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Contents

India and USA............................................................................................................................................... 2


a) General difference ............................................................................................................................ 2
b) Form of Government ......................................................................................................................... 2
c) Office of President ............................................................................................................................ 3
d) Civil Services .................................................................................................................................... 3
India and UK ................................................................................................................................................. 4
a) General difference ............................................................................................................................ 4
b) Civil service ...................................................................................................................................... 5
c) Parliamentary Commissioner ........................................................................................................... 6
d) CAG................................................................................................................................................... 7
India and France............................................................................................................................................ 7
a) General difference ............................................................................................................................ 7
b) Office of President ............................................................................................................................ 8
c) Civil service ...................................................................................................................................... 8
d) Administrative courts ........................................................................................................................ 9
India and Japan ........................................................................................................................................... 10
a) General differences ......................................................................................................................... 10
b) Civil service .................................................................................................................................... 10
Sample questions of PubAdm (mains) ........................................................................................................ 11
References ................................................................................................................................................... 11
Personal Info: .............................................................................................................................................. 11
India and USA

a) General difference
USA India
1. Oldest written constitution 1. New constitution (1949) originally
consisting of a preamble and 7 consisting of a preamble, 395 articles
articles. and 8 schedules.

2. Highly rigid: All parts of the 2. Mix of rigidity and flexibility.


constitution are to be modified by Some parts of the constitution can be
special procedure which is 2/3rd modified by ordinary law and some
majority in both the houses and require special process.
ratified by 3/4th of the states.

3. Federal constitution – more 3. Federal constitution with a strong


power is given to the states, with center. There is division of power
states having separate between center and states with
constitutions and residual powers. residual power with the center.
Also, the subjects (union+
concurrent) available to the center
are significant in numbers and
matter.

4. Bicameral legislature (congress) 4. Bicameral legislature (parliament)


– house of representative (lower – loksabha (lower house) and rajya
house) and senate (upper house) sabha (upper house). The loksabha is
with powerful upper house. more powerful.

b) Form of Government
USA – Presidential form of government India – Parliamentary form of
government
1. Head of the government 1. Head of the government (PM) is
(president) is elected by the people appointed by the President. He is
directly via an electoral college leader of the party/coalition
constituted for the purpose. having majority in the lower
house.
2. He is assisted by a cabinet, an 2. He is first among the ministers.
advisory body consisting of non All the ministers are appointed
congress members appointed by by the president on his advice.
him.
3. He is not responsible to the 3. He is responsible to the lower
congress for his acts. house.
4. He does not attend the congress 4. He attends the parliamentary
sessions. sessions and has the voting right
in which he is a member.
5. He is elected for a fixed term of 4 5. He has to resign if he does not
years and can be removed by having the confidence of the
impeachment. lower house.

c) Office of President
USA India
1. Elected by an electoral college 1. Elected by an electoral college
created for the purpose. Size of consisting of :
this is equal to the size of  Elected members of parliament.
congress and members are elected  Elected members of state
by the people from the states. assemblies.
The presidential candidate who  Elected members of assemblies of
secure absolute majority is UT of Delhi and puducherry.
declared winner. If no candidate
secures the majority then the
Houser of representative elect the
president among the three
candidates securing the highest
votes.
2. Only natural born citizens and 2. Any person who has the Indian
residents for 14 years are eligible. citizenship is eligible.
3. He can grant pardon and reprive 3. He can grant pardon and reprive on
for offense against federal laws. federal and state laws.
4. His pocket veto is limited. When 4. He enjoys unlimited pocket veto.
a bill is sent to him for assent he
can reserve the bill for not more
than 10 days.
5. He can call special sessions of the 5. There is no such provision.
congress for consideration of
urgent matters.

d) Civil Services
USA India
1. It’s a mix of merit and spoils 1. All recruitments are based on
system. Around 10,000 senior civil merit system only.
service posts are filled based
political patronage.
2. There is a system of lateral entry. 2. There is no system of lateral
This facilitates entry at all levels entry and strict age restrictions
and any age ensuring movement are followed.
between government and private
jobs.
3. Examinations are ‘assembled’ and 3. All the examinations are
‘unassembled’. Assembled ‘assembled’.
examinations are used to fill lower
posts by conducting written tests.
Unassembled tests are used for
senior posts by individual interview
and testimony.
4. No definite education qualification 4. Education qualifications are
is prescribed. prescribed.
5. There exists a system of pre-entry 5. Only post-entry trainings are
and post-entry trainings. Trainings available.
are flexible involving universities
as well as in house training
conducted by OPM (Office of
Personnel Management).
6. Less Restriction on fundamental 6. Restrictions on fundamental
rights such as: rights such as:
 They have the right to  They don’t have any
express views on rights to comment on
government policy matters policy matters. This is
however they can be done to ensure political
disciplined in cases such as neutrality.
false information,  Right to form/join
confidential information, associations is
affects the performance of guaranteed. However the
organization, etc. government would
 Right to form/join consult or negotiate only
associations and collectively with the recognized
bargain is allowed. ones.

