 1957 1960 1972 1984 –
1975 1989
Norway – – 1963 1971 1981 1990
1965 1972 1986 1997
1973 1987
Spain – – – – 1982 1996
Sweden – – – 1976 1982 1991
1994
tal. Walesa’s successor, Kwasniewski, shows, however, that a different

government composition is not a disaster as long as some presidential
restraint is exercised.
Finally, in presidential systems alternation is frequent, but even
when there are two consecutive presidents from the same party the
new administration appoints different secretaries of state and top

officers.120 Alternation at both levels does not prevent effective govern-
ment. This should warn us not to generalise too much on the basis of
the experiences of European democracies. Whether alternation is good
or bad depends on many other variables.
Alternation is always asymmetrical. Between 1922 and 1997 in
Britain the Conservatives held power for a total of 55 years and Labour
only 20 years. In France the balance between right and left was even
more unequal.121
There is no need for ideological struggles over whether majoritarian
or consociational democracies are preferable. One day a European elec-
toral law – certainly a proportional one – will show that neither the
British nor the French majoritarian formula can prevail. Postmodern
democracies – with growing fragmentation among ethnic groups,
regions and functional movements – will probably swing more towards
consociationalism. This may contribute to the peaceful development of
fairer European parliamentary democracy, but it will have one draw-
back: alternation will remain rare unless long-term entrenchment, such
as occurred with conservative neoliberalism in many countries in the
1980s and the new wave of social democratic rule at the end of the
1990s, from time to time creates a transnational change in the domi-
nant values of governing.
7
Conclusion
Parliamentary democracy is the worst of the governmental

forms – except all others.
Winston Churchill
7.1 The consolidation of parliamentary systems
Consolidation research after the fourth wave of democratisation in

Europe (1989 onwards) has put the start of democratisation at an early
point in time – according to Huntington, around 1828. However, what
was called democratisation before 1914 was only the intention of
radical and socialist parties from 1848. The dominating familles spir-
ituelles, the liberals and conservatives, and also the Christian social
groups that developed out of the church–state cleavage (initially
Belgium), wanted the constitutional system to be parliamentarised. But
most of them disapproved of universal male suffrage, which was the
minimum criterion for a democracy. Universal suffrage was first sup-
ported by conservative groups (Napoleon III in the Second Empire
retained it in 1851; Bismarck 1871; in the 1860s Disraeli supported
wider suffrage in Britain, which would make some ‘affluent workers’
eligible to vote). In most countries democratisation was merely parlia-
mentarisation of the constitutional regime. But in France in 1875
constitutional laws were laid down that allowed the beginning of a
parliamentary form of government.
Parliamentary government in theory and practice developed on the
European continent after 1814. All earlier attempts to push through
some elements of parliamentary government in the revolutionary
constitutions had failed. In the debates of the French national assem-
bly after 1789 and the Spanish Cortes between 1810 and 1812 only few
198
Conclusion 199
politicians, for example Mirabeau and Argüelles, departed from the

ruling doctrine of separation of powers and demanded closer executive
– legislative ties. But even they confined themselves to demanding
compatibility between ministerial office and mandate and to the bid
for political ministerial responsibility. A comprehensive theory of par-
liamentary government did not yet exist.
The first system of government on the continent that could be
called parliamentarian was the Charte regime of 1814. During
Restoration a theory of parliamentary government was developed in
France that was strongly oriented towards the English constitutional
reality, but it was not modelled on the political writings of Britain.
Even the most original English political thinkers of the time – from
Burke to Mill – still strongly adhered to the old theory of mixed gov-
ernment. The parliamentary system of the Restoration did not last
long: it ceased when Charles X acceded to the throne and took on the
role of active ruling monarch. After the resignation of Villèle he aban-
doned the principle of parliamentary majority government.
The revolution of 1830 in France and Belgium led to elected
national representation for the first time in the history of the conti-
nent, and this became the predominant factor in political life. This in
turn led to a constitutional system where the principle of majority
government accountable to parliament – with few exceptions – was
respected.
The process of parliamentarisation in the nineteenth century cannot
be generalised for all countries, only for groups of countries.
First, in some countries a dualistic constitutional system was created
as few politicians wanted parliamentary government. Nonetheless,
these systems developed in the direction of parliamentary majority
government since the preponderance of parliament remained because
of social and political circumstances (the July monarchy in 1830–48,
the constitution of the Paulskirche in Germany, in Belgium, the Statuto
Albertino in Italy).
Second, in other countries the dualistic constitutional system contin-
ued until the end of the nineteenth or the beginning of the twentieth
century. It was only after vehement fights with the crown that parlia-
ments managed to gain influence over the formation or removal of
governments (the Netherlands in 1868, Norway in 1894, Denmark in
1901, Sweden in 1917, Germany in 1918).
Third, the deliberate creation of a parliamentary system by constitu-
tional assemblies in the nineteenth century was rare (the Second
Republic in France created a semipresidential system, and a fully parlia-
mentary regime was created at the beginning of the Third Republic)

and did not become the norm until the twentieth century.
Fourth, a small group of countries in Europe were strongly inclined
towards parliamentarisation, but parliamentary government was not
introduced before the end of the First World War and in some coun-
tries (the Balkan states, Austria-Hungary, Russia) it never prevailed (see
Chapter 1).
In the parliamentary countries, the dependence of the executive on
parliamentary majorities was not always ensured. In some countries
there were backlashes. Depending on the influence of political groups
opposed to a parliamentary regime, there were big differences between
the interpretation and the development of the system. In countries
where radicals were in power, a parliamentary oligarchy of ministrables
temporarily gained such a degree of predominance that conservative
observers spoke of a gouvernement d’assemblée (Third Republic in France).
In countries with a strong conservative influence many attempts were
made to return to the constitutional system (the Kingdom of Italy, the
Weimar Republic, to a lesser degree in the Netherlands, and in Sweden
around 1920). Between the two world wars the parliamentary system
was in crisis throughout Europe and even Britain had to make a great
effort to avoid the danger of minority government.
Only after the Second World War were the democratic and parlia-
mentary elements of the modern constitutional state so closely tied
that in most countries the parliamentary system functioned satisfacto-
rily. Only in France, with the downfall of the Fourth Republic in 1957,
and in Greece (1967) did parliamentarism suffer a severe reversal. After
the Second World War several attempts were made to rationalise or
restrain parliamentarism. But all these attempts suffered from a
doctrinaire belief in constitutional provisions and from neglect of the
political and social realities.
The theoretical reference points of the constitution-making assem-
blies were usually legal doctrines of balance. Social science and histor-
ical research were hardly ever analysed. In some cases the interpretations
of the ideal of the ‘fathers of the constitution’ were understandable. In
Germany, in 1949 the political stability that came to exist in 1959
would have been dismissed as an impossible dream. It is understand-
able that after the breakdown of many parliamentary regimes follow-
ing their usurpation by totalitarian groups that mistrust of power
became widespread in Europe.
Parliamentarism in Europe – favoured by the social development –
created stable conditions not because but in spite of its institutional
Conclusion 201
provisions. In the twentieth century the parliamentary system spread

to all free states in Europe – with the exception of Switzerland – and
also started to gain a foothold in non-European countries. The
Commonwealth countries and Israel, Japan and India made the great-
est progress towards parliamentary democracy. Today only the dualis-
tic presidential system of the United States and the Swiss collegial
system (Kollegialsystem) – where the executive has a limited term of
office – provide a theoretical alternative to the parliamentary system.
Although these two systems have some supporters in Europe, no
attempt to introduce either one into another European country has
found majority support.
In the extension of the parliamentary system, imitation of the British
system was less important than the functional necessities of the consti-
tutional systems. Political theory at the beginning of parliamentarisa-
tion was only rarely the torchbearer. With the exception of the Third
French Republic, parliamentary government in the nineteenth century
partly lacked a proper legal foundation. Only with the help of ‘loop-
hole theories’ has it been tried to harmonise parliamentary practice
and dualistic constitutionalism (for example Donati in Italy).
Compatibility of mandate and ministerial office – an important pre-
requisite for parliamentary regimes – was established in most constitu-
tions in Europe (the exceptions being France, the Netherlands and
Luxembourg). Before 1875 parliamentary ministerial responsibility –
besides constitutionally guaranteed responsibility in terms of penal
law, which has become nearly insignificant – was not defined in any
constitution and the standing orders of parliament were an obstacle
rather than a support. Therefore ministerial responsibility in many
countries was controversial and seen as a characteristic feature of the
personal governing style of some monarchs.
The ‘Coburg governing style’ was frequently used to describe the
position of the parliamentary monarch in Britain and Belgium. Only in
the second half of the nineteenth century did the realisation spread
that the parliamentary system was neither a governing style nor a copy
of the English constitutional reality, but a form of government sui
generis, which slowly replaced the constitutional system – with or
without changes to the constitution. Parliamentary monarchies
legalised this development in their constitutions only after the Second
World War (for example Denmark in 1953 and Sweden in 1970 and
1974) (see Chapter 2).
Research on the process of parliamentarisation in continental Europe
does not lead to an ‘anatomy of parliamentarisation’. The development
of the parliamentary form of government cannot be explained by

homogeneous causes and political instruments. Some countries
achieved parliamentarisation through parliamentarily led revolution
(for example the July monarchy in Belgium), and others through the
insistence of the lesser partner when it was united with another
country in a ‘personal union’ of the two monarchs (Norway,
Luxembourg, Finland, Hungary). The weakening of the crown by
breaks in continuity and legitimacy have favoured the strengthening of
parliament (for example in England, Belgium, and Italy after 1861). But
none of these factors is applicable to all parliamentary monarchies.
A general reason for the strengthening of parliament is high esteem
for the strictures of the law in constitutional monarchies. However, not
every state that favoured the division of powers developed towards par-
liamentary rule. Some countries even emphasised the incompatibility
of their highly developed rule of law with the principles of parliamen-
tary party government (the German Empire). With the increasing shift
of emphasis from parliament to government, the rigorous constitu-
tional concept of law threatened to be undermined by the growing
decree-making power of the government.
The closer the ties between the parliamentary majority and the gov-
ernment, the less that parliament as a whole could oppose this devel-
opment. The distinction between executive and legislative – to which
early constitutionalism attached great importance – in the parliamen-
tary state became questionable because of the unity of actions by the
government and the parliamentary majority. The general reason given
for the development of parliamentary governments is a social one. One
could say that the powers gained by the bourgeoisie contributed to the
emergence of parliamentary government. But the bourgeoisie also
created other forms of representative government and in some of the
countries that were parliamentarised early, the aristocracy became sup-
porters of parliamentary majority governments (England and France
during the Restoration). In nations that were slower to develop,
however, it was only when the working class began to participate in
political life that the bourgeoisie put through parliamentary principles
that had been demanded for a long time (Sweden and Germany). It
follows from this that the large ideological party groups did not imple-
ment parliamentarism by themselves. In most countries liberal parties
– in close cooperation with the ‘discussing class’ of the bourgeoisie –
were the pioneers of parliamentarisation, but only in a few countries
were they able to force through parliamentarisation by themselves (the
Venstre Party in Norway and the Liberal Party in the Netherlands).
Conclusion 203
Large ideological groups that had reservations about parliamentary

government later began to demand it or – after parliamentary govern-
ment had been implemented – took advantage of the system. In some
countries (Belgium and Italy) moderate conservatives, clericals and lib-
erals supported parliamentarisation. In other systems conservatives –
when they had a majority without being in government – demanded
parliamentarisation as their oppositional doctrine (the ultra-royalists
after 1814 in France, the Orléanists in 1873 against Thiers). In other
countries socialists played a decisive role in putting through parlia-
mentary government (Sweden and Germany). Thirty years after the
socialists began to participate in elections and parliamentary work in
many countries they became members of bourgeois coalition cabinets
(first in 1899 in France, later in parliamentary support of Giolitti in
Italy, and during the Second World War in many warring nations in
Western Europe and even in neutral Sweden).
Parliamentary government born of the liberal constitutional ideal
became more and more the favoured governmental system of all polit-
ical groups. But some parties – depending on their influence – realized
strong variations in several institutional questions, especially with
regard to regulations on the position of the head of state, the two-
chamber system, the vote of no-confidence, the question of confidence
and parliamentary dissolution. Only polar groups such as communists
and right-wing extremists remained apart from the increasing consen-
sus on the desirability of a parliamentary government. But in some
countries even the communists were willing to cooperate in a strong
monistic parliamentary system without a dualistic separation of powers
(shortly after the Second World War in most countries in Europe,
today in post-communist Eastern Europe).
The means used by the parliaments and parties that had become
torchbearers of parliamentarisation did not follow a general pattern.
Ministerial impeachment (Norway), rejection of the budget or parts of
it (the Netherlands), the right to interpellate and criticism of the gov-
ernment in debates on the parliamentary address (the July monarchy,
Belgium, Italy) were important weapons of parliament to increase the
dependence of the government on parliamentary votes. Only rarely –
as in the case of Norway and the Netherlands – did one spectacular
parliamentary conflict and one noticeable instrument of parliamentary
combat help to implement parliamentary government. In many coun-
tries the process was cumbersome and complex. In countries where the
right to interpellate was only rudimentarily developed, parliamentary
government was introduced under the pressure of threatened social
upheaval. ‘Parliamentarisation from above’ in these cases came before

‘upheavals from below’ (the Second French Empire and the German
Empire).
In the first chapter of this book the parliamentary government and
its position in the research on governmental regimes were analysed.
The counter term to the parliamentary regime in the leading constitu-
tional doctrine of the nineteenth century was the ‘monarchical princi-
ple’. The fiction that a balance existed between two independent state
powers – crown and parliament – was destroyed in the long struggle
between the adherents of each principle. For a short period the monar-
chical principle of a ‘dictatorship by the king’ in countries that were on
the way to parliamentary government regained ascendance (France
and Spain in the early nineteenth century).
In the long run, however, national representation was successful
everywhere. In the theoretical framework of parliamentary government
the terms ‘mixed constitution’, ‘constitutional monarchy’, ‘representa-
tive constitution’ and ‘legal state’ played a major role and in most cases
delayed recognition of parliamentary government as a distinct form of
government. The more the parliamentary system spread across the
world, the more questionable the homogeneous term parliamentary
government became. Depending on the political position of the
authors, various states were associated with ‘parliamentary govern-
ment’, ‘parliamentarism’ or ‘degenerated constitutionalism’. Terms
that were used to discriminate against individual systems, such as ‘gov-
ernment of assemblies’, ‘system of convention’, ‘unauthentic parlia-
mentarism’, ‘chancellor regime’ and ‘dictatorship of the prime
minister’, to this day create ideological frontlines instead of solving the
classification problem (Chapter 1).
Attempts have been made to deal with the many variations of parlia-
mentary government. A number of forms can be identified according
to institutional criteria. Evaluations of individual systems have not
been avoided, but they cannot be made by the mere addition of the
eleven features that have been emphasised as characteristic of parlia-
mentary government. There are systems that lack a number of those
features but still have to be counted among parliamentary systems. The
features do not have the same significance in every system.
In spite of the large number of variations there is an abstract form of
parliamentary government that has become a point of orientation for
the classification and evaluation of the various constitutional forms.
Political theory that is set within the scope of ‘theories of medium
range’ has to avoid to deduct from a normative image of the system.
Conclusion 205
But at the same time it must not lose itself in descriptions of the
numerous historically unique value systems, behaviour patterns and
institutions that constitute a governmental system.
In the light of the functional comparative method the parliamentary
system has proved to be one of the most viable constitutional mecha-
nisms in the institutional settlement of political and social conflicts.
The flexibility of the system, which the dualistic representative consti-
tutions with strict separation of powers only have to a small degree,
has led to a system serving various nations, classes or parties as a shift-
ing frame. This flexibility enabled the transfer of the principles of par-
liamentary government to many countries, and to an extent that no
other form of government had achieved.
The functioning of the parliamentary system has been examined in
the literature on the basis of the three most important political
processes in the parliament–government–head of state triangle: cabinet
formation, the dissolution of government and the dissolution of parlia-
ment. This does not imply that the everyday practices of the parlia-
mentary system (beyond the main actions of parliament and
government dissolution) have been analysed exhaustively – for the
continental countries there have been few empirical studies to date.
Securing the autonomy of parliament – which initially was a protec-
tion not only against the head of state but also against the electorate –
was an important prerequisite of parliamentary democracy (Chapter 3).
The four most important functions of parliament (representation and
articulation of the people’s will, control of government, legislation and
the recruiting function) have also been important to the democratisation
of parliament (Chapter 4). In particular the recruitment of ministers by
parliament – only a few countries have retained the concept of incom-
patibility between mandate and ministerial office (the Netherlands,
Luxembourg and Fifth French Republic) – became a driving force to
implement ministerial responsibility to parliament (Chapter 5).
Cabinet formation is constitutionally regulated only in more recent
constitutions. The ideals of the fathers of national as well as parliamen-
tary constitutions have very rarely been realised. Party systems and
electoral systems determine the reality of cabinet formation. Since
there are no clear principles for government building in most constitu-
tional countries with a multiparty system, several principles are strug-
gling to gain influence in cabinet formation. The mode of dissolution
of the previous cabinet is of great importance. The ‘guilt principle’ –
which decrees that the group that caused the resignation of the last
government should assume governmental responsibility – was once the
principle of cabinet formation par excellence, but since the parliamen-

tary reasons for government downfall have decreased, it has increas-
ingly been replaced by one of the variations of the majority principle
(Chapter 6).
In the different stages of cabinet formation, the role of individual
institutions varies in importance. In the first stage of preconsultations,
the head of state still has a certain degree of influence in most coun-
tries. The dangers emanating from this influence – for example the sus-
pension of certain politicians or the instructions of government
formation under political conditions – are not the same in all systems.
But there is the general tendency to reduce both the influence of the
head of state and the possibility of a veto. In the next stage the desig-
nated cabinet former becomes the focus of attention. During the last
stage parliament as a whole usually has a chance to influence cabinet
formation when the government is introduced or in the event of a
formal investiture. In all three stages, but especially in the second, the
activities of the parties are crucial. In spite of interparty horse trading,
the party structure and political culture in most European countries
only allow pluralist political bargaining. But in many respects this is
little different from the practice of cabinet formation in a two-party
system. The negotiation process in a two-party system is less public but
on the whole it is no shorter or ‘cleaner’ than the interparty negotia-
tions in multiparty systems.
The parliamentary basis of ministries has changed considerably over
the years. It has become increasingly rare for government to come
from the upper house, and it is virtually out of the question for non-
members of parliament and independents to become head of govern-
ment because of the increasing power of the parties. The presence of
non-parliamentarians indicates a certain crisis in a system.
The structure of parliamentary cabinets has changed in the same
way, usually by increasing the power of the prime minister and by
making the prime ministership an office without portfolio. Changes in
the organisational power of the government, the tendency towards
hierarchisation of the cabinet, the extension of the patronage powers
of the head of government in terms of increasing the number of offices
and appointing ministers without portfolio have changed the character
of modern government and given the individual and collective respon-
sibility a different function compared with classical parliamentarism
(Chapter 6).
The doctrine of parliamentary ministerial responsibility led to the
view that the defeat of the government at the hands of parliament was
Conclusion 207
a classic reason for the dissolution of government, since the right of

revocation on the part of the head of state had become out of the ques-
tion with the extension of parliamentary sovereignty. Parliamentary
responsibility according to parliamentary right and parliamentary prac-
tice was effected by votes of no-confidence, questions of confidence or
simple defeat in a parliamentary vote. Theoreticians of parliamen-
tarism who oriented themselves towards the time of classical parlia-
mentarism with local dignitaries, regret that the mechanism of trust
between parliament and government has been disturbed by new vari-
ables. With the increasing democratisation of parliament, elections
became the most important reason for the resignation of governments.
With increasing fragmentation of the party structure in most continen-
tal European countries, collapse of the cabinet (in the one-party gov-
ernments) or collapse of the coalition (in multiparty governments) also
became a reason for the dissolution of government.
Evolutionary comparative studies (for example Patzelt, 1995) that
take account of the historical dimension can shed new light on the
consolidation debate of the 1990s. Consolidation research has empha-
sised four levels.
• Constitutional consolidation at the polity level (constitutional order).

This happened rather quickly during the third and fourth waves of
democratisation, although ‘finishing touches’ to the constitution
were sometimes necessary (Portugal and Poland, not yet finished in
Hungary)
• Representative consolidation at the level of parties and interest groups.
The party systems were affected by long-term restructuring, espe-
cially in countries where forum and umbrella parties were dissolving
(Spain: UCD; Poland: Solidarność; the Czech Republic and Hungary:
Democratic Forum).
• Behavioural consolidation at the level of informal actors such as the
military, entrepreneurs and radical groups. Until the beginning of
the 1980s, this consolidation was not safe in Spain. By the end of
the 1990s, in Eastern Europe, it was hardly secured with the excep-
tion of the Czech Republic, Hungary, Slovenia and Poland, the first
candidates for the eastwards expansion of the European Union.
• The consolidation of civil society usually takes a generation, as the
second wave of democratisation in the twentieth century has shown
in Italy, Germany, Austria and Japan. Opinion polls and the emer-
gence of extremist parties show that this process has been
completed in Southern Europe but not in Eastern Europe.
The parliamentary system is particularly involved with the second

level, representative consolidation. Often the literature has suggested
rather superficial indicators.
• Two elections without violent intervention from above or below.

• Acceptance of a changeover of power between the political factions
(according to this criterion, Germany would not have been consoli-
dated until 1966, the Fifth French Republic not until 1981 and Italy
not until 1994).
• No high fluctuations of voters.
• No large parties hostile to the system.
• Acceptance of the rules of the parliamentary system by the majority
of the people.
Looking back at the history of the parliamentary system, one can find
more detailed indicators for acceptance of the rules:
• Solidarity among ministers and clear-cut structures of responsibility

(Chapter 6.1).
• Acceptance of political responsibility instead of resort to ministerial
impeachment and the shift of political conflicts to the courts
(Chapters 2.2, 6.4) (at this level, an old-fashioned antipolitical con-
stitutional attitude caused by the judicial review is coming up again
in parliamentary democracy, which has its drawbacks).
• Reduction of the functions of the head of state in legislation (veto), the
formation of governments (Chapter 6.4), dismissal of the government
(Chapter 6.4) and the dissolution of parliament (Chapter 6.5).
• Reduction of the functions of the second chamber and democratis-
ation of the method of election if symmetry still exists between the
two chambers (Chapter 4.2).
• Acceptance of the parties as a link between the government and the
parliamentary majority (Chapter 4.1).
• Acceptance that parliamentarians are professional politicians who
have to be freed from outside financial temptation by receipt of
financial compensation for their work (Chapter 4.1).
According to these criteria for consolidation, it is evident that the

systems in Poland and Russia under Walesa and Yeltsin had not yet
been consolidated. The subjective indicator of the absence of violence
in the event of conflict must not be applied too formalistically even
with regard to consolidated parliamentary democracy. 1 There is often a
Conclusion 209
gap between the de facto functioning of the system and the de jure pos-
tulates that the citizens demand of the system.
Opinion polls in Germany show that the citizens and even a few par-
liamentarians do not have a clear understanding of the German parlia-
mentary system: 6 per cent of the German deputies and 18 per cent of
the voters polled believed that Germany had a dualistic presidential
system. Fifty-three per cent of deputies and 33 per cent of voters would
prefer a presidential system. This preference is less the result of enthu-
siasm for America than a preference for the constitutionalism and pres-
identialism of the nineteenth century. Germans still see the
parliamentary system as a dualistic constitutional one and therefore
demand greater separation of powers and incompatibility between
mandate and ministerial office. In particular the steering which links
the government with the parliamentary majority remains strange for
most citizens. In this respect most experts suggest a change in political
education rather than adapting the system to the ill-informed wishes
of the voters.2 The gap in people’s perception of the reality and ideals
of a system would not change with the introduction of a presidential
system, which supposedly many citizens want. In the US presidential
system there is the same discrepancy between ideals and reality, called
the ‘IvI gap’, or the gap between ideals and institutions. 3 This tension
between ideal and reality is actually useful as it promotes regular regen-
eration of the system. A certain tension between ideal and reality is
part of the consolidation of a system, as long as the ideal is not too
unrealistic or utopian.
An extensive reform literature suggests putting a stop to this process
of erosion. The extension of the modern welfare state has led to a pow-
erful bureaucracy even in states – such as Britain – that had no such
bureaucracy in the era of classical parliamentarism. The contact
between executive and legislative has become multiple and is not
restricted to the ideal-typical confrontation between parliament and
government. Civil servants who serve as ministers or in committees,
even civil servants who take part in the meetings of the governing
party (usually without giving the opposition the same chance) have
increased the communication channels between the executive and the
legislature. The power of modern party machines and organisations
with their decision centres outside of the two strongest powers, execu-
tive and legislative, put the old liberal model of parliamentarism even
more into question.
Measured by the ideals of classical parliaments of local elites, the
decline of parliamentary sovereignty seems to be a critical occurrence,
though recent research on interest groups shows that even in the nine-
teenth century the parliamentary plenary assembly was not the only
forum for the settlement of conflicts. The loss of parliamentary power
must not be regarded as purely negative – to some extent it is only the
dark side of the progressive parliamentarisation and democratisation of
numerous areas of state and society. Parliament used to be a loyal and
democratic oasis in the desert of a deeply bureaucratic and elitist
regime; today it has become a democratic centre of power, among
other things, and in the view of most scholars it is still the most vener-
able one.
The loss of parliamentary power has gone hand in hand with the
extension of parliamentary working principles – from parliamentary
diplomacy at the world-wide level down to clubs, societies and
associations that orient themselves towards parliamentary models
in their decision making. Decision by discussion, a principle that
was developed fully in the representative assemblies of Europe,
even penetrates the hierarchical subsystems such as bureaucracies.
Democratisation and pluralisation mean that important debates are
no longer the sole preserve of the parliamentary plenary assembly
and today there are countless discussion, advisory and decision-
making committees.
The reduction in the power of the parliamentary plenary assembly is
partly the price that has been paid for reduction of the oligarchic ten-
dencies of early parliamentarism. This does not mean that there are no
longer oligarchic groups striving to monopolise their areas of compe-
tence. Such groups are present in many areas and are equipped with
numerous powers and their own bureaucracies: in the administration,
in parties, in organisations, in the economy. This elite pluralism makes
it nearly impossible for a single forum – even one as worthy as parlia-
ment – to be the preferred place to argue out conflicts. The parliamen-
tary arena is still one of the most important ones – a focus point for
the conflicts of a pluralistic society.
Many suggestions for parliamentary reform reflect a yearning for the
‘good old days’ when parliaments consisted of local elites. But there
can be no reform to restore the supremacy of that parliament, which –
where it existed at all – existed only in the short historical moment
when the crown could no longer defy the parliamentary majority will,
and the parliamentary majority (in the ivory tower of a parliament
elected by a restricted number of citizens) could make their decisions
fairly independently of the people.
Conclusion 211
7.2 Decline of parliament? The changing functions of

parliamentary democracy
The importance of the four main functions of parliament has changed

constantly. The controlling function has suffered decay while the impor-
tance of the recruiting function has risen. The representation and articu-
lation functions have changed even more than the legislative function.
Parliamentarians have become less removed from their voters in
terms of social structure. What has been called ‘virtual representation’
in early parliaments for those not eligible to vote, in ‘post-parliamen-
tarism’ is true of the social ties between deputies and voters. But people
have adapted to this development and demand less strongly to be repre-
sented by members of the same region, the same sex, the same profes-
sion or the same social class (Chapter 5.1). The influence of voters on
the selection of representatives is still mediated by the parties and their
formal members. Primary elections can undermine the recruitment
function of the parties, among other disadvantages, such as a lower
voter turnout in the general election. Modern democracies are not ruled
according to President Lincoln’s Gettysburg formula of government of
the people, by the people, and for the people. The distance of the repre-
sentatives is compensated by increasing responsiveness and sensibility
to the wishes of the voters. Government for the people in the modern
‘democracy of moods’ has increased rather than decreased.
Nonetheless the deparliamentarisation of democracy is lamented.
This has a domestic political side. At the stage of policy formulation
the practice of expert committees working together with the govern-
ment is growing stronger. In the decision-making arena the govern-
ment is the most important initiator of legislation (Chapter 5.3).
Informal unauthorised initiatives behind the formal initiatives of
advisory boards, constitutional courts or international organisations
are further undermining the part played by parliamentarians in legisla-
tion. The penetration of interest groups into the work of ministers and
parliament has shifted the preparatory work to round tables, extra-
parliamentary committees and working teams. But parliament is not
just a rubber stamp to ratify the decisions of networks outside
parliament. Parliaments – formally the institutional seat of the people’s
sovereignty – represent the framework for the coordination of net-
works of actors from parliamentarians, party strategists, interest
groups, ministry officials and – in federal states – the federal
units. The ‘cosy triangles’ of early American parliamentary studies, 4
composed of parliamentarians, bureaucrats and interest groups, have

become ‘uncosy squares’ since party steering was rediscovered in the
‘legislative Leviathan’. In federal states such as Germany, deparliamen-
tarisation at the Länder level has led to greater participation of the
Länder in the national decision-making process via intergovernmental
decision making. Thus a further actor has been added, making an
‘uncosy pentagon’.
Extension of the judicial review of acts of parliament has also con-
tributed to deparliamentarisation. In no other parliamentary democ-
racy in Europe does the mere threat of the controlling power of the
Constitutional Court being exercised result in as much obedience as in
Germany. Comparative studies show that this aspect of putting politi-
cal–parliamentary decisions before the Constitutional Court is not to
be underestimated. 5 Especially in the new democracies in Eastern
Europe, where the political process is still unconsolidated, the constitu-
tional courts have extended their influence. This is even true of
Russia’s three-quarter presidential system. In the British tradition of
parliamentary sovereignty the idea of an outside institution revising
acts of parliament is especially strange, but nonetheless arrived in
Britain via the European Court.
Without doubt deparliamentarisation is hardly bearable for Britain
because all the processes described above run against the majoritarian
system of a sovereign parliament. In the nineteenth century
Palmerston’s bon mot circulated that the British parliament could do
everything with a one-vote majority except turn a man into a woman.
Even this no longer has to be true: a British parliament could – in a law
recognising legal change of gender after a sex-change operation –
resolve this formerly insoluble problem. If one day in the future a
Europe-wide electoral law is created, it can be expected that the British
system will be no less fragmented than the continental consociational
democracies.
In spite of the tendency towards deparliamentarisation in the area of
domestic policies, parliaments still have important functions. Where
the legislature does not decide as the whole ‘house’ parliamentary
debate has symbolic functions. Symbolic politics, or Bagehot’s
‘dignified parts’, are recognised as important and in many cases cannot
be separated from the ‘efficient parts’ of the centre of decision making.
In the early modern era legislation was viewed as rational machinery.
But it is more similar to an overgrown garden – from time to time it is
necessary to reduce the rank growth to the level prescribed by the con-
stitution. Curbing the institutional growth of subsidiary parliaments
Conclusion 213
and committees is considered as the only way of preventing the

constitutionally authorised decision-making process from moving into
permanent crisis. But this strategy is likely to fail.
There is also a foreign policy reason for the deparliamentarisation of
democracies. In foreign policies a lesser degree of responsiveness is
demanded of the representatives than in domestic policies, where
deputies are increasingly measured according to the responsiveness
towards the voters in certain areas. According to one British MP, ‘they
[the people of my constituency] tell me that every fool could talk
about foreign relations in parliament … but that no one would talk
about their local bus garage if I didn’t do it’. 6 Foreign policy – if it is
not about NATO ‘out-of-area missions’ involving troops from member
states or entry into the European Union – is relatively removed from
the voters. New areas of decision far removed from the voters have
developed, especially as a result of Europeanisation and globalisation.
According to one democracy model highly accepted in the whole of
Europe, parliament is the institutional seat of sovereignty, but at one
level European states have renounced sovereignty: the regional level of
the European Union. Therefore many influences on the legislation of
national parliaments that may be regarded as legitimate are initiated by
the European Union. International politics has always influenced
national parliaments. Half of all legal acts are international treaties.
Often they are voted upon unanimously as even the opposition does
not see a possibility of distinguishing its views on the costs of inter-
national agreements.
The international perspective can be present at the start of a legisla-
tive initiative. Behind the formal initiatives of the Bundestag, its parlia-
mentary groups, the government and the Bundesrat there is often an
informal initiative by an outside actor, in particular the Constitutional
Court or the European Union. In Germany 20 per cent of all laws and
6 per cent of the most important laws are based on initiatives by the
European Union (Chapter 5.3). The figures are probably similar for
other EU countries. Judgements by the European Court are binding on
all countries, although national constitutional courts are fighting to
defend their sovereign rights.
The Maastricht Treaty has increased the number of areas that are
subject to EU rules and legislation. With growing competences at the
EU level, lobbying at that level is likewise growing. 7 National ministers
of agriculture frequently refer protesting farmers directly to the EU and
then claim innocence: ‘I did my utmost for their claims, but unfortu-
nately I was outvoted.’ Meanwhile national parliaments – more than
the executive – have been downgraded to the position of lobbyist.

Paradoxically the democratisation of the European Union has led to
deparliamentarisation at the national level. Until 1979 MEPs were tied
to their national parliaments, but since the introduction of direct elec-
tions this has no longer been the case. However, the European
Parliament does not yet pose a real threat to the national parliaments as
it can only draw up laws when asked to do so by the Commission.
Formally, EU legal acts are passed by the Council of Ministers and not
the European Parliament.
The weakening of the national parliaments is based on the fact that
the EU follows – more so than many national systems – the ideology of
neoliberalism. The EU constantly seeks further integration and this has
led to restrictions in national actions, especially in Germany during the
integration of East Germany. The EU tends to trust the market for the
implementation of its ideas rather than the national governmental
institutions. 8 The latter are often forced to become involved in the
regulation of petty areas they would not have deemed to consider by
themselves, such as the outlawing of the ‘Paternoster’ as a model of
elevator. There are those who suggest that Europe and its institutions
should be reduced to a well-functioning market and that economic
decisions should be completely withdrawn from national parliaments,
but the social state as a domain of the national parliament is still
demanded as a protective institution by the people.
Full integration, where wide areas of social policy are regulated at the
European level, is not yet in sight but continued calls for the retention
of national sovereignty are probable. The French initiative of organis-
ations for the unemployed is probably only the first proof for populist
tendencies for resovereignisation in the area of welfare policies.
Literary works on Europe disagree on the scenario for future develop-
ments. Paradoxically, left-wing authors such as Leibfried and Offe are
interested in greater European integration in the social arena. However,
this is understandable in the light of their belief that the EU is more
capable than national states of neutral politics without consideration
to national structures. One study, contrary to the opinion of numerous
other authors, concludes that party politics plays a very subordinate
role9 in the creation of consensus of the Commission. Mainstream
authors, on the other hand, are of the opinion that distributive social
policies, education and culture should remain in the national domain.
Whichever scenario becomes relevant in the future, there is no doubt
that processes above and below the national systems will limit the
scope of decision making by national parliaments. Only the extent to
which these processes will develop are controversial:
Conclusion 215
• In the process of regionalisation, regional assemblies will try to

strengthen themselves via regional politics at the cost of national
parliaments.
• In the process of Europeanisation, more and more domains of the
national parliaments will be regulated by the EU. This process will
be supported by the activities of the European Court and the
gradual standardisation of the national legal systems.
• In the process of globalisation, a consolation to be had at the
national level is the fact that world-wide organisations such as
the World Trade Organisation and GATT are starting to retaliate to
the EU for what it did to the national decision makers. The room
for manoeuvre of the European organisations is increasingly
limited by global organisation, although only in some arenas.
The debate about which social and political competences the national
parliaments will lose can only be settled by new classifications. Some
point to the impact of the standardisation of industrial-relations
schemes and the codetermination rules. Others differentiate between
‘social regulative’ measures and distributive and redistributive meas-
ures. The first were undoubtedly more Europeanised by the Single
European Act (Articles 100a, 118a). Environmental protection (Title
VII) can also be counted among the social regulative areas that in the
old European Community were limited to intergovernmental coopera-
tion. The incorporation of the workplace environment and health,
consumer and environmental protection have deprived the national
parliaments of important competences.10
Still, there are strong reasons to assume that the most important fea-
tures of the welfare state will continue to be regulated by the national
governments for a long time to come. The US idea of a federation with
far-reaching competences of the member states showed that the ability
to tolerate regional differences is large. In 1990 California paid six
times more to welfare recipients than the poor state of Alabama. If the
old national states did not succeed in homogenising the welfare state
at the state level it is improbable that the EU will succeed in doing so.
It only has 4 per cent of the budgets of all national governments and
less than 1.3 per cent of the gross national product of the EU at its dis-
posal. Regarding the budgetary restrictions, it is improbable that the
member states really want equal distribution of social services among
the member states which have very different levels of development.
Social welfare policy – partly disguised as regional policy of the EU – so
far was not very successful. The bulk of social problems will be dealt
with by the national parliaments also in the future.
The decline of parliaments is discussed in most parliamentary

systems. Cavour, the founder of the Kingdom of Italy, once said that
the worst chambre is preferable to the best antichambre. Even if the
power of the parliamentary chambers declines as a result of the compe-
tition between the deliberative and decision-making bodies at various
levels there is one comfort: the principles of public discussion in cham-
bers are spreading – from local round tables up to the level of world-
wide parliamentary diplomacy.
Notes and References
Introduction
1. Some of these older debates were reproduced in: Arend Lijphart,
Parliamentary versus Presidential Government (Oxford University Press, 1992).
2. Giovanni Sartori, Comparative Constitutional Engineering (London:
Macmillan, 1994).
3. Samuel P. Huntington, The Third Wave. Democratization in the Late Twentieth
Century (Norman: University of Oklahoma Press, 1991), p. 16.
1 Parliamentary government – the rise of a concept