India and UK

a) General difference
UK India
1. Oldest democracy which is a 1. New democracy which is a
blend of monarchy, aristocracy parliamentary and republic.
and democracy.
2. Unwritten constitution. The 2. Lengthiest written constitution.
administration is carried out
based on great charters, statutes,
conventions which are backed by
tradition and public support.
3. Flexible constitution. There is no 3. Mix of rigidity and flexibility. Some
distinction between ordinary law parts of the constitution can be modified
and amendment. by ordinary law and some require special
process.
4. Unitary constitution. The 4. Federal constitution with a
provincial governments are for strong center. There is
administrative purposes only. division of power between
They can be abolished at any time center and states with residual
by the center. power with the center. Also,
the subjects
(union+concurrent) available
to the center is significant.

5. British system is based on the 5. Indian system is based on the


doctrine of supremacy of doctrine of supremacy of
parliament. The laws made by constitution. The Supreme Court
the parliament cannot be is constitutional given the right to
declared void by judiciary. validate the laws passed via
judicial review.
6. The head of the state/president or 6. The head of the state is elected by
Crown is not elected but decided the people indirectly.
by inheritance.
7. Shadow cabinet is formed by the 7. There is no such concept here.
opposition party. Almost every
member “shadows” the ministers.
The leader of opposition heads
the shadow cabinet. They closely
monitor the working of respective
ministries.

b) Civil service
UK India
1. Elaborate recruitment procedure 1. See USA.
called country house method is used.
After candidate qualified after the
written tests are taken for a 2 day
interview tests to a country house
and various interviews
individual/group are carried out.
2. There is a 2 year probationary period. 2. There is no probation period.
3. Promotions are carried out 3. It is carried out by the Department
professionally : of Personnel and Training. The is
 Candidate is informed well in scope to improve this area.
advance of vacant posts.
 Suitability is decided by
board.
 Aggrieved candidates have
the right to appeal.
4. A highly comprehensive system is in 4. There is no such mechanism.
place for better employer (state) and
employee relations - whitley
counsels.
5. Rights 5.Rights
 They have the right to express  They don’t have any
views on non political matters rights to comment on
of public importance. policy matters. This is
 There is a total ban on done to ensure political
political activities at higher neutrality.
level. It becomes less relaxed  They cannot involve in
to the middle and lower any political activity
levels. The lower levels can like joining political
participate in all the political parties, attending
activities. meetings, etc. However
 Right to strike is not illegal. they enjoy the right to
However they can be vote.
subjected to disciplinary  They don’t have the
actions. right to strike.
 Right to form/join  Right to form/join
associations and collectively associations is
bargain is allowed. guaranteed. However
the government would
consult or negotiate
only with the
recognized ones.

c) Parliamentary Commissioner
UK India
1. Limited scope. Does not include 1. Wider scope includes ministers, PM
ministers, PM and MPs. and MPs.

2. He investigates matters of 2. He investigates matters of corruption.


maladministration which he is free to
define.
3. All the matters that are referred to him 3. The aggrieved citizens can directly
come via MP. This process is known as approach him.
‘MP filter’.
4. He is only an investigation agency and 4. After investigation, the findings are
cannot persecute. presented in a special court. A copy is
also sent to the competent authority that
has to report with the action taken.
d) CAG
UK India
1. He is an officer of the parliament 1. He is a constitutional body who
and audits the accounts of the audits the accounts of union as
union. well the state.
2. Any money can be drawn by the 2. He has no control over the money
executive from the public drawn from the consolidated
exchequer only after his approval. funds and is involved only during
He is both the comptroller and the audit stage when the
auditor. expenditure has already occurred.
He is only auditor.

India and France

a) General difference
France India
1. Rigid constitution, a special 1. Already covered
procedure requiring 60% majority in
both houses is required.
2. Features of direct democracy like :- 2. No such futures.
 President seeking referendum
on amendments
Is available.
3. Highly unitary government. No 3. Already covered.
separation of power and power to
abolish provincial governments.
4. Quasi-Presidential and Quasi- 4. Already covered.
Parliamentary system. The president
is elected by the people and is
powerful. There also exists a cabinet
headed by PM responsible to the
legislature.
5. Restricted parliament, it can make 5. There is no such distinction.
laws only on those subjects listed in
the constitution. The residual powers
are vested with the executive. This is
to ensure powerful executive.
6. There exists a constitutional council 6. There is no such provision.
to check the constitutional validity of
the executive decrees and
parliamentary laws.
7. The peculiarities of the constitution 7. NA
like powerful executive, direct
democracy, emergency provisions
etc are to ensure smooth working of
the system as France has the history
of unstable governments and
redrafting the constitution every 12
years.

b) Office of President
France India
1. Directly elected by people. The 1. Already covered.
candidate has to secure absolute
majority. If there are no results
then 2nd ballot is used to decide
between the first two candidates
securing highest votes.
2. No age restrictions and elected for 2. He has to be 35+.
a fixed term of 5 years. He can be
removed by impeachment
involving parliament and judiciary.
3. He is powerful with the following 3. He has only nominal powers.
functions:-
 He presides over the
cabinet meetings and
directly influences the
government.
 He appoints the president
and members of the
constitutional council.
 He can summon special
sessions of the parliament.