1. Immanuel Kant, Zum Ewigen Frieden, 2. Abschnitt, 1, Definitivartikel;
Benjamin Constant, Cours de politique constitutionnelle, vol. 3 (Paris/Rouen:
Plancher, 1819), p. 60.
2. Frederik Lagerroth, Frihetstidens författning (Stockholm, 1915), p. 711;
Lennart Linnarsson, Riksrådens licentering. En studie i frihetstidens parlamen-
tarism (Uppsala: Almqvist & Wiksell, 1943), p. 51ff; S. J. Boëthius, Om
statslivet (Stockholm, 1916), p. 307; Ludwig Stavenow, ‘Frihetstidens parla-
mentarism och vår egen tid’, Svensk tidskrift, 1916 (173–82), pp. 175, 181;
Axel Brusewitz, ‘Frihetstiden som avskröckande exempel’, Forum, no. 27
(1919) p. 322, col. 3.
3. Juan Donoso Cortés, Obras completas, vol. 2 (Madrid: BAC, 1946), p. 576.
4. Henry G. Grey, Parliamentary Government (London, 1858), p. 21;
‘Parliamentary Government’, Edinburgh Review, vol. 108 (1858) (271–97),
p. 285 (Grey’s review).
5. Robert Mohl, ‘Uber die verschiedene Auffassung des repräsentativen
Systems in England, Frankreich und Deutschland’, Staatsrecht, Völkerrecht
und Politik, vol. 1 (Tübingen, 1860, reprint: Graz: Akademische
Verlagsanstalt, 1960, pp. 33–65). For the history of terminology: Klaus von
Beyme, Die parlamentarischen Regierungssysteme in Europa, 2nd edn (Munich:
Piper, 1973), p. 34ff.; Hans Boldt, ‘Parlamentarismustheorie. Bemerkungen
zu ihrer Geschichte in Deutschland’, Der Staat (1980), pp. 384–412; Hans
Boldt, ‘Parlament, parlamentarische Regierung, Parlamentarismus’, in Otto
Brunner et al. (eds), Geschichtliche Grundbegriffe. Historisches Lexikon zur
politisch-sozialen Sprache in Deutschland (Stuttgart: Klett-Cotta, 1978), vol. 4,
pp. 649–76.
6. Paul Bastid, Le gouvernement d’assemblée (Paris: Editions Cujas, 1956), p. 7.
7. Robert Redslob, Die parlamentarische Regierung in ihrer wahren und in ihrer
unechten Form (Tübingen: Mohr, 1918); Leo Wittmayer, Die Weimarer
Reichsverfassung (Tübingen, Mohr, 1922), p. 314; Léon Duguit, Traité de droit
constitutionnel, 2nd edn, vol. 2 (Paris, 1923), p. 62ff.
8. Herbert Döring, ‘Parlamentarismus, Präsidentialismus und Staatstätigkeit’,
Welt Trends, no. 16 (1997), pp. 143–70.
217
218 Notes and References
2 The parliamentarisation of representative government

1. Samuel P. Huntington, The Third Wave. Democratisation in the Late Twentieth
Century (Norman: University of Oklahoma Press, 1991), p. 16.
2. Actas de las Cortes de Cádiz, vol. 1 (Madrid: Taurus, 1964), p. 10.
3. Friedrich Naumann, ‘Reichstagsruhe’, Die Hilfe, 26 (May 1907) p. 323,
col. 2.
4. Mario Mancini and Ugo Galeotti, Norme ed usi del parlamento italiano
(Rome, 1887), p. 489; Hans Ludwig Rosegger, Das parlamentarische
Interpellationsrecht (Leipzig, 1907), p. 44.
5. Léon Muel, Gouvernements, ministères et constitutions de la France depuis cent
ans (Paris, 1890), p. 414.
6. ‘Betaenkning om ministrenes answar for regeringens førelse’ (Betaenkning
no. 312, Copenhagen, 1962), p. 28; Poul Meyer, Ministrenes ansvar, Verdens
gang (Copenhagen: Gyldendal, 1962), pp. 242–6; Lovtidende, (1964),
p. 288: compare Erik Rasmussen, Komparativ politik, vol. 2 (Copenhagen:
Gyldendal, 1969), p. 205f.; Den Danske Riksdag 1849–1949, vol. 2
(Copenhagen: Gyldendal, 1949ff., vol. 2), p. 230.
7. O. Bähr, Der Rechtsstaat (1864); Nachdruck (Aalen: Scientia, 1961), p. 80.
8. Friedrich Julius Stahl, Parlamentarische Reden (Berlin: Hermann Hollstein,
n.d.), p. 15; Heinrich von Treitschke, Historische und politische Aufsätze,
vol. 3 (Leipzig: Hirzel, 1915), p. 505.
9. S. R. Gardiner, The Constitutional Documents of the Puritan Revolution (Oxford
University Press, 1962), p. 6f: J. R. Tanner, English Constitutional Conflicts in
the 17th Century (Cambridge University Press, 1962), p. 59.
10. Friedrich Brockhaus, Das Legitimitätsprinzip (Leipzig, 1868), p. 210; C. D.
von Witzleben, Die Grenzen der Volksrepräsentation in der constitutionellen
Monarchie (Leipzig, 1847), p. 97; Benjamin Constant, Cours de politique con-
stitutionnelle, 8 vols. (Paris: Plancher, 1818–20, vol. 1), p. 86, note 1: Robert
Mohl, Die Verantwortlichkeit der Minister in Einherrschaften mit Volksvertretung
(Tübingen, 1835); Hans von Frisch, Die Verantwortlichkeit der Monarchen und
höchsten Magistrate (Berlin, 1904), pp 13, 55ff.
11. Gunnar Rexius, Studier rörande striden om finansmarkten under Karl XIV Johan
(Uppsala/Leipzig, 1917), p. 75.
12. Debate, Journal officiel de la République Française, vol. 24, no. 4 (1896),
p. 727, col. 2.
13. Georg Jellinek, Ausgewählte Schriften und Reden, vol. 2 (Berlin, 1911) p. 282;
Carl Schmitt, Staatsgefüge und Zusammenbruch des Zweiten Reiches (Hamburg:
Hanseatische Verlagsanstalt, 1934), p. 29; deliberations on the refusal of the
budget in Germany (1848) and Belgium: Stenographischer Bericht über die
Verhandlungen der deutschen constituirenden Nationalversammlung zu Frankfurt
am Main, ed. Wigard, 9 vols (1848/49, vol. 1), p. 405; Émile Huyttens (ed.),
Discussion du congrès national de Belgique 1830–31, 5 vols (Brussels, 1844–5,
vol. 1), pp. 200, 208.
14. The Dutch case: W. J. van Welderen Baron Rengers, Schets eener parlemen-
taire geschiedenis van Nederland, 5 vols (The Hague: Nijhoff, 1948, 5th edn
vol. 1), p. 400f.; E. van Raalte, Het Nederlandse Parlement, 3rd edn (The
Hague: Nijhoff, 1963), p. 20; A. J. Verbrugh, De politieke partijen in
Nederland, 3 vols (Rotterdam: Gronendijk, 1959–63, vol. 3), p. 282.
15. SFIO, 37e congrès national 11–15 August 1945, Paris, p. 11.
16. Alf Kaardtved et al., Det Norske Storting gjenomm 150 år, 4 vols (Oslo:
Gyldendal, 1955, vol. 2), p. 263.
17. Paul Laband, Staatsrecht des Deutschen Reiches, 5th edn (Berlin, 1911,
vol. 2), p. 307.
18. Samhälle och riksdag, 5 vols (Stockholm: Almqvist & Wiksell, 1966/67,
vol. 2), p. 212; Riksdagens protokoll, Andra Kammarens protokoll, no. 46
(1907), p. 19; critique by Kjellén in the upper house: Första kammarens
protokoll, no. 19 (1912), p. 48.
19. Chateaubriand, De La Monarchie selon la Charte (1815), in Mélanges
politiques. Oeuvres complétes, vol. 7 (Paris: Garnier, 1939), p. 158ff.; for
theoretical details see Klaus von Beyme, Die parlamentarischen
Regierungssysteme in Europa, 2nd edn (Munich: Piper, 1973), p. 84ff.
20. Text in Papal Thought on the State (New York: Appleton Century-Crofts,
1958), p. 24.
21. Marx and Engels, Werke (Berlin: Dietz, 1966), p. 160.
22. Klaus von Beyme, Political Parties in Western Democracies (Aldershot: Gower,
1985), p. 31ff.
23. Dieter Nohlen, Wahlrecht und Parteiensystem, 2nd edn (Opladen: Leske &
Budrich, 1990), p. 34.
24. Terry M. Moe and Michael Caldwell, ‘The institutional foundation of demo-
cratic government. A comparison of presidential and parliamentary
systems’, Journal of Institutional and Theoretical Economics, vol. 150 (1994),
pp. 171–95; Arend Lijphart, ‘Constitutional choices for new democracies’,
Journal of Democracy, (1991), pp. 72–84; Klaus von Beyme, Transition to
Democracy in Eastern Europe (London: Macmillan, 1996), p. 96ff.
25. Dieter Nohlen and Mirjana Kasapovic, Wahlsysteme und Systemwechsel in
Osteuropa (Opladen: Leske & Budrich, 1996), p. 45.
26. Arend Lijphart, ‘Democratisation and Constitutional Choices in
Czechoslovakia. Hungary and Poland 1989–1991’, Journal of Theoretical
Politics, vol. 4 (1992), pp. 207–23.
27. Giuseppe Mazzini, ‘Costituente e patto nazionale’, in Mazzini, Scritti.
Politica e economica (Milan: Sonzogno, 1896), p. 364.
28. Archives parlementaires, vol. 30 (1 September 1791), p. 138.
29. Conde de Torreno in Actas de las Cortes de Cádiz, vol. 2 (Madrid: Taurus,
1964), p. 570; Luis Sánchez Agesta, Historia del Constitucionalismo español
(Madrid: Instituto de estudios politicos, 1964), p. 87ff.
30. Hans Meijer, Regeringsformen. 150 årsminnet (Stockholm: Almqvist &
Wiksell, 1959), p. 190ff.; Riksdagsforsamlingens forhandlingar, Teil 3
(Grundlovutkast: Kristiania 1916), see pp. 9ff, 297ff and p. 319ff about the
losses of the king.
31. For Finland see K. J. Ståhlberg, Parlamentarismen i finlands statsförfattning
(Helsinki, 1927), p. 33ff; cf. Klaus von Beyme, Die verfassunggebende Gewalt
des Volkes (Tübingen: Mohr, 1968), p. 21ff; Hugo Preuss in Verhandlungen
der verfassunggebenden deutschen Nationalversammlung, vol. 336 (report of
constitutional committee) (Berlin, 1920), p. 274ff.
32. Cf. Klaus von Beyme, America as a Model: The Impact of American Democracy
in the World (Aldershot: Gower, 1987), p. 33ff.
33. R. J. Chazbulatov, ‘Kakaya vlast’ nuzhna Rossii?’, Sotsiologicheskie issle-

dovaniya, no. 11, 1992 (18–31), p. 26.
34. Francesco de Sanctis, in G. Ferrarelli (ed.), Scritti politici, 4th edn (Naples,
1924), p. 79.
3 The organisational basis of parliamentary sovereignty

1. John C. Calhoun, A Disquisition on Government (New York: Liberal Arts
Press, 1953), p. 35.
2. Thomas Saalfeld, ‘Rational-choice theory in legislative studies. Models of
politics without romanticism’, Journal of Legislative Studies no. 1 (1995),
pp. 32–64; Herbert Döring, ‘Institutions and politics: why we need cross-
national analysis’, in idem (ed.), Parliaments and Majority Rule in Western
Europe (Frankfurt am Main: Campus/NewYork: St. Martin’s Press, 1995), p. 39.
3. Arend Lijphart, Democracies. Patterns of Majoritarian and Consensus
Government in Twenty-One Countries (New Haven, CT: Yale University Press,
1984), pp. 216.
4. Herbert Döring, ‘Parlament und Regierung’, in Oscar Gabriel (ed.), Die EG-
Staaten im Vergleich (Opladen: Westdeutscher Verlag, 1992) pp. 339f., 342.
5. Benjamin Constant, ‘Principes de politiques’, in Oeuvres (Paris: Gallimard,
1957), pp. 1129, 1132ff.; Alexis de Tocqueville, ‘De la démocratie en
Amérique’, in Oeuvres complètes, vol. 1 (Paris: Gallimard, 1961), p. 85.
6. John Stuart Mill, Utilitarianism, Liberty, Representative Government (London:
Dent, 1960), p. 324.
7. Nils Stjernquist, Twåkammer tiden. Sveriges riksdag 1867–1970 (Stockholm:
Sveriges Riksdag, 1996), p. 315.
8. Lijphart, Democracies, op. cit., p. 96.
9. L. S. Amery, My Political Life, vol. 2 (London, 1953), p. 260; G. M. Young,
Stanley Baldwin (London, 1952), p. 49; John W. Wheeler-Bennett, King
George VI: His Life and Reign (London, 1958), p. 444.
10. Peter Bromhead, ‘The Peerage Act and the New Prime Minister’,
Parliamentary Affairs, 1963/64 (57–64) p. 57.
11. Maurice Deslandres, Histoire constitutionnelle de la France de 1789 à 1870, vol. 2
(Paris: Colin, 1933), p. 246; for example Monis 1911, Doumergue 1913,
Poincaré 1922, François-Marsal 1924, Steeg 1930, Laval I 1931, Paul-Boncour
1932, Sarraut I 1933, Laval III 1936 and Sarraut II 1936; Spartaco Cannarsa,
Senato e Camera nei loro rapporti e conflitti 1884–1948 (Rome: Oiss, 1955), p. 91.
12. Robert Urbain, La fonction et les services du premier ministre en Belgique
(Brussels: Institut Belge des Sciences Politiques, 1958), p. 68; J. Th. Ruwe, De
eerste Kamer der Staten-Generaal (Nijmegen, 1957), p. 30.
13. Hans Daalder, Cabinet Reform in Britain 1914–1963 (Stanford Ca: Stanford
University Press, 1963), p. 6; Parliamentary Debates 493 HC, 15.11.1951,
col. 833.
14. Georges Bonnefous, Histoire politique de la IIIe République, vol 4. (Paris: PUF,
1956), p. 372; Jacques Ollé-Laprune, La stabilité des ministres sous la 3e
République 1879–1940 (Paris: LCGJ, 1962), p. 199; A. Shoubagi, La respons-
abilité politique devant les sénats et les chambres hautes (Paris: Thèse, 1932),
p. 55ff.
15. Lord John Russell, The Life and Times of Charles Fox, vol. 2 (London, 1859),
p. 48.
16. Walter Bagehot, The English Constitution (London: World Classics, 1958),
p. 86.
17. See Klaus von Beyme, Die parlamentarischen Regierungssysteme in Europa, 2nd
edn (Munich: Piper, 1973), p. 690ff.; Jacques Chastenet, Le Sénat de la 3e
République RPP, Dec. 1963, p. 18.
18. Léon Duguit, ‘Le sénat et al reponsabilité politique du ministère’, RDPSP,
1896, p. 428f.; Saverio Cilibrizzi, Storia parlamentare, politica, diplomatica
d’Italia, vol. 2 (Milano: Giuffrè, 1923) pp. 282, 584. Criticism against the
rights of the Senate: Assemblea costituente, vol. 3 Commissione per la
Costituzione. (Rome, 1947), p. 103 col. 1.
19. W. C. Costin and J. St. Watson, The Law on Working of the Constitution.
Documents, vol. 2, 2nd edn (London: Oxford University Press, 1961) pp. 22,
36, 121, 146, 404f., 416, 422; Robert Blake, Disraeli (London: Eyre
Spottiswoode, 1966), p. 515; Alan Bullock, The Life and Times of Ernest Bevin,
vol. 1 (London, 1960), p. 459; Parliamentary Debates HC, vol. 582,
col. 416f.; Peter G. Richards, Patronage in British Government (London 1963)
p. 227.
20. L. F. Crisp, Australian National Government (London: Oxford University
Press, 1965), p. 302.
21. AK 1960, N. 57, p. 11 (Staaff), FK 1923, N. 23, p. 40. On the proposals to
restrict votes on the fate of government to the Lower House: FK 1930, 3.
Saml., vol. 2, no. 239, p. 9.
22. Max Weber, ‘Parlament und Regierung’, in Gesammelte politische Schriften
(Tübingen: Mohr, 1958), p. 460.
23. Jörg-Detlev Kühne, ‘Volksvertretungen im monarchischen Konstitution-
alismus (1814–1918)’, in Hans-Peter Schneider and Wolfgang Zeh (eds),
Parlamentsrecht und Parlamentspraxis (Berlin: De Gruyter, 1989), p. 75.
24. Klaus von Beyme, ‘Das Reichstagsgebäude zwischen Repräsentationsfunktion
und den Anforderungen eines Arbeitsparlaments’, in Kulturpolitik und
nationale Identität (Opladen: Westdeutscher Verlag, 1998), p. 238f.
25. Carl Schmitt, Die geistesgeschichtliche Lage des heutigne Parlamentarismus, 3rd
edn (Berlin: Duncker & Humblot, 1961); Jürgen Habermas, Strukturwandel
der Öffentlichkeit, 5th edn (Neuwied: Luchterhand, 1971), p. 76ff.
26. Allan Kornberg and Lloyd D. Musolf (eds), Legislatures in Development
Perspective (Durham, NC: Duke University Press, 1970), p. 26.
27. Jan Sokol, ‘Ostmitteleuropa: ein Prüffeld demokratischer Institutuionen’, in
Uwe Thaysen and Hans Michael Kloth (eds), Wandel durch Repräsentation –
Repräsentation im Wandel. Entstehung und Ausformung der parlamentarischen
Demokratie in Ungarn, Polen, der Tschechoslowakei und der ehemaligen DDR
(Baden-Baden: Nomos, 1992), p. 133.
28. Johan P. Olsen, Organized Democracy: Political Institutions in a Welfare State –
the Case of Norway (Oslo: Universitetsforlaget, 1983), p. 57.
29. Anthony King, ‘How to strengthen legislatures – assuming that we want to’,
in Norman J. Ornstein (ed.), The Role of Legislatures in Western Democracies
(Washington DC: AEI, 1981), p. 85, Bernard Crick, The Reform of Parliament
(Garden City, NY: Doubleday, 1964), p. 78ff.
30. Peter Esaiasson and Sören Holmberg, Representation from Above: Members of
Parliament and Representative Democracy in Sweden (Aldershot: Dartmouth,
1996), p. 279.
31. G. Cox and M. D. McCubbins, Legislative Leviathan. Party Government in the

House. (Berkeley, CA: University of California Press, 1993).
32. Andrew Hill and Anthony Whichelow, What’s Wrong with Parliament?
(Harmondsworth: Penguin, 1964), p. 65f.; Thomas Saalfeld, Das britische
Unterhaus 1965 bis 1986 (Frankfurt: Lang, 1988), p. 78f.
33. David Solomon, The People’s Palace: Parliament in Modern Australia
(Melbourne University Press, 1986), pp. 69, 75.
34. Steven S. Smith and Christopher J. Deering, Committees in Congress
(Washington, DC: Congressional Quarterly, 1984).
35. Cf. Andrea Manzella, II Parlamento (Bologna: Il Mulino, 1977), p. 317ff.
36. David Arter, ‘The Swedish Riksdag: the case of a strong policy-influencing
assembly’, West European Politics, vol. 13, no. 3 (1990), p. 123.
37. Norton, 1990; p. 145.
38. Magnus Isberg, The First Decade of the Unicameral Riksdag (Stockholm:
Statsvetenskapliga institutionen, 1982), p. 22.
39. Klaus von Beyme, Der Gesetzgeber, Der Bundestag als Entscheidungszentrum
(Opladen: Westdeutscher Verlag, 1997), p. 244ff.
40. Bo Bjurulf, A Dynamic Analysis of Scandinavian Roll-Call Behaviour (Lund:
Studentlitteratur, 1974), p. 63.
41. Parliaments of the World, vol. 2 (Aldershot: Gower, 1986), p. 961; Ingvar
Mattson and Kaare Strom, ‘Parliamentary committees’, in Döring,
Parliaments, op. cit., p. 260ff.
42. Philip Norton, ‘Legislatures in perspective’, West European Politics, vol. 13,
no. 3 (1990), p. 145; on the debate of committee reform: Specialist
Committees in the British Parliaments (London: PEP, 1976), pp. 1, 33.
43. John D. Lees and Malcolm Shaw (eds), Committees in Legislatures: A
Comparative Analysis (London: Martin Robertson, 1979).
44. Jean-Claude Masclet, Le rôle du député et ses attachés institutionnelles sous la
Ve République (Paris: LGDJ, 1979), p. 266ff.
45. For Israel: See Gregory S. Mahler, The Knesset (London: Associated
University Press, 1981), p. 183.
46. Erwin K. and Ute Scheuch, Cliquen, Klüngel und Karrieren (Reinbek: Rowohlt,
1992).
47. Gudmund Hernes, Interest, Influence and Cooperation. A Study of the
Norwegian Parliament, PhD thesis, Johns Hopkins University, 1971, p. 352;
von Beyme, Der Gesetzgeber, op. cit., p. 188ff.
48. Attila Ágh and Gabriella Honszki (eds), Parliaments and Organised Interests:
Second Steps (Budapest: Hungarian Center for Democracy Studies, 1996),
p. 329.
49. Cf. von Beyme, Der Gesetzgeber, op. cit., p. 195; Parliaments, op. cit., p. 654.
50. Parliaments, op. cit., p. 678.
51. Esaiasson and Holmberg, Representation from Above, op. cit., p. 267.
52. David Arter, The Nordic Parliaments (London: Hurst, 1984), p. 207.
53. Von Beyme, Der Gesetzgeber, op. cit., p. 222.
54. David Coombes and S. A. Walkland, Parliaments and Economic Affairs (London:
Heinemann, 1980), p. 227; von Beyme, Der Gesetzgeber, op. cit., p. 313ff.
55. Ulrike Liebert, Modelle demokratischer Konsolidierung. Parlamente und organ-
isierte Interessen in der Bundesrepublik Deutschland, Italien und Spanien
1948–1990 (Opladen: Leske & Budrich, 1995), p. 349.
56. Franz Urban Pappi et al., Entscheidungsprozesse in der Arbeits- und Sozialpolitik
(Frankfurt: Campus, 1995).
57. Ingvar Mattson and Kaare Strøm, ‘Parliamentary committees’, in Herbert
Döring (ed.), Parliaments and Majority Rule in Western Europe (Frankfurt:
Campus/New York: St. Martin’s Press, 1995), p. 303.
58. Arter, ‘The Swedish Riksdag’, op. cit., p. 129.
59. Gabriele Rutschke, Die Mitwirkung der Fraktionen bei der parlamentarischen
Willensbildung im Europäischen Parlament im Vergleich zu den Parlamenten der
Mitgliedstaaten (Frankfurt: Lang, 1986), p. 17.
60. Cf. Emil Hübner and Heinrich Oberreuter, Parlament und Regierung. Ein
Vergleich dreier Regierungssysteme (Munich: Ehrenwirth, 1977), p. 48f;
Antoine Santschy, Le droit parlementaire en Suisse et en Allemagne (Neuchâtel:
Ides et calendes, 1982), p. 188.
61. David Solomon, The People’s Palace: Parliaments in Modern Australia
(Melbourne University Press, 1986), p. 88.
62. U. Mittmann, Fraktion und Partei: Ein Vergleich von Zentrum und
Sozialdemokratie im Kaiserreich (Düsseldorf: Droste, 1976), p. 123.
63. Jean Blondel, ‘Toward a systematic analysis of government–party relation-
ships’, International Political Science Review (1995), p. 132.
64. Hans-Dieter Klingemann et al., Parties, Policies and Democracy (Boulder, CO:
Westview, 1994), p. 240ff.
65. Cf. Klaus von Beyme, Die politische Klasse im Parteienstaat, 2nd edn
(Frankfurt: Suhrkamp, 1995).
66. Ulrike Liebert and Maurizio Cotta (eds), Parliament and Democratic
Consolidation in Southern Europe (London: Pinter, 1990), p. 254.
67. Cox and McCubbins, Legislative Leviathan, op. cit.
68. Jean Claude Colliard, Les régimes parlementaires contemporains (Paris: Presses
de la fondation nationale des science politiques, 1978), p. 3.
69. Anthony King, British Members of Parliament: A Self-Portrait (London:
Macmillan, 1974), p. 101.
70. David Solomon, Inside the Australian Parliament (Hornsby: Allen & Unwin
Australia, 1978), p. 43; A. H. Hanson and Bernard Crick (eds), The Commons
in Transition (London: Fontana-Collins, 1970), p. 107; Marcelo Jenny and
Wolfgang C. Müller, ‘Neutral chairman of assets of the majority?’, in Döring,
Parliaments, op. cit., pp. 326–64; Kenneth Bradshaw and David Pring,
Parliament and Congress (Austin: University of Texas Press, 1972), p. 28.
71. Robert L. Peabody, ‘Legislative leadership’, in Gerhard Loewenberg et al.
(eds), Handbook of Legislative Research (Cambridge MA: Harvard University
Press, 1985), p. 259; William O. Aydelotte (ed.), The History of Parliamentary
Behavior (Princeton NJ: Princeton University Press, 1977), p. 6.
72. D. Melnish and P. Cowley, ‘Wither the new role in policy-making?
Conservative MPs in standing committees 1979 to 1992’, Journal of
Legislative Studies, vol. 1, no. 4 (1995), pp. 54–75.
73. Isberg, The First Decade, op. cit., p. 11; von Beyme, Der Gesetzgeber, op. cit.,
p. 287.
74. Solomon, The People’s Palace, op. cit., p. 78.
75. Roland Cayrol et al., ‘French deputies and the political system’, Legislative
Studies Quarterly, vol. 1, no. 1 (1976), p. 79.
76. Cf. von Beyme, Der Gesetzgeber, op. cit., p. 244ff.
77. Ibid., p. 284; Mogens Pedersen, ‘Consensus and conflict in the Danish
Folketing’, Scandinavian Political Studies, no. 4 (1967), p. 144; Jean-Yves
Cherolt, Le Comportement parlementaire (Paris: Economica, 1984), p. 13;
Philip Norton, Dissension in the House of Commons (London: Macmillan,
1975), p. 609; Pierre Avril and Jean Gicquel, Droit parlementaire (Paris:
Montchrestien, 1988), p. 79.
78. Gerhard Loewenberg, Parlamentarismus im politischen System der
Bundesrepublik Deutschland (Tübingen: Wunderlich, 1969), p. 422.
79. J. E. Schwarz and L. E. Shaw, The United States Congress in Comparative
Perspective (Hinsdale, Ill.: Dryden Press, 1976); M. A. Hechter, Principles of
Group Solidarity (Berkeley, CA: University of California Press, 1987).
80. Denis van Mechelen and Richard Rose, Patterns of Parliamentary Legislation
(Aldershot: Gower, 1986), p. 58.
81. Thomas Saalfeld, Parteisoldaten und Rebellen. Fraktionen im Deutschen
Bundestag 1949–1990 (Opladen: Leske & Budrich, 1995) p. 169; Hechter,
Principles, op. cit., p. 80.
82. Von Beyme, Der Gesetzgeber, op. cit., p. 283.
83. Thomas Saalfeld, ‘On dogs and whips: recorded votes’, in Herbert Döring
(ed.), Parliaments and Majority Rule in Western Europe (Frankfurt: Campus
New York: St. Martin’s Press, 1995).
84. Ibid., p. 561.
85. Herbert Döring, ‘Parlamentarismus, Präsidentialismus und Staatstätigkeit’,
Welt Trends, vol. 16 (Autumn 1997), pp. 143–70.
86. Damgaard in : Döring p. 323.
87. Stephen K. Medvic and Silvio Lenart, ‘The influence of political consultants
in the 1992 Congressional Elections’, Legislative Studies Quarterly,
vol. 20, p. 61–77.
88. Pierre Birnbaum et al., Réinventer le parlement (Paris: Flammarion, 1977),
p. 35.
4 Functions of parliaments
1. Walter Bagehot, The English Constitution (London: Oxford University Press,
1958), p. 117ff.
2. Hanna F. Pitkin, The Concept of Representation (Berkeley, Ca: University of
California Press, 1967), p. 236.
3. Eric Voegelin, Die neue Wissenschaft der Politik (München: Pustet, 1959),
p. 54ff.
4. Max Weber, Wirtschaft und Gesellschaft (Tübingen: Mohr, 1956), pp. 171,
172.
5. Edmund Burke, The Works, vol. 1 (London: Henry Bohn, 1864), p. 447.
6. Eberhard Schmitt, Repräsentation und Revolution. Eine Untersuchung zur
Genesis der kontinentalen Theorie und Praxis parlamentarischer Repräsentation
(Munich: Beck, 1969), p. 33ff; Heinz Rausch, ‘Repräsentation. Wort. Begriff.
Kategorie. Prozeß. Theorie’, in Karl Bosl (ed.), Der moderne Parlamentarismus
und seine Grundlagen in der ständischen Repräsentation (Berlin: Duncker &
Humblot, 1977), pp. 69–98.
7. Gerhard Loewenberg and Chong Lim Kim, ‘Comparing the representatives
of parliaments’, Legislative Studies Quarterly, vol. 3, (1978), pp. 27–49.
8. Heinz Eulau and John C. Wahlke, The Politics of Representation (Beverly

Hills, CA: Sage, 1978), p. 119.
9. Guiseppe DiPalma, Surviving Without Governing. The Italian Parties in
Parliament (Berkeley, CA: University of California Press, 1977), p. 163.
10. Philip Norton, The Commons in Perspective (Oxford: Martin Robertson,
1981), p. 59ff. Di Palma, Surviving Without Governing, op. cit., p. 163.
11. Peter Esaiasson and Sören Holmberg, Representation from Above: Members of
Parliament and Representative Democracy in Sweden (Dartmouth: Aldershot,
1996), pp. 53ff., 3: Sören Holmberg, Riksdagen representerar svenska folket
(Lund: Studentlitteratur, 197).
12. Norton, The Commons, op. cit., p. 55.
13. Pierre Birnbaum et al., Réinventer le parlement (Paris: Flammarion, 1977),
p. 90.
14. Jean-Claude Masclet, Le rôle du député et ses attachés institutionelles sous la Ve
République (Paris: LGDJ, 1979), p. 263.
15. Datenhandbuch zur Geschichte des Deutschen Bundestages 1983 bis 1991 (Baden-
Baden: Nomos, 1994), p. 288ff.
16. Essaiasson and Holmberg, Representation from Above, op. cit., p. 31; Henry
H. Kerr, Parlement et société en Suisse (Saint-Saphorin: Georgi, 1981), p. 42.
17. Joan Rydon, A Federal Legislature. The Australian Commonwealth Parliament
1901–1980 (Melbourne: Oxford University Press, 1986), pp. 199, 201.
18. Warren E. Miller and Donald E. Stokes, ‘Constituency influence in
Congress’, American Political Science Review, vol. 57 (1963), pp. 45–56; Eulau
and Wahlke, The Politics, op. cit., p. 214.
19. Birnbaum et al., Réinventer le parlement, op. cit., 30.
20. David Arter, ‘The Swedish Riksdag: the case of a strong policy-influencing
assembly’, West European Politics, vol. 13, no. 3 (1990), p. 121.
21. Dietrich Herzog et al., Abgeordnete und Bürger. Ergebnisse einer Befragung der
Mitglieder des 11. Bundestages und der Bevölkerung (Opladen: Westdeutscher
Verlag, 1990), p. 56f.
22. Klaus Armingeon, ‘Die Bundesregierung zwischen 1949 and 1985. Eine
Forschungsnotiz über Ausbildung und Beruf der Mitglieder der
Bundeskabinette in der Bundesrepublik Deutschland’, Zeitschrift für
Parlamentsfragen (1986), pp. 25–40; Thomas Leif et al. (eds), Die politische
Klasse in Deutschland (Bonn: Bouvier, 1992), p. 180.
23. A. Panebianco, Modelli di partito (Bologna: Il Mulino, 1982), p. 431.
24. Eulau and Wahlke, The Politics, op. cit., p. 215.
25. Hermann Schmitt, Neue Politik in alten Parteien (Opladen: Westdeutscher
Verlag, 1982); Bernhard Weßels, ‘Politische Repräsentation als Prozeß
gesellschaftlich-parlamentarischer Kommunikation’, in Dietrich Herzog et
al. (eds), Parlament und Gesellschaft (Opladen: Westdeutscher Verlag, 1993),
p. 111.
26. Loewenberg and Patterson, op. cit., p. 169.
27. Bernard Crick, The Reform of Parliament (Garden City, NY: Doubleday,
1964), p. 76.
28. Wilfried Dewachter, Afscheid van het laateste dubbelparlement (Löwen: Acco,
1997), p. 230.
29. J. Stimson et al., ‘Dynamic Representation’, American Political Science Review,
vol. 89 (1995), pp. 543–65.
30. K. von Beyme, The Legislator: German Parliament as a Center of Political

Decision Making (Aldershot: Ashgate, 1998), p. 20ff.
31. L. Ragsdale, ‘Disconnected politics: public opinion and presidents’, in
B. Norrander and C. Wilcox (eds), Understanding Public Opinion (Washington,
DC: Congressional Quarterly Press, 1997), p. 229f.
32. Sören Holmberg, ‘Dynamic opinion representation’, Scandinavian Political
Studies, vol. 20, no. 3 (1997), p. 267.
33. Peter Gerlich and Karl Ucakar, Staatsbürger und Volksvertretung. Das
Alltagsverständnis von Parlament und Demokratie in Österreich (Salzburg:
Neugebauer Verlag, 1981), p. 126.
34. Von Beyme, The Legislator, op. cit., p. 24.
35. Essaiasson and Holmberg, Representation from Above, op. cit., p. 280.
36. Bernhard Wessels, ‘Politische Repräsentation als Prozeß gesellschaftlich-
parlamentarischer Kommunikation’, in Herzog et al., Abgeordnete und Bürger,
op. cit., p. 109.
37. Norbert Gehrig, Parlament – Regierung – Opposition. Dualismus als Voraussetzung
für eine parlamentarische Regierung (München: Beck, 1969), p. 308.
38. Arendt Lijphart, Democracies. Patterns of Majoritarian and Consensus
Government in Twenty-One Countries (New Haven. CT: Yale University Press,
1984), p. 189.
39. Peter Gerlich, Parlamentarische Kontrolle im politischen System (Vienna:
Springer, 1973), p. 330.
40. Von Beyme, The Legislator, op. cit., 1998, p. 24ff.
41. Bagehot et al., The English Constitution (1867) (London: Oxford University
Press, 1958), p. 120.
42. Roland Sturm, Haushaltspolitik in westlichen Demokratien (Baden-Baden:
Nomos, 1989), p. 330.
43. Mark Franklin and Philip Norton, Does Parliament Matter? (New York:
Harvester Wheatsheaf, 1993), p. 112.
44. Jean Claude Masclet, Le rôle du député et ses attachés institutionelles sous la Ve
République (Paris: LGDJ, 1979), p. 213.
45. Matti Wiberg, ‘Parliamentary questioning: control by communication?’ in
Döring, op. cit., p. 215. Matti Wiberg and Antti Koura, ‘The logic of parliamen-
tary questioning’, in Matti Wiberg (ed.), Parliamentary Control in the Nordic
Countries (Turku: Finnish Political Science Association, 1994) pp. 19–43, 357–64.
46. Parliaments of the World, op. cit., p. 1148.
47. Samuel E. Finer, ‘The individual responsibility of ministers’, in Geoffrey
Marshall (ed.), Ministerial Responsibility (Oxford University Press, 1989),
pp. 119, 121.
48. Datenhandbuch, op. cit., p. 464f.
49. Philip Norton, ‘Government defeats in the House of Commons: myth and
reality’, in Marshall, Ministerial Responsibility, op. cit., pp. 33–45.
50. Jordi Capo Giol, La Institucionalización de las Cortes Generales (Barcelona:
Universidad de Barcelona, 1983), p. 67.
51. Hans Maier et al., Zum Selbstverständnis des fünften Deutschen Bundestages
(Bonn: Bonner Universitätsdruckerei, 1969), p. 19; Herzog, Abgeordnete und
Bürger, op. cit., 1990, p. 121.
52. Specialist Committees in the British Parliament, London: PEP, 1976), p. 2.
53. Von Beyme, The Legislator, op. cit., p. 25.
54. Ingeborg E. Schäfer, Bürokratische Macht und demokratische Gesellschaft.