4. There is a constitutional provision 4. There is no such provision


to ensure republican form of although it’s a basic structure of
government meaning there is no the constitution.
scope for monarchy through
amendment.

c) Civil service
France India
1. It is known as ‘civil service state’ or 1. Stable government.
‘administrative state’ due to the
weak government.
2. It had the system of ‘Sale of Office’; 2. It has been merit based.
the vacant posts were sold to the
highest bidder.
3. The Ecole Nationale’d 3. Already covered.
Administration (ENA) is the apex
institute involved in pre-entry,
recruitment, post-entry training.
4. It has world class training. Some 4. It is not as comprehensive as France.
feature:
 Practical rather than
theoretical.
 Handled by senior civil
servants.
 Provision for private
trainings.
 Long term trainings.
5. Provision to switch to private and 5. There is no such provision.
public is available.
6. Promotions are based on merit and 6. Promotions are based on merit.
seniority.
7. They enjoy all the rights : 7. India’s rights can be derived from
 They enjoy freedom of points mentioned against USA/UK
expression on all matters. above.
 They can join/form
association/trade unions.
 They are given the right to
strike.
 They enjoy all the political
rights. In fact they can get
elected and come back to the
service after resigning.

d) Administrative courts
France India
1. It is created to provide justice to 1. It has a narrower scope and is created
citizens on all administrative matters. for curbing corruption.
The scope is wider. The administrative
laws known as ‘Droit Adminsitratif’ are
safeguarded.
2. It can ask for compensation to the 2. It can only ask to take action on
aggrieved citizens as well as take asks disciplinary matters.
action on disciplinary matters.
India and Japan

a) General differences
Japan India
1. Features of direct democracy like – 1. Already covered.
ratification of amendments passed in
the legislature by people at special
referendums.
2. Unitary constitution with no 2. Already covered.
separation of powers.
3. Constitutional monarch enjoys only 3. Elected president and enjoys few
ceremonial functions. powers.
 He does not enjoy the power  He enjoys the power to choose and
to choose but only appoint appoint PM.
the PM. PM is chosen by  He appoints the ministers of
diet. course on the advice of PM.
 He does not appoint the  He can remove the ministers on
ministers. They are appointed the advice of PM.
by PM.
 He cannot remove the
ministers. They are removed
by PM.
4. Parliamentary government with 4. PM does not enjoy the power to choose
powerful PM. He can appoint and from outside the parliament.
remove the ministers. He can choose
at will but majority have to be from
the diet.
5. Renunciation of war is a 5. It’s a matter of India’s foreign policy.
constitutional provision that was
added by the General MacArthur to
see that Japan does not have the
sovereign right to raise war.

b) Civil service
Japan India
1. The administrative officers called 1. IAS is not attached to any ministry. They
‘careermen’ or ‘elitos’ are attached to move from one to another. India believes
ministries. Japan seems to believe in administration is a generalist job.
specialist administrators.
2. All the civil servants join on the same 2. They can join at will.
day 1st April, the 1st day of financial
year.
3. Promotions are based on seniority then 3. It is based on merit.
educational background, university and
area of specialization.
4. At lower levels promotions are based 4. It is uniform across levels.
on written tests.
5. System of collective seniority is 5. There is no such provision.
prevalent at higher levels. Civil
servants who have same seniority get
promoted at the same time. Whoever is
not able to find position has to resign
and start ‘Second career’.
6. On retirement, a civil servant is placed 6. There is no such provision.
in a private corporation. This system is
called ‘amakudari’ system.
7. Rights 7. India’s rights can be derived from points
 Right to form/join associations mentioned against USA/UK above.
is allowed except for police and
maritime safety agency.

Sample questions of PubAdm (mains)


1. Government has been slow in using modern methods for discovering executive talent‘
Examine the validity of the statement with reference to recruitment to higher civil service in
India. USA and France (1990)
2. In what respects, the powers of proposed institution of Lok Pal in the Bill already introduced
in Indian Parliament, will strengthen the institution as compared to Parliamentary Commissioner
of UK? (2001)

References
1. Public Administration – M. Lakshikanth
2. Indian Polity – M. Lakshmikanth
3. PRS - http://www.prsindia.org
4. Internet digging.

Personal Info:
Name: Rajith P.R.

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