Kontrolle der öffentlichen Verwaltung – ein internationaler Vergleich (Opladen:
Leske & Budrich, 1994), p. 113.
55. Herbert Döring, ‘Parlamentarische Konflikte in Westeuropa’, Aus Politik und
Zeitgeschichte, vol. 27ff (1996), pp. 3–19.
56. Dewachter et al., Afschied, op. cit., p. 233.
57. Udo Kempf, Von De Gaulle bis Chirac. Das politische System Frankreichs
(Opladen: Westdeutscher Verlag, 1997), pp. 74, 76.
58. Jean Chariot, La politique en France (Paris: Fallois, 1994), p. 19.
59. S. A. Walkland, The Legislative Process in Great Britain (London: Allen &
Unwin, 1968), p. 44.
60. Von Beyme, The Legislator, op. cit.; David Hine, Governing Italy (Oxford:
Clarendon, 1993), p. 177.
61. Von Beyme, The Legislator, op. cit., p.35; Annette E. Töller, Europapolitik im
Bundestag (Frankfurt: Lang, 1995), p. 47.
62. Döring, op. cit., p. 594.
63. S. A. Walkland and Michael Ryle (eds), The Commons Today, 2nd edn
(London: Fontana, 1981), p. 137.
64. Di Palma, Surviving Without Governing, op. cit., p. 46.
65. Paul Silk and Rhodri Walter, How Parliament Works (London: Longman,
1987), p. 114ff.
66. Ludger Helms, Wettbewerb und Kooperation. Zum Verhältnis von
Regierungsmehrheit und Opposition im parlamentarischen Gesetzgebungsverfahren
in der Bundesrepublik Deutschland Großbritannien und Österreich (Opladen:
Westdeutscher Verlag, 1997), p. 208.
67. Ibid., p. 211.
68. Rudy B. Andeweg and Lia Nijzink, ‘Beyond the two-body image. Relations
between ministers and MPs’, in Döring, op. cit., p. 57.
69. Di Palma, Surviving Without Governing, op. cit., pp. 64, 138.
70. Markus M. L. Crepaz, ‘Consensus versus majoritarian democracy. Political
institutions and their impact on macroeconomic performance and indus-
trial disputes’, Comparative Political Studies, vol. 29, no. 1 (1996), pp. 4–26.
71. Arend Lijphart, ‘Democracies: forms, performance and constitutional en-
gineering’, European Journal of Political Research, vol. 28 (1994), pp. 1–17.
72. Silk and Walters, How Parliament Works, op. cit., p. 117.
73. Matti Wiberg, ‘Law production in Finland. Strategic considerations’, in
Matti Wiberg (ed.), Rationality in Institutions (Turku: University of Turku,
1994), p. 236.
74. John D. Huber, ‘Restrictive legislative procedures in France and the
United States’, American Political Science Review, vol. 86, no. 3 (1992),
pp. 675–87.
75. Mikko Mattila, ‘From quantified majority to simple majority: the effects of
the 1992 change in the Finnish constitution’, Scandinavian Political Studies,
vol. 20, pp. 331–43.
76. Ernst Fraenkel, ‘Die repräsentative und die plebiszitäre Komponente im
demokratischen Verfassungsstaat’, in Deutschland und die westlichen
Demokratien (Stuttgart: Kohlhammer, 1964), pp. 72, 18; David Butler and
Austin Ranney (eds) Referendums. A Comparative Study of Practice and Theory
(Washington, DC: AEI, 1978), p. 57f., 127f.
77. David Butler and Austin Ranney (eds), Referendums around the World: The
Growing Use of Direct Democracy (London: Macmillan, 1994). Thomas E.
Cronin, Direct Democracy: The Politics of Initiative, Referendum and Recall
(Cambridge, MA: Harvard University Press, 1989); Wolfgang Luthardt,
Direkte Demokratic. Ein Vergleich in Westeurope (Baden-Baden, 1994); Silvano
Möckli, Direkte Demokratie (Bern: Haupt, 1994); Günther Rüther (ed.),
Repräsentative oder plebiszitäre Demokratie – eine Alternative? (Baden-Baden:
Nomos, 1996).
78. Gordon Smith, ‘The functional properties of the referendum’, European
Journal of Political Research, vol. 4 (1976): Lijphart, Democracies, op. cit.,
p. 203.
79. Hine, Governing Italy, op. cit., p.153f.
80. Paolo Beretta, ‘II referendum abrogativo negli sviluppi della prassi’, Quaderni
costituzionali, vol. 5, no. 2 (1985), p. 390.
81. Eric S. Einhorn and John Logue, ‘Restraining the Governors: The Nordic
Experience with Limiting the Strong State’, Scandinavian Political Studies,
no. 1 (1988), pp. 15–67.
82. Leonard Neidhart, Plesbizit und pluralitäre Demokratie (Bern: Haupt, 1970);
Hans Werder, Die Bedeutung der Volksinitiative in der Nachkriegszeit (Bern:
Haupt, 1978), p. 158.
83. Klaus G. Troitzsch, Volksbegehren und Volksentscheid (Meisenheim: Hain,
1979), p. 118f.
84. Vernon Bogdanor, The People and the Party System: The Referendum and
Electoral Reform in British Politics (Cambridge University Press, 1981), pp. 1,
14.
85. Luthardt, Direkte Demokratie, op. cit., p. 83.
86. ‘Voting age of 18 years. Adopted by the Danish Folketing. Rejected by
popular referendum’, Scandinavian Political Studies (1970), pp. 301–5.
87. Butler and Ranney, Referendums, op. cit., p. 234.
88. Uwe Wagschal, ‘Direct democracy and public policy making’, Journal of
Public Policy (1997), vol. 17, no. 3, pp. 233–45.
89. John Stuart Mill, ‘Representative Government (1861)’, in Utilitarianism,
Liberty, Representative Government (London: Dent (Everyman’s Library
No. 482), 1960), p. 234; Bagehot, The English Constitution, op. cit., p. 117.
90. Sergio Fabbrini, ‘Presidents, Parliaments and Good Government’, Journal of
Democracy, vol. 6, no. 3 (1995), p. 135.
91. Luk Holvoet, ‘De stemmingen over het investiturdebat in Kamer en Senaat
(1944–1979)’, in Het Belgisch Parlament – Le Parlement Belge, Res Publica,
vol. 22, nos 1–2 (1980), pp. 35–76.
92. Michael Laver and Kenneth A. Shepsle (eds), Cabinet Ministers and
Parliamentary Government (Cambridge University Press, 1994), pp. 308,
305.
93. Kaare Strøm, Minority Government and Majority Rule (Cambridge University
Press, 1990).
94. Mattei Dogan, ‘How to become a cabinet minister in Italy: unwritten rules
of the political game’, in idem (ed.), Pathways to Power, p. 122f.
95. Silk and Water, How Parliament Works, p. 12.
96. Maurizio Cotta, Classe politica e parlamento in Italia 1946–1976 (Bologna: II
Mulino, 1979), p. 233ff.
97. J. A. Schlesinger, Ambition and Politics (Chicago: Aldine, 1966).

98. James Hacker, Yes Minister. The Diaries of a Cabinet Minister (London,
1990), p. 11.
99. Anthony King, ‘How to Strengthen Legislatures – Assuming That We Want
to’, in Norman J. Ornstein (ed.), The Role of the Legislature in Western
Democracies (Washington, DC: AEI, 1981), p. 80.
100. Jean Blondel and Ferdinand Müller-Rommel (eds), Cabinets in Western
Europe (London: Macmillan, 1998), p. 9.
101. Ibid., p. 11.
102. Mattei Dogan, ‘Career Pathways to the Cabinet in France 1870–1986’, in
Dogan (ed.), Pathways, op. cit., pp. 19–44; Roland Cayrol et al; Le député
français (Paris: Colin, 1973), p. 129ff.
103. M. Knight, The German Executive 1890–1933 (Stanford, CA: Stanford
University Press, 1955).
104. Wolfgang C. Müller et al., ‘“Politische Klasse”, politische Positionselite
und politische Stars’, in Herbert Dachs et al. (eds), Die Politiker. Karrieren
und Wirken bedeutender Repräsentanten der Zweiten Republik (Vienna: Manz,
1995), p. 31.
105. Kempf, Von De Gaulle bis Chirac, op. cit., p. 292.
106. Birnbaum et al., Réinventer le parlement, op. cit., p. 34.
107. Dogan, Pathways, op. cit., p. 115; von Beyme, The Legislator, op. cit., p. 41ff.
108. Maurizio Cotta, ‘Conclusion’, in Jean Blondel and Jean Louis Thiébault
(eds), The Profession of Government Minister in Western Europe (London:
Macmillan, 1991), p. 181.
109. Wilma E. Bakema, ‘The Ministerial career’, in Blondel and Thiébault, The
Profession, op. cit., p. 71; Jean Blondel and Ferdinand Müller-Rommel
(eds), Cabinets in Western Europe (London: Macmillan, 1988), p. 7.
5 The role of the head of state in relation to parliament and

government
1. Walter Bagehot, The English Constitution (1867) (London: Oxford
2. Sir William Blackstone, Commentaries of the Laws of England (1765)
(New York: Strouse, 1892), ch. I.7, p. 80.
3. Woodrow Wilson, Congressional Government (1884), 9th edn (Cleveland:
Meridian Book, 1965), p. 29: cf. Klaus von Beyme, America as a Model (New
York: St. Martin’s Press, 1987), p. 83ff.
4. Werner Kaltefleiter, Die Funktionen des Staatsoberhauptes in der parlamen-
tarischen Demokratie (Cologne: Westdeutscher Verlag, 1970); Jürgen
Hartmann and Udo Kempf, Staatsoberhäupter in westlichen Demokratien
(Opladen: Westdeutscher Verlag, 1989). Recently quoted a lot, but useful
only with regard to presidents in semipresidential systems is Matthew
Soberg Shugart and John M. Carey, Presidents and Assemblies (Cambridge:
Cambridge University Press, 1992).
5. Alexis de Tocqueville, Souvenirs. Oeuvres complétes, vol. 12 (Paris:
Gallimard, 1964), p. 188 (cf. Motto).
6. Walter C. Opello, Portugal’s Political Development (Boulder, CO: Westview,
1985), p. 149.
7. Thomas C. Bruneau and Alex MacLeod, Politics in Contemporary Portugal

(Boulder, CO: Lynne Rienner, 1986), p. 121ff.
8. Jaakko Nousiainen, ‘Bureaucratic Tradition: Semi-presidential Rule and
Parliamentary Government: The Case of Finland’, European Journal of
Political Research, vol. 16 (1988), pp. 221–49.
9. Matthew Soberg Shugart and John M. Carey, Presidents and Assemblies
(Cambridge: Cambridge University Press, 1992), p. 212.
10. Ibid., p. 268.
11. See Klaus von Beyme, Die parlamentarischen Regierungssysteme in Europa, 2nd
edn (Munich: Piper, 1973), p. 367ff, and the literature cited there.
12. Jean-Louis Quermonne, ‘Le cas français: Le président dominant la majorite’,
in Maurice Duverger (ed.), Les régimes sémi-présidentiels (Paris: Presses Univ.
de France, 1986), p. 199ff.
13. Udo Kempf, Von De Gaulle bis Chirac. Das politische System Frankreichs
(Opladen: Westdeutscher Verlag, 1997), p. 68 f.
14. Thomas A. Baylis, ‘Presidents versus Prime Ministers. Shaping Executive
Authority in Eastern Europe’, World Politics, vol. 48 (1996), p. 303.
15. Ted Gurr, ‘The Transformation of the Western State. The Growth of
Democracy, Autocracy and State Power since 1800’, in Alex Inkeles (ed.), On
Measuring Democracy (New Brunswick: Transaction, 1991), pp. 69–104. For a
more recent typology see Klaus von Beyme, Transition to Democracy in
Eastern Europe (Basingstoke: Macmillan, 1996), p. 167.
16. Jean-Jacques Rousseau, Politische Schriften (Paderborn: Schöningh, 1977),
p. 98 f. (Contrat social 2.7).
17. Gaetano Filangieri, La scienza della legislazione (1798), vol. 1 (Catania: La
Magna, 1833), p. 101; Robert von Mohl, ‘Die Abfassung der Rechtsgesetze’
(1862), in idem, Staatsrecht. Völkerrecht und Politik, vol. 2 (Graz:
Akademische Verlagsanstalt 1962), p. 376.
18. John Stuart Mill, Utilitarianism, Liberty, Representative Government (London:
Dent, 1960), p. 237 (ch. 5 of Representative Government).
19. Niklas Luhmann, Rechtssoziologie (Reinbek: Rowohlt, 1972), p. 292.
20. Jaako Nousiainen, The Finnish Political System (Cambridge, Mass.: Harvard
21. Kaare Strøm, Minority Government and Majority Rule (Cambridge: Cambridge
22. Nils Andren, Den klassiska parlamentarismens genombrott i England
(Stockholm: Almqvist & Wiksell, 1947), p. 248 f.
23. See von Beyme, Die parlamentarischen Regierungssystem, op. cit., p. 503f., and
the literature cited there: Philip Viscount Snowden, An Autobiography,
vol. 2 (London Nicholson & Watson 1934), p. 601.
24. Riksdagens protokoll. Första Kammarens protokoll 1923, vol. 2, p. 39.
25. Michel Soulié, La vie politique d’Edouard Herriot (Paris, 1962), p. 271ff.
26. Georges Bonnefous, Histoire politique de la IIle République, 7 vols, 1956ff,
vol. 5 (Paris: PUF), p. 16ff; E. van Raalte, Het Nederlandse Parlement, 3rd edn
(Den Haag: Nijhoff, 1963), p. 24.
27. Peter Haungs, Reichspräsident und parlamentarische Kabinettsregierung
(Cologne: Westdeutscher Verlag, 1968), p. 146ff.
28. Jan Debes, Det norske statsråd 1814–1949 (Oslo: Gyldendal, 1963), p. 186.
29. Dankwart A. Rustow, The Politics of Compromise. A Study of Parties and

Cabinet Government in Sweden (Princeton, NJ: Princeton University Press,
1955), p. 213; Nore Tenow, ‘Den moderna parlamentarismens kris’, Forum
1920, p. 623; Ernst Wigforss, Minnen, vol. 2 (Stockholm, 1951), p. 353.
30. Fritz Poetzsch, ‘Vom Staatsleben unter der Weimarer Verfassung’, in Jahrbuch
des öffentlichen Rechts der Gegenwart 1925, p. 164; cited in W. Hubatsch,
Hindenburg und der Staat (Göttingen: Vandenhoeck & Ruprecht, 1966),
p. 257; Joseph Wirth, Unsere politische Linie im deutschen Volksstaat (Berlin,
1924), p. 104.
31. José Maria Gil Robles, No fué posible la paz (Barcelona: Rialp, 1968), p. 109.
32. Sven Lindman, Studier över Parlamentarismens tillämping i Finland.
1919–1926 (Abo, 1937), p. 182f.
33. Jan Magnus Jansson, Från splittring till samverkan. Parlamentarismen i Finland
(Borga: Söderström, 1992), p. 187.
34. Kingsley Martin, The Crown and the Establishment (London: Hutchinson
1962), p. 60.
35. See von Beyme, Die parlamentarischen Regierungssysteme, op. cit., p. 527.
36. Richard Pares, King George III and the Politician, 2nd edn (Oxford: Oxford
University Press, 1967), pp. 144, 122: cases in von Beyme, Die parlamen-
tarischen Regierungssysteme, op. cit., p. 529, ‘Rapport de la commission
chargée d’émettre un avis motive sur l’application des principes constitu-
tionnels entre eux’, Le Moniteur Belge, 6 Aug. 1949, pp. 7589–600; Ignazio
Tambaro, Del potere esecutivo (Turin, 1910), p. 188; Jan Debes, Det norske
statsrad. 1814–1949 (Oslo: Gyldendal, 1950), p. 131.
37. Luigi Preti, Il governo nella costituzione italiana (Milan: Giuffré 1954), p. 159;
Fausto Cuocolo, Il governo nel vigente ordinamento italiano (Milan: Giuffré,
1959), vol. 1 p. 101; Jürgen Domes, Bundesregierung und Mehrheitsfraktion
(Cologne: Westdeutscher Verlag, 1964), p. 60; Theodor Eschenburg, Zur
politischen Praxis in der Bundesrepublik, vol. 2 (Munich: Piper, 1966), p. 229;
Eberhard Menzel, ‘Ermessensfreiheit des Bundespräsidenten bei der
Ernennung der Bundesminister?’, Die öffentliche Verwaltung, 1965, p. 595;
Hans Schneider, ‘Die Regierungsbildung nach dem Bonner Grundgesetz’,
Neue Juristische Wochenschrift, 1953, p. 1332; cf. von Beyme, Die parlamen-
tarischen Regierungssysteme, op. cit., p. 536 on the cases.
38. R. K. Alderman and J. A. Cross, The Tactics of Resignation (London:
Routledge & Kegan Paul, 1968).
39. See Olof Ruin, ‘Three Swedish Prime Ministers’, West European Politics,
vol. 14, no. 3 (1991), pp. 58–82.
40. Hugo Preuß, Deutschlands republikanische Reichsverfassung, 2nd edn (Berlin,
1923), p. 73; Friedrich Glum, Die staatsrechtliche Stellung der Reichsregierung
sowie des Reichskanzlers und des Reichsfinanzministers in der Reichsregierung
(Berlin, 1925), p. 31; Gustav Stresemann, Vermächtnis: Der Nachlaß in drei
Bänden, vol. 3 (Berlin, 1932), p. 429.
41. J. Th. De Ruwe, De eerste Kamer der Staten-Generaal (Nijmegen, 1957), p. 30.
Press, 1965), p. 268.
43. E. van Raalte, Het Nederlands Parlement, 2nd edn (The Hague: Nijhoff, 1963),
p. 36.
44. Carl-Henrik Höjer, Le régime parlementaire belge de 1918 á 1940 (Uppsala:

Almqvist & Wiksell, 1946), p. 322.
45. Robert Urbain, La fonction et les services du premier ministre en Belgique
(Brussels: Université de Bruxelles, 1958), p. 67.
46. Kaare Strøm, Minority Government and Majority Rule (Cambridge: Cambridge
University Press, 1990), p. 26; for the cases see von Beyme, Die parlamen-
tarischen Regierungssysteme, op. cit., p. 748ff.
47. See von Beyme, ibid., p. 727ff; Jean Massot, Le chef du gouvernement en
France (Paris: La documentation française, 1979), p. 75ff.
48. K. J. Ståhlberg, Parlamentarismen i Finnlands Statsförfattning (Helsingfors,
1927), p. 66f; see also Paavo Kastari, Le présidence de la république en Finlande
(Neuchâtel: Ides et Calendes, 1962), p. 47.
49. Klaus Berchtold, Der Bundespräsident (Vienna: Deuticke, 1969), p. 234.
50. Eugene A. Forsey, The Royal Power of Dissolution of Parliament in the British
Commonwealth (Oxford: Oxford University Press, 1968), p. 73.
51. Dufaure, La dissolution. Discours prononcé á l’assemblée le 14. Déc. 1872.
(Paris, 1872), p. 24.
52. Frede Castberg, Spørsmålet om innforelse av opløsningsrett for kongen (Oslo:
Gyldendal, 1934), p. 22, col. 1.
53. See Karl Leowenstein, Über Wesen.Technik und Grenzen der Verfassungsänderung
(Berlin: de Gruyter, 1961), p. 32.
54. D. J. Heasman, ‘The Monarch, the Prime Minister and the Dissolution of
Parliament’, Parliamentary Affairs, 1960/61, p. 107.
55. For: Paul Reynaud in Journal officiel de la République française, 27 May 1953,
p. 2849; against: Charles Roig, ‘Dissolution automatique et réforme consti-
tutionnelle’, Révue française de science politique. 1964, pp. 459–79.
56. Edvard Thermaenius, Kontrasignationsinstitutet (Lund: Gleerup, 1955), p. 92ff.
57. Frede Castberg, Spørsmälet om innforelse av oplåsningsrett for kongen (Oslo:
Gyldendal, 1934), p. 15.
58. Robert Hermansson, Den senaste riksdagsupplösningen och grundlag, tidskrift
utgiven av Juridiska föreningen i Finland, 1924, p. 65.
59. Sir Ivor Jennings, Cabinet Government (Cambridge: Cambridge University
Press, 1947), p. 313; Chi Kao Wang, Dissolution of British Parliament
1832–1951 (New York, 1934), p. 33ff.
60. Harold Nicolson, King George V (London, 1952), p. 225ff; House of
Commons, 29 March 1944, sp. 1516; G. H. L. Le May, British Government
1914–1963. Select Documents, 2nd edn (London: Methuen, 1964), p. 189;
further cases in von Beyme, Die parlamentarischen Regierungssysteme, op. cit.,
p. 842ff.
61. R. M. Dawson, Constitutional issues in Canada 1900–1931. Documents
(Oxford: Oxford University Press, 1953), p. 73; Eugene A. Forsey, The Royal
Power of Dissolution of Parliament in the British Commonwealth, 2nd edn
(Toronto: Toronto University Press, 1968), pp. 66, 69.
62. Harold Laski, Reflections on the Constitution (London: Macmillan, 1951),
p. 72.
63. Raymond Fusilier, Les monarchies parlementaires (Paris: Editions ouvriéres,
1960), p. 457; Ernest Discailles, Charles Rogier d’aprés des documents inédits,
vol. 3 (Brussels, 1893–95), p. 50f.; von Beyme, Die parlamentarischen,
op. cit., p. 845.
64. Giuseppe Massari, La vita ed il regno di Vittorio Emanuele II di Savoia primo re

d’Italia, vol. 2 (Milan, 1878), p. 292; Leif Kihlberg, Karl Staaff, vol. 2
(Stockholm: Bonniers, 1963), p. 80f.
65. Documents in Huber, vol. 3, pp. 389, 393, 534, 529ff.
66. Costin and Watson, vol. 2, p. 393; Details on the cases in von Beyme, Die
parlamentarischen Regierungssysteme, op. cit., p. 849ff.
67. See von Beyme, ibid., p. 852f.
68. Jacques Velu, La dissolution du parlement (Brussels: Bruylandt, 1966), p. 122.
69. Van Raalte, Het Nederlands Parlement, op. cit., p. 54.
70. Velu, op. cit., p. 284f.
71. Giovanni Schepis, Le consultazioni popolari in Italia dal 1848 al 1957
(Empoli: Caparrini, 1958), p. 7ff.; cf. von Beyme, Die parlamentarischen
Regierungssysteme, op. cit., p. 859f; Jacques Georgel, ‘La dissolution du
2 décembre 1955’, thése, Rennes, 1958, p. 38; Jean-Pierre Harcourt, ‘La dis-
solution de l’Assemblée du 1er décembre 1955’, thése, Caen, 1958.
72. Andra Kammaren, B. 13, nr 17 (1958), p. 77; Björn Molin,
Tjänstepensionsfrågan (Göteborg: Gumperts, 1965), p. 93; Fredrik Sterzel, Om
riksdagsupplösning och nyvalsförordnande (Stockholm: Norstedt, 1961),
p. 111ff.; (1953), Federico Mohrhoff, La dissolution des assemblées législatives
dans les constitutions modernes (1953), pp. 131–5.
73. Frank Eyck, Prinzgemahl Albert von England (Erlenbach: Rentsch, 1961),
p. 32.
74. Velu, op. cit., p. 540.
75. Castberg, op. cit.: 23. Oskar Kraines, Government and Politics in Israel
(Boston: Little, Brown, 1961), p. 35.
6 The government and parliamentary majority

1. Otto Hintze, ‘Die Entstehung der modernen Staatsministerien’ (1907), in
idem, Staat und Verfassung. Gesammelte Abhandlungen zur allgemeinen
Verfassungsgeschichte (Göttingen: Vandenhoeck & Ruprecht, 1962), vol. 2,
p. 276.
2. Richard Pares, King George III and the Politicians (Oxford: Oxford University
Press, 1967), p. 149f.
3. Marchais de Migneaux, De la responsabilité des ministres (Paris, 1818) pp. 41,
89; Pagés, De la responsabilité ministérielle (Paris, 1818) p. 37; Henri Hervieu,
Les ministres (Paris, 1893), p. 194ff.
4. Carl-Henrik Höjer, Le régime parlementaire belge de 1918 á 1940 (Uppsala:
Almqvist & Wiksell, 1946), p. 333.
5. Georg Freiherr von Eppstein, Fürst Bismarcks Entlassungen. Aufzeichnungen
des Staatssekretäars von Boetticher (Berlin, 1920), p. 68f.
6. Ernst-Wolfgang Böckenförde, Die Organisationsgewalt im Bereich der Regierung
(Berlin: Duncker & Humblot, 1964), pp. 99, 291.
7. Ronald Butt, The Power of Parliament (London: Constable, 1967), p. 424.
8. On the development of offices and departmental organisation see Herbert
Tingsten, Regieringsarbetet (SOU, 1938), p. 14; N. Stjernquist, Jahrbuch des
öffentlichen Rechts (1969) vol. 18, p. 269.
9. Bihang till Riksdagens Protokoll no. 239 (1930), 1, p. 13.
10. Annales de l’Assemblée constituante élu le 2 juin 1946, vol. 2 (Paris), p. 3527,
col. 3.
11. Max Ferrand, The Records of the Federal Convention of 1789, vol. 1 (New
Haven, CT: Yale University Press, 1911), p. 65.
12. Annales, op. cit., Annexe 20, p. 27.
13. Maurice Hauriou, Précis de droit constitutionnel (Paris, 1923), p. 461.
14. Mario Mancini and Ugo Galeotti, Norme ed usi del parlamento italiano (Rome,
1887), p. 99; Luigi Palma, ‘Dell’ordinamento del potere esecutivo’, in
Questioni costituzionali (Florence, 1985), p. 278.
15. Henry Leyret, Le gouvernement et le parlement (Paris, 1919), p. 74.
16. Eberhard Menzel, Ermessensfreiheit des Bundespräsidenten bei der Ernennung
der Bundesminister? Die Öffentliche Verwaltung (1965), p. 594.
17. Livio Minguzzi, Governo di gabinetto e governo presidenziale, 2nd edn
(Bologna: Zanichelli, 1886), p. 254.
18. P.-J. Proudhon Théorie du mouvement constitutionnel au XIXe siécle. L’Empire
parlementaire et l’opposition légale (Paris, 1870), p. 221.
19. G. W. Jones, ‘The Prime Minister’s Power’, Parliamentary Affairs, no. 2
(1965), pp. 167–85; Anthony King (ed.), The British Prime Minister (London:
Macmillan, 1969), p. 209; Hans Daalder, Cabinet Reform in Britain.
1914–1965 (Stanford, Ca: Stanford University Press, 1963), p. 24.
20. Felix von Eckardt, Ein unordentliches Leben (Düsseldorf: Econ, 1967), p. 439.
21. Joseph La Palombara, Interest Groups in Italian Politics (Princeton, NJ:
Princeton University Press, 1964), p. 114.
22. Daalder, Cabinet Reform, op. cit., p. 301; Winston S. Churchill, Memoirs. The
Second World War, vol. 2: Their Finest Hour (Boston: Houghton-Mifflin,
1948).
23. Jean Blondel, The Organization of Governments (London: Sage, 1982), p. 220.
24. Jaakko Nouisiainen, ‘Bureaucratic tradition, semi-presidential rule and
parliamentary government: the case of Finland’, European Journal of Political
Research, vol. 6 (1988), pp. 229–49.
25. Thomas A. Baylis, Governing by Committee. Collegial Leadership in Advanced
Society (New York: State University of New York Press, 1989), p. 158f.
26. Francis Williams, A Prime Minister Remembers (London: Heinemann, 1961),
p. 82.
27. Jean-Louis Thiébault, ‘The Organisational Structure of Western European
Cabinets and its Impact on Decision-Making’, in Jean Blondel and
Ferdinand Müller-Rommel (eds), Governing Together. The Extent and Limits of
Joint Decision-Making in Western European Cabinets (New York: St Martin’s
Press, 1993), p. 84, Table 4.1.
28. Peter C. Hartmann (ed.), Französische Könige und Kaiser der Neuzeit (Munich:
Beck, 1994), pp. 176, 211.
29. Werner von Beyme, Carl Friedrich von Beyme (Berlin: Stapp, 1987), p. 33.
30. E. Bezold (ed.), Materialien der Deutschen Reichsverfassung, vol. 3 (Berlin,
1873), p. 1194; Georg Frhr. von Eppstein, Fürst Bismarcks Entlassung.
Aufzeichnungen des Staatssekretärs von Boetticher (Berlin, 1920), p. 76.
31. Graf V. N. Kokovtsev, Iz moego proshlago. Vospominaniya 1905–1919, vol. 2
(Paris, 1933), p. 153.
32. Pierre Avril, Le régime politique de la Ve République, 2nd edn (Paris: Pichon,
Durand-Auzias, 1967), p. 397.
33. Harold Laski, Parliamentary Government in England, 2nd edn (New York:
Viking, 1947), p. 340.
34. Georges Suarez, Briand, 6th edn, vol. 5 (Paris, 1945–52), p. 411; Königin
Victorias Briefwechsel und Tagebuchblätter, 1870–1878 (Berlin, 1926),
p. 213.
35. Clive Bigham, The Chief Ministers of England, 920–1720 (New York, 1923);
W. C. Costin and J. St. Watson, The Law and Working of the Constitution,
vol. 1 (London: Adam & Black, 1961), p. 318; E. N. Williams, The 18th
Century Constitution: Documents (Cambridge: Cambridge University Press,
1960), p. 125; B. E. Carter, The Office of Prime Minister (Princeton, NJ:
Princeton University Press, 1956), p. 19.
36. Williams, The 18th Century Constitution, op. cit., pp. 128, 132.
37. William Viscount Melbourne, Memoirs, ed. W. M. Torrens, vol. 2 (London,
1878), p. 374; G. H. L. LeMay, British Government 1914–1963: Selected
Documents, 2nd edn (London: Methuen 1964), p. 74ff.
38. Paul Bastid, Les institutions politiques de la Monarchie parlementaire française.
1814–1848 (Paris: Sirey, 1954), p. 305ff.
39. Raymond Hayem, Le conseil des Ministres sous Louis-Philippe (Paris: Thése,
1939), p. 55f.: J. Lucas-Dubreton, La manière forte. Casimir Périer et la
Révolution de 1830, 4th edn (Paris, 1929), p. 101.
40. Henri Fonfréde, Du gouvernement du Roi et des limites constitutionnelles de la
prérogative parlementaire (Paris, 1839), p. 137; Étienne Vacherot, La démocra-
tie (Paris, 1860), p. 365.
41. J. Chastenet, Histoire de la 3e République, vol. 1 (Paris, Hachette, 1952),
p. 192; Léon Muel, Gouvernements, ministères et constitutions de la France
depuis cent ans (Paris, 1890), p. 252; Serge Arné, Le président du conseil des
ministres sous la IVe République (Paris: LGJD, 1962), p. 25ff.
42. André Tardieu, La Révolution à refaire, vol. 2 (Paris, 1937), p. 228.
43. Jean Massot, Le Chef du Gouvernement en France (Paris: La documentation
française, 1979), p. 13.
44. Robert Urbain, La fonction et les service du premier ministre en Belgique
(Brussels: Université de Bruxelles, 1958), p. 42.
45. Alberto Predieri, Lineamenti della posizione costituzionale del presidente del
consiglio dei Ministri (Florence: Barbera, 1951), p. 39ff. Gazzetta ufficiale,
no. 87 (Florence, 1867), p. 28, March 1867 (no. 3639, Raccolta uff. delle legge),
p. 1; Gazzetta ufficiale, no. 271, (Nov. 1901) p. 15 (no. 3289 Raccolta), p. 5313.
46. Gunnar Heckscher, Konung och statsråd i 1809 års författning (Uppsala:
Almqvist & Wiksell, 1933), p. 5; Leif Kihlberg, Den Svenska ministären under
ståndsriksdag och tvåkammarsystem intill 1905 års totala ministerskifte
(Uppsala: Almqvist & Wiksell, 1922), p. 536.
47. Louis de Geer, Minnen, vol. 2 (Stockholm, 1892), p. 191; Nils Forssell,
Statsministerämbetets genesis. Statsvet, Tidskrift 1918, p. 190.
48. R. Kranenburg, Het Nederlandse Staatsrecht, 8th edn (Haarlem, 1958), p. 127;
E. van Raalte, De Minister-President (The Hague: Nijhoff 1917) pp. 158, 170;
W. J. von Welderen Baron Rengers, Schets eener parlementaire geschiedenis van
Nederland, 5th edn, vol. 3 (The Hague: Nijhoff, 1948), p. 21.
49. Hintze, ‘Die Entstehung’, op. cit., p. 319.
50. Jones, ‘The Prime Minister’s Power’, op. cit., p. 167ff.
51. Sir John Jennings, Cabinet Government (Cambridge University Press, 1943),
p. 64; letter dated 5 August 1873 in Philip Guedalla (ed.), The Queen and
Mr. Gladstone (Garden City, NY, 1934), p. 421.
52. R. C. Fried, The Italian Prefects: A Study in Administrative Politics (New Haven,
CT: Yale University Press, 1963), p. 122.
53. Hubert Cole, Laval: A Biography (London: Heinemann, 1963), p. 44.
54. Ian Budge and Hans Keman, Parties and Democracy (Oxford: Oxford
University Press, 1990), p. 101f.
55. Louis Hymans, Histoire parlementaire de la Belgique de 1831 á 1880, vol. 1
(Brussels, 1878–1880), p. 535; Ruggero Bonghi, Discorsi parlamentari, vol. 2
(Rome, 1918), pp. 666, 719, Appendix: Crispi, Francesco, Politica interna
(Milan, 1924) p. 187.
56. Wilhelm Hennis, Richtlinienkompetenz und Regierungstechnik (Tübingen:
Mohr, 1964), p. 19; Pierre Chatenet, La situation du premier Ministre anglais
(Paris: Thése, 1937), p. 68ff.; Böckenförde, Die organisations gewalt, op. cit.,
p. 200; Alberto Predieri, Lineamenti della posizione del presidente del consiglio
dei ministri (Florence: Barbera 1951), pp. 39ff).
57. Exceptions are Richard Rose and Ezra N. Suleiman (eds), Presidents and
Prime Ministers (Washington: AEI, 1980); Jean Blondel, Government Ministers
in the Contemporary World (London: Sage, 1985); Jean Blondel and
Ferdinand Müller Rommel, Cabinets in Western Europe (London:
Macmillan, 1988); Jean Blondel and Jean Louis Thiébault (eds), The
Profession of Government Minister in Western Europe (Basingstoke: Macmillan,
1991); G. W. Jones (ed.), West European Prime Ministers (London: Frank
Cass, 1991), Michael Lee, ‘The Ethos of the Cabinet Office: A Comment on
the Testimony of Officials’, in R. A. W. Rhodes and Patrick Dunleavy (eds),
Prime Minister, Cabinet and Core Executive (New York: St. Martin’s Press,
1995), pp. 149–57.
58. Ludger Helms, ‘Executive Leadership in Parliamentary Democracy. The
British Prime Minister and the German Chancellor compared’, German
Politics, vol. 5, no. 1 (1996), pp. 101–20.
59. Patrick Gordon Walker, The Cabinet (London: Heinemann, 1972),
p. 103ff.
60. David Judge, The Parliamentary State (London: Sage, 1993), p. 197.
61. R. H. S. Crossman, Inside View: Three Lectures on Prime Ministerial Government
(London: Jonathan Cape, 1972); H. Berkeley, The Power of the Prime Minister
(London: Allen & Unwin, 1968), p. 83ff.
62. John Hart, ‘President and Prime Minister: Convergence or Divergence?’,
Parliamentary Affairs, vol. 44 (1991), pp. 208–25.
63. Michael Laver and Kenneth A. Shepsle (eds), Cabinet Ministers and
Parliamentary Government (Cambridge: Cambridge University Press, 1994),
p. 308.
64. Kaare Strøm et al., ‘Constraints on Cabinet Formation in Parliamentary
Democracies’, American Journal of Political Science, vol. 38, no. 2 (1994),
p. 332.
65. William Riker, The Theory of Political Coalitions (New Haven, CT: Yale
University Press, 1962), p. 32ff.
66. Mats Sjöllin, Coalition Politics and Parliamentary Power (Lund University
Press, 1993) p. 14ff.; R. Axelrod, Conflict of Interests. A Theory of Divergent
Goals with Applications to Politics (Chicago: Markham, 1970), p. 165ff.; A. de
Swaan, Coalition Theories and Cabinet Formations (Amsterdam: Elsevier,
1973), p. 15.
67. Budge and Keman, Parties and Democracy, op. cit., p. 128.
68. Peter van Rozendaal, Cabinets in Multi-Party Democracies (Amsterdam: Thesis
Publishers, 1992), p. 184; Wilma Bakema, ‘The Ministerial Career’, in
Blondel and Thiébault, The Profession, op. cit., p. 82.
69. Bakema, ibid., p. 82.
70. Anthony Downs, An Economic Theory of Democracy (New York: Harper &
Row, 1957), p. 21.
71. E. Pappalardo, Partiti e governi di coalizione in Europa (Milan: F. Angeli, 1978),
p. 162.
72. G. Mahler and R. J. Trilling, ‘Coalition Behavior and Cabinet Formation.
The Case of Israel’, Comparative Political Studies (1975) vol. 8, pp. 200–33;
Erik Damgaard, ‘Party Coalitions in Danish Law Making 1953–1970’,
European Journal of Political Research (1973), p. 59.
73. E. C. Browne, ‘Testing Theories of Coalitions Formation in the European
Context’, Comparative Political Studies (1970) vol. 3, no. 4, p. 403.
74. Lawrence C. Dodd, Coalitions in Parliamentary Government (Princeton, NJ:
Princeton University Press 1976), p. 208.
75. Jan-Erik Lane and Svante O. Ersson, European Politics (London: Sage, 1996),
p. 141.
76. Klaus von Beyme, Parties in Western Democracies (Aldershot: Gower, 1985),
p. 322ff.
77. Arend Lijphart, Democracies. Patterns of Majoritarian and Consensus
Government in Twenty-One Countries (New Haven, CT: Yale University Press,
1984), p. 62.
78. Klaus von Beyme, Transition to Democracy in Eastern Europe (Basingstoke:
Macmillan, 1996), p. 132ff.
79. Chateaubriand, Du systéme suivi par le ministére (Paris, 1817), pp. 58, 60.
80. Sir Ivor Jennings, Cabinet Government (Cambridge: Cambridge University
Press, 1947), p. 27; Karl Loewenstein, Minderheitsregierung in Großbritannien
(Munich: Beck, 1925).
Press, 1965), p. 197.
82. Henry Valen and Daniel Katz, Political Parties in Norway (Oslo:
Universitetsforlaget, 1964), p. 25ff.
83. Erik Damgaard, ‘The Parliamentary Basis of Danish Governments’,
Scandinavian Political Studies, vol. 4 (1969), p. 32.
84. Van Roozendal, Cabinets, op. cit., p. 158.
85. Strøm, Constraints, op. cit, p. 17.
86. Lawrence C. Dodd, Coalitions in Parliamentary Government (Princeton, NJ:
Princeton University Press, 1976), p. 68ff.
87. C. A. Reuterskiöld, ‘Minoritetsparlamentarism. Några synpunkter’, Tidskrift
for Retsvidenskap (Oslo, 1931), p. 140.
88. Louis Hymans, Histoire parlementaire de la Belgique de 1831 á 1880, vol. 2
(Brussels, 1878–1880), p. 397, col. 2.
89. Giuseppe Ieraci, ‘“Events” and “Causes” in Cabinet Termination and
Survival: Is Explanation Still Possible?’, West European Politics, vol. 19, no. 1
(1996), pp. 51–68.
90. E. N. Williams, The Eighteenth Century Constitutions: Documents and
Commentary (Cambridge: Cambridge University Press, 1960), p. 78.
91. Samuel R. Gardiner, The Constitutional Documents of the Puritan Revolution

1625–1660 (Oxford: Clarendon Press, 1889, reprinted 1932), p. 231.
92. Costin and Watson, The Law, op. cit., p. 217f.
93. Journal officiel, 16 October 1888, p. 2170.
94. Hymans, Histoire parlementaire, op. cit., vol. 1, p. 742, col. 2.
95. Benjamin Constant, ‘Principes de politique’, in Oeuvres (Paris: Pléiade,
1957), p. 44.
96. Émile Laboulaye, Le parti libéral, son programme et son avenir, 2nd edn
(Paris, 1863), p. 189.
97. Heinrich von Treitschke, Historische und politische Aufsätze, 7th edn, vol. 3
(Leipzig: Hirzel, 1915), p. 495.
98. U. Rattazzi, Discorsi parlamentari, vol. 1 (Rome, 1876), p. 331.
99. See Klaus von Beyme, Die parlamentarischen Regierungs-systeme in Europa,
2nd edn (Munich: Piper, 1973), p. 679ff.
100. A. V. Dicey, Introduction to the Study of the Law of the Constitution (1885)
(London: Macmillan, 1962), p. 457.
101. J. Georgel, ‘La révision constitutionnelle. La 4e République à la recherche
d’une politique gouvernemental’ thesis’, Rennes, 1958, p. 112.
102. Hans Friedrich Zacher, Die Erneuerung des parlamentarischen Systems in
Deutschland nach dem 2. Weltkrieg (Munich: Diss, 1952), p. 80.
103. Assemblea costituente, vol. 7, p. 128, col. 1, p. 153, col. 2; numbers in Lane
et al, 1997, p. 123.
104. Cases in von Beyme, op. cit., p. 720ff.
105. Ibid., p. 450ff.
106. Giovanni Sartori, ‘European Political Parties: the Case of Polarised Pluralism’,
in Joseph La Palombara and Myron Weiner (eds), Political Parties and Political
Development (Princeton, NJ: Princeton University Press, 1966), pp. 137–76.
107. André-Paul Frognier, ‘The Single Party/Coalition Distinction and Cabinet
Decision-Making’, in Jean Blondel and Ferdinand Müller-Rommel (eds),
Governing Together. The Extent and Limits of Joint Decision-Making in Western
European Cabinets (New York: St. Martin’s Press, 1993), p. 49.
108. Robert von Mohl, ‘Über die verschiedene Auffassung des repräsentativen
Systems in England, Frankreich und Deutschland’, in idem, Staatsrecht,
Völkerrecht und Politik (1860), vol. 1 (Nachdruck Graz: Akademische
Verlagsanstalt, 1960), p. 429.
109. Karl-Heinz Naßmacher, Das österreichische Regierungssystem (Cologne:
Westdeutscher Verlag, 1968), pp. 40f, 83; Georg Geismann, Politische
Struktur und Regierungssystem in den Niederlanden (Frankfurt: Athenäum,
1964), p. 146ff.
110. David Sanders and Valentine Herman, ‘The Stability and Survival of
Governments in Western Democracies’, Acta Politica, vol. 12 (1977),
pp. 346–77.
111. Sanders and Herman, ‘Stability and Survival’, op. cit., p. 371.
112. Jacques Ollé-Laprune, La Stabilité des ministres sous la 3e République,
1879–1940 (Paris: LGDJ, 1962), p. 244f.
113. André Philippart, Analyse statistique de la stabilité ministérielle en Belgique de
1830 à 1961 (Res Publica, 1962), pp. 275–96; Giovanni Sartori et al.,
Parlamento italiano 1946–1963 (Naples: Edizioni Scientifiche Italiane 1963),
p. 193.
114. Mattei Dogan and Maria Scheffer van der Veen, ‘Le personnel ministériel
hollandais’, L’année sociologique (1957/58), pp. 95–125.
115. Bakema, ‘Ministerial Career’, op. cit., pp. 70–98.
116. Jean Blondel and Ferdinand Müller-Rommel (eds), Cabinets in Western
Europe (Basingstoke: Macmillan, 1988), p. 11ff.
117. David Coombes and S. A. Walkland, Parliaments and Economic Affairs
(London: Heinemann, 1980), p. 228.
118. Klaus von Beyme, ‘Parteien im Prozeß der demokratischen Konsolidierung
der Demokratien Osteuropas’, in Wolfgang Merkel and Everhard
Sandschneider (eds), Systemwechsel 3. Parteien im Transformationsprozess
119. Jean Elleinstein, ‘Le marxisme, la democracie et l’alternance’, in Pouvoirs
no. 1 (1977), p. 74.
120. Richard A. Fenno, The President’s Cabinet (New York: Vintage Books, 1959),
p. 60 f.
121. Jean-François Aubert, ‘Vertus d’un système non-majoritaire’, Pouvoir,
no. 85 (1998), p. 130.
7 Conclusion
1. Wolfgang Merkel, Systemtransformation (Fern Universität Hagen, 1998),
p. 72ff.; Klaus von Beyme, ‘Parteien im Prozeß der demokratischen
Konsolidierung’, in Wolfgang Merkel and Eberhard Sandschneider (eds),
Systemwechsel 3 (Opladen: Leske & Budrich, 1997), pp. 23–56.
2. Werner Patielt, Ein latenter Verfassungskonflikt? Die Deutschen und ihr parla-
mentarisches Regierungssystem, politische Vierteljahresschrift, vol. 39, no. 4,
1999, pp. 725–57.
3. Samuel P. Huntington, American Politics. The Promise of Disharmony, 2nd
edn (Cambridge, Mass.: Belknap, 1982), p. 39.
4. Klaus von Beyme, The Legislator: German Bundestag as a Centre of Political
Decision-Making (Aldershot: Ashgate, 1998).
5. Christine Landfried (ed.), Constitutional Review and Legislation: An
International Comparison (Baden-Baden: Nomos, 1988); Alexander von
Brünneck, Verfassungsgerichtsbarkeit in den westlichen Demokratien. Ein sys-
tematischer Verfassungsvergleich (Baden-Baden: Nomos, 1992).
6. Philip Norton, The Commons in Perspective (Oxford: Martin Robertson,
1981), p. 181.
7. Sven S. Andersen and Kjell A. Eliassen (eds), Making Policy in Europe: The
Europeification of National Policy-Making (London: Sage, 1993), p. 260.
8. Markus Jachtenfuchs and Beate Kohler-Koch (eds), Europäische Integration
9. Christine Landfried, Politische Steuerung in der Europäischen Union (Baden-
Baden: Nomos, 2000, forthcoming); Roger Morgan and Claire Tame (eds),
Parliament and Parties (New York: St Martin’s Press, 1996).
10. Giandomenico Majone, ‘Redistributive und sozialregulative Politik’, in
Jachtenfuchs and Kohler-Koch, Europäische Integration, op. cit., pp. 225–48.
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Index
Absolute monarchy 5–8, 24, 73, Bulgaria 10, 15, 32, 45, 111, 112,
157f. 116, 118, 123, 127, 132, 134, 137,
Administration, bureaucracy 102, 139, 142, 170, 195
194 Burke, Edmund 8, 73, 109
Albania 170
Allowance for parliamentarians Cabinet 11, 38f., 97–107, 129–35,
50–2 137–9, 142f., 149–61, 162,
Alternative government 193, 164–78, 179–97, 205f.
194–8 stability 105, 147, 177, 188–97,
Australia 23, 30, 40, 45, 47, 51, 55, 206
67f., 74, 83, 86, 89, 93, 96, 99, Canada 15, 23, 30, 40, 45, 51, 52,
100, 102, 109, 112, 118, 123, 130, 56, 85, 86, 89, 92, 93, 100, 112,
137, 145, 146, 167, 171, 172, 174, 118, 123, 141, 145, 146, 167, 171,
182, 187, 189, 191, 196 172, 176, 177, 189, 191, 192, 193,
Austria 10, 13, 14, 18, 21, 28, 30, 196, 216
31, 35, 36, 40, 42, 45, 51, 56, 61, Cavour, Camillo 160
62, 66, 76, 77, 81, 85, 86, 89, 92, Chancellor’s system 99, 156
93, 95, 96, 100, 104, 105, 106, Chateaubriand, F. R. 26, 173
111, 112, 114, 118, 123, 137, 140, Christian Democrats 27, 36, 66, 67,
141, 142, 146, 147, 157, 165, 166, 75, 97, 130, 133, 167, 170, 187
167, 170, 171, 172, 182, 185, 187, Coalition 39f., 64, 66–71, 100f.,
189, 191, 192, 194, 196, 200, 207 143, 147, 163–78, 186, 189,
191–8
Bagehot, Walter 4, 48, 72, 82, 96, Coburg government style 8, 33, 201
98, 108, 122, 128, 162 ‘Cohabitation’ 15, 99, 111–16, 195
Belgium 3, 8, 10, 15, 17, 20, 21, 23, Committees 40f., 52–71, 213
26, 28, 29, 30, 42, 45, 46, 47, 49, Communist Parties 75, 93, 141, 187,
51, 56, 70, 74, 77, 80, 81, 85, 86, 203
89, 92, 93, 95, 98, 99, 100, 106, Compatibility between mandate and
107, 112, 117, 118, 122, 123, ministerial office 5, 9, 14, 60,
127, 134f., 136, 137, 139, 140, 102, 199, 201
143, 144, 145, 146, 147, 157, Conference committees 46
160, 161, 162, 165, 166, 167, Conservatives 26, 27, 48, 81, 104,
169, 170, 171, 172, 176, 179, 164, 190, 197, 198, 200, 203
181, 182, 183, 187, 188, 189, Consociational democracy 40–1,
190, 191, 192, 193, 196, 198, 43f., 45, 52, 92, 97, 129, 170,
199, 202, 203 187f., 192, 194, 198
Bismarck, Otto von 27, 50, 150, Consolidation 2–3, 50, 116f., 142f.,
158 146f., 195, 198–210
Bodin, Jean 4 Constant, Benjamin 4, 8, 20, 41f.,
Britain see Great Britain 109, 180
Budget 7, 18–25, 45, 60, 61, 82, 151, Constitution 35–8, 53, 54, 104, 109,
203 114, 127, 160, 177, 180, 198, 200
243
244 Index
Constitutional courts 50, 91, 111, Estonia 32, 142

116, 122, 181, 212 European Union 60, 70, 91, 97,
Constitutional engineering 1, 31–37 213–16
Constitutional monarchy 5–8, 11,
32, 39, 104f., 127, 135–7, 141f., Factions 64f., 66, 67, 102, 116, 151,
151, 152f., 190, 198–204 168
Control 40–1, 54–60, 64–71, 81–8, Federalism 39–46, 52, 88, 105f.,
103, 211 140, 152, 211, 212, 215
Corporatism 18, 62–67 Finland 10, 12, 15, 19, 21, 22, 30,
Corruption 51, 67, 131 31, 34, 35, 40, 42, 45, 51, 56, 61,
Counter-signature of acts of the head 65, 70, 76, 77, 79, 85, 86, 89, 92,
of state 36, 88f., 91, 141f. 93, 94, 100, 105, 106, 111, 112,
Croatia 15, 32 114, 115, 118, 122, 124, 131, 134,
Culture, political 68, 75, 94 137, 142, 144, 146, 147, 148, 156,
Czech Republic 10, 15, 30, 32, 37, 157, 158, 162, 165, 166, 171, 172,
43, 45, 53, 99, 100, 110, 111, 112, 174, 175, 176, 177, 185, 188, 189,
116, 118, 123, 130, 137, 170, 195, 191, 192, 194, 203
207 France
Revolutionary system 1789–99
Decrees 88–91, 117, 118–21, 122, 17, 19, 22, 33, 34, 35, 43, 65,
144 73
De Gaulle, Charles 11, 13, 23, 35f., under Napoleon 1799–1815 18
115f., 140, 158, 194f. Restoration 1814–30 19, 28, 159,
Denmark 10, 15, 19, 21, 22, 23, 28, 199, 203
29, 30, 40, 42, 43, 45, 51, 56, 60, July Monarchy 1830–48 8, 17,
62, 68, 74, 77, 79, 81, 85, 86, 93, 19–21, 24, 46, 49, 131, 199, 202
94, 95, 96, 97, 100, 106, 112, Second Republic 1848–51 1, 27,
117, 118, 122, 123, 139, 140, 28, 31, 32, 152, 158, 161, 173,
142, 144, 145, 146, 148, 165, 199
166, 168, 171, 172, 174, 175, Second Empire 1851–70 19, 27,
176, 177, 188, 189, 191, 192, 30, 34, 198, 204
195, 196, 199, 201 Third Republic 1871–1940 10, 11,
Democratisation 1–37, 50, 52, 67, 21, 22, 26, 30, 47, 48, 54, 76,
140f., 153, 185, 186, 190, 198, 91, 104, 129, 133, 136, 139,
207–10 140, 142, 144, 152, 159f., 174,
Dictatorship 18, 36, 185 181, 182, 183, 185, 186, 188,
Dissolution of government 7, 127, 190, 193, 199f., 201
135f., 169, 178–94 Fourth Republic 1945–58 10, 11,
Dissolution of parliament 7, 48, 21, 30, 34, 35f., 47, 54, 91,
109, 110, 115, 128f., 135–48 142f., 145, 152, 153, 160, 164,
Donoso Cortés, Juan 8, 20, 26 176, 181, 187, 192, 193
Duguit, Léon 48 Fifth Republic 1958ff. 11, 13–15,
30, 32, 35f., 40, 42, 45, 46, 51,
Electoral law 17, 27–31, 130, 158f. 54, 57, 60, 66, 70, 75, 77, 79,
Elites 43, 51–71, 74, 81, 96, 102–7, 80, 81, 83, 85, 86, 89, 91, 94,
209 99, 100, 104, 105, 106, 111,
Emergency powers 122, 123–126, 114, 115f., 117, 118, 124, 127,
141 131, 137, 139, 140, 141, 146,
Estates 24, 28 147, 148, 159, 171, 172, 176,
Index 245
178, 189, 191, 192, 195, 196, Green Parties 61, 76, 78, 134, 164,
197 186
Guizot, François 131
General strike 22
Germany Habermas, Jürgen 52
German Confederation 1814–66 Head of state 14f., 88, 98, 108–48,
19, 21, 23, 28, 32, 33, 34, 65, 157f., 163, 195
Second Empire 1871–1918 19, 20, Hearings 88ff.
25, 29, 150, 154, 199, 202, 204 Hungary 10, 13, 15, 17, 30, 31, 32,
Weimar Republic 1918–45 1, 12, 37, 45, 53, 100, 112, 116, 117,
17, 34, 35, 96, 105, 117, 122, 119, 122, 124, 134, 137, 141, 170,
135, 139, 140, 143f., 154, 158, 195, 207
159, 164, 175, 181, 182, 185, Huntington, Samuel 11f., 16, 26,
187, 188, 192, 199, 200 198
Nazi rule 1933–45 181
Federal Republic 1949ff. 10, 15, 19, Iceland 13, 14, 29, 30, 45, 60, 70,
34, 40, 42, 45, 46, 50, 51, 54, 55, 71, 74, 114, 158, 165, 166, 168,
57, 61, 62, 64, 65, 66, 68, 69, 70, 176, 189
74, 76, 77, 79, 80, 81, 83, 89, 91, Impeachment 20–2, 110f., 180, 203,
92, 96, 98, 100, 103, 104, 106, 208
107, 111, 112, 119, 122, 124, India 201
127, 130, 132f., 137, 139, 141, ‘Informateurs’ 134–5
151, 153, 155, 156, 159, 161, Interest groups 53f., 61–3, 73–81,
162, 164, 165, 166, 167, 168, 94, 155, 194, 210–12
171, 172, 177, 180, 181f., 182, Interparliamentary Union 60, 77,
186, 187, 189, 191, 192, 194, 91
196, 200, 209, 212, 213, 214 Interpellations 20, 21, 24–6, 82–8,
Government 108–97 203f.
Government building 122–34, 165, Investiture of government 25, 99,
173, 194 179
Governmental stability 170, 182, Ireland 10, 13, 14, 30, 40, 41, 42,
185, 186–94, 200 45, 47, 51, 57, 70, 76, 77, 79, 80,
Great Britain 3, 8, 19, 21, 26, 27, 28, 83, 86, 89, 92, 93, 95, 96, 99,
29, 30, 38, 45, 46f., 48f., 51, 55, 101, 102, 106, 112, 114, 119,
57, 61, 65, 66, 67f., 70, 75, 77, 124, 127, 137, 145, 146, 147,
79, 80, 83, 86, 89, 92, 94, 100, 152, 157, 159, 165, 166, 167,
103f., 106, 107, 112, 119, 122, 168, 171, 172, 176, 189, 191,
124, 128, 130, 136, 137, 139, 143, 192, 194, 195, 196
144, 146, 147, 148, 149, 153, 156, Israel 10, 14, 40, 45, 58, 84, 86, 89,
157, 159, 161, 162, 171, 172, 173, 93, 98, 101, 110, 113, 117, 119,
174, 176, 178f., 181, 182, 183, 125, 138, 141, 145, 161, 165, 169,
185, 188, 189, 190, 191, 192, 196, 170, 176, 201
197, 198, 199, 201 Italy/Piedmont
Greece 10, 15, 19, 30, 41, 42, 54, 57, Monarchy 1848–1943 2, 5, 19,
61, 62, 70, 74, 76, 77, 83, 85, 86, 21, 23, 24, 27, 28, 31f., 34, 48,
89, 92, 99, 100, 102, 112, 117, 131, 139, 140, 142, 143, 147,
119, 124, 127, 131, 132, 134, 137, 160, 173, 179, 182, 183, 185,
139, 141, 158, 170, 171, 175, 191, 186, 188, 199, 200, 201, 202,
195, 196, 200, 213 216
246 Index
Italy/Piedmont (cont.) Minority government 127, 129f.,

Republic 1944ff. 10, 15, 31, 34, 145, 167, 169ff., 173–8, 193, 195
35, 42, 43, 45, 46, 49, 50, 51, Minority rights 41–9, 53
54, 55, 58, 61, 70, 75, 77, 79, Mirabeau, H. G. 199
80, 84, 87, 89, 91, 92, 94, 95, Mohl, Robert von 20, 117, 190
97, 98, 99, 101, 102, 105, 106, Monarchy 10, 14f., 47f., 88, 109,
107, 111, 113, 119, 125, 127, 110, 117, 143, 149f., 157f.
130, 135, 138, 144, 146, 147, Monarchical principle 5, 20, 32f.
148, 151, 155, 158, 161, 162, Monarchists 36
165, 166, 167, 169, 170, 171,
172, 176, 177, 180, 181, 187, Naumann, Friedrich 17
189, 191, 192, 193, 194, 196, Netherlands 14, 17, 19, 26, 28, 30,
203 34, 42, 43, 45, 46, 47, 49, 51, 59,
60, 70, 77, 79, 89, 92, 93, 100,
Japan 10, 31, 45, 58, 81, 84, 89, 93, 101, 102, 104, 105, 106, 107, 110,
101, 113, 120, 125, 138, 139, 170, 113, 120, 122, 125, 129, 131, 133,
171, 191, 196, 201, 207 134f., 138, 142, 144, 146, 157,
160, 165, 166, 167, 170, 171, 172,
Kant, Immanuel 4, 5, 193 175, 176, 177, 180, 181, 182, 183,
Kjellén, Rudolf 175 185, 188, 189, 190, 191, 192,
193f., 194, 199, 200, 202
Laski, Harold 1, 55, 143 Networks 40, 62–4
Latvia 32, 142 New Zealand 15, 40, 43, 45, 51, 58,
Legal state (Rechtsstaat) 10, 50 84, 87, 89, 92, 96, 100, 102, 113,
Legislation 88–97, 212 120, 125, 130, 171, 172, 182, 189,
Liberal parties 17, 20, 23, 29, 55f., 191, 196
61, 129, 150, 164, 167, 169, 170, Norway 10, 17, 19, 20, 21, 25, 26,
198, 202f. 28, 30, 33, 42, 45, 59, 61, 62, 70,
Lijphart, Arend 41–2, 43, 52, 94 79, 81, 84, 87, 89, 93, 97, 99, 100,
Lithuania 12, 13, 32, 142, 170, 195 101, 102, 104, 106, 110, 113, 120,
Luhmann, Niklas 117 122, 125, 127, 130, 136, 138, 144,
Luxembourg 14, 17, 28, 30, 42, 45, 145, 148, 151, 157, 160, 161, 165,
51, 52, 58, 70, 77, 84, 86, 89, 93, 166, 170, 171, 172, 174, 175, 176,
95, 100, 101, 102, 106, 107, 113, 177, 181, 182, 183, 185, 187, 188,
117, 120, 122, 125, 138, 139, 189, 190, 191, 194, 195, 196, 199,
140, 146, 152, 165, 166, 167, 202, 203
168, 170, 171, 172, 187, 189,
191, 192, 196 Obstruction 53
Ombudsman 202, 203
Majority principle 128ff. Opposition 11, 25, 40–50, 61, 64,
Marx, Karl 26 81, 92f., 97, 153, 154, 157
Media 53, 80, 82
Mill, John Stuart 8, 20, 38, 43, 98, Parliamentary groups 53, 61, 64–71
149, 199 Parliamentary secretaries of state
Ministerial responsibility 105, 151f.
legal 20–2, 201 Parliamentary sovereignty 38–71,
political 20–2, 37, 85–8, 199, 201 80
Ministerial solidarity 9, 11, 14, Parties 10, 35, 64–71, 163–78,
149–51, 208 179–97, 202f.
Index 247
Party discipline 15, 53, 67–71, 157 Russian Federation (since 1991)
Party government 38, 64, 75, 131, 10, 11, 14, 35, 36f., 38, 45, 85,
157, 163–78, 190, 214 91, 99, 111, 113, 114, 116, 121,
Patronage 151–2 122, 126, 127, 136, 138, 141,
Poland 4, 10, 12, 13, 32, 45, 53, 99, 212
101, 111, 113, 114, 116, 120, 126,
138, 142, 176, 195, 207 Sartori, Giovanni 1, 67,
Policies 97 Schmitt, Carl 23, 52, 117, 175
Political culture 174, 175, 187 Semipresidential system 12–15, 19,
Populism 27, 95, 97 30f., 36f., 71, 85, 88, 96, 105, 109,
Portugal 10, 15, 19, 30, 39, 41, 42, 111–16, 117, 122, 127, 131, 136,
51, 54, 59, 60, 61, 65, 70, 77, 81, 140, 143f., 147, 158, 195, 199, 212
84, 85, 87, 89, 91, 93, 101, 113, Slovakia 10, 12, 15, 116, 195
114, 115, 120, 122, 126, 127, 134, Slovenia 15, 207
170, 171, 175, 176, 191, 195 Social democratic parties 26, 29, 36,
Postcommunism 116, 170f., 195 49, 61, 65, 66, 93, 129, 130, 160,
Presidential government 14f., 36, 164f., 169, 174, 186, 187, 197, 198
109, 122, 162, 167f., 196f., 201, Spain 2, 10, 14, 17, 19, 27, 28, 30,
209 33, 34, 35, 36, 41, 42, 42, 45, 51,
Primaries 71, 74 53, 54, 55, 59, 60, 61, 65, 70, 77,
Prime minister 11, 14, 41, 46–50, 79, 84, 85, 87, 89, 93, 99, 101,
68, 85, 98–107, 123–6, 127, 142, 104, 113, 121, 122, 126, 127, 131,
145, 150–62, 179f., 185, 190, 191, 138, 139, 141, 143, 170, 171, 175,
195 176, 182, 185, 191, 195, 196,
Preuss, Hugo 133 198f., 207
Stahl, Friedrich Julius 8, 20
Question hour 82–5 Standing orders 24, 39–41, 53, 65,
Stein, Lorenz von 8
Radical parties 156, 174, 192, 198, Sweden 5, 10, 14, 19, 20, 25, 27, 28,
200 29, 30, 33, 41, 42, 43, 45, 53, 55,
Recruitment of ministers 98–107, 211 59, 60, 61, 62, 63, 64, 66, 69, 70,
Redslob, Robert 48 75, 77, 79, 80, 84, 987, 89, 91, 92,
Referendum 15, 36–7, 38, 88, 95–8, 93, 94, 97, 99, 101, 105, 107, 113,
117, 118–21, 139f. 117, 121, 126, 127, 129, 131, 133,
Regions 43f., 76, 88, 197, 215 134, 138, 139, 140, 142, 144, 145,
Religious groups 26, 96, 187, 203 146, 147, 151, 154, 155, 158, 159,
Representation 192 160, 161, 165, 166, 169, 170, 171,
Representative government 4, 5, 172, 174, 175, 176, 177, 181, 182,
16–31, 202 187, 188, 189, 191, 195, 197, 199,
Responsible government 37, 38 200, 201, 202, 203
Responsiveness 78–81, 95 Switzerland 5, 21, 29, 45, 69, 82, 96,
Revolution 17, 22, 27, 33, 43, 107, 97, 98, 156, 201
190
Rousseau, Jean-Jacques 73, 117 Tocqueville, Alexis de 41, 43, 110
Romania 14, 31, 45, 113, 116, 121, ‘Trasformismo’ 131
126, 127, 138, 170, 195 Treitschke, Heinrich von 24, 180
Russia Two-chamber-system 19, 23, 41–50,
Empire until 1917 17, 24, 34, 158, 99, 133f., 140, 141, 147, 180,
191, 200 206, 208
248 Index
United States 5, 19f., 22, 30, 40, 43, Vote of no-confidence 7, 15, 20,
45, 46, 50, 51, 54, 62, 67, 69, 74, 24–6, 48, 85–8, 98, 110f., 129,
76, 78, 80, 82, 88, 94, 96, 98, 103, 139, 178ff., 188, 190
105, 116, 122, 152, 156, 163,
167f., 171, 201, 209, 215 Women in parliament and
government 28, 29, 76f., 156
Veto of the head of the state 6, 19,
122, 154, 208 Yugoslavia 15, 117, 142

[Advances in Political Science_ An International Series] Klaus von Beyme (auth.) - Parliamentary Democracy_ Democratization, Destabilization, Reconsolidation, 1789–1999 (2000, Palgrave Macmillan UK).pdf

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[Advances in Political Science_ An International Series] Klaus von Beyme (auth.) - Parliamentary Democracy_ Democratization, Destabilization, Reconsolidation, 1789–1999 (2000, Palgrave Macmillan UK).pdf

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Parliamentary Democracy

Advances in Political Science: An International Series

Advances in Political Science

Klaus von Beyme

First published in the United States of America 2000 by

JF1051 .B49 2000

List of Figures and Tables vii

1 Parliamentary Government: the Rise of a Concept 4

2 The Parliamentarisation of Representative Governments 16

3 The Organisational Basis of Parliamentary Sovereignty 38

5 The Role of the Head of State in Relation to Parliament

5.3 Functions of the head of state in legislation 117

6 The Government and Parliamentary Majority 149

Notes and References 217

Bibliography of Comparative Literature 240

4.9 Ministers’ career pattern in parliamentary democracies 106

Parliamentary democracy was a favourite subject of ‘grandpa’s political

cases parliamentarisation. 3 The ‘holy trinity’ of transitional stages in

However, in the case of parliamentary regimes that developed after the

This sequence may be ampliﬁed as follows:

• The parliamentarisation and consolidation of parliamentary regimes fre-

The historical study of parliamentary regimes has a wider focus for

• Parliaments (Chapters 2, 3, and 4).

• The executive (Chapter 6).

Parliamentary regimes are, however, characterised by cooperation

A great assembly is as soon spoiled by overindulgence as a little

The term ‘parliamentary government’ had hardly been accepted when

monarchy or democracy. Kant even called non-representative govern-

• Regimes dominated by the estates in an electoral monarchy.

The deﬁnition of parliamentary government – as the ﬁfth stage of

• The ministers did not develop cabinet solidarity.

If we look at the constitutions of parliamentary regimes and the way in

• Compatibility of parliamentary mandate and ministerial ofﬁce

Table 1.2 Self-deﬁned characteristics of selected parliamentary democracies

Austria Republic Democratic

dualistic presidential systems, apart from the possibility of toppling

Besides the minimal institutional criteria, certain social–structural fea-

• Organised parties to facilitate the building of parliamentary

1848–51) and reemerged in the Weimar Republic (1919) and Finland.

• Semipresidential systems in which the president has more power

Purely parliamentary systems, semipresidential and presidential

Ranking of countries 3. Weimar

Parliamentary system Presidential

President elected by the people No (exceptions: prime Yes Yes

Parliamentary system Presidential

Downfall of government by Yes, partly controlled Yes, controlled parliamentarism No

What is a democracy if not a third power which political

2.1 Waves of parliamentarisation of the executive

Modern theories of transformation to democracy assume that after

1. First long wave: 1828–1926

What Huntington has called ‘democratisation’ was at best parlia-

1791). There were few waves of democratisation in Europe in the nine-

Parliamentary majorities in the nineteenth century often fought for

2.2 Parliamentarisation via the constitutional weapons of

There have been ﬁve types of representative or quasi-representative

1 Parliamentarisation of the system of estates England from 1688

a balance between the legislature and the constitutional monarchy,

Table 2.2 Parliamentary means of ensuring the accountability of government

Right to interpellation leading to vote of

Britain: Britain: Britain:

Early legal attempts at regulation

it functioned in a similar way to the practice in the presidential system

2.2.2 Refusal to approve the budget

people. It was predemocratic because in the perception of most liberals