FOUN 1301 – LECTURE 2

PARLIAMENTARY & PRESIDENTIAL SYSTEMS OF

GOVERNMENT & THE WESTMINISTER SYSTEM
OF GOVERNMENT IN THE CARIBBEAN
Reading: Section II Westminster/Whitehall
Systems
Parliamentary Government:

1. The executive is not separated from the

legislature. The members of council of ministers are the
members of legislature.

2. The executive is accountable to the legislature.

The executive loses power when it loses the
confidence of the legislature.

3. In the Parliamentary government, one person is

head of state while another persons is head of
government.
4. In the Parliamentary systems, the Prime
Minister is most powerful

5. In the Parliamentary system, the Prime

Minister can appoint only the members of
parliament as minister.

6. In the Parliamentary system, the tenure of

the executive is not fixed. The Council of
Ministers is dismissed if it loses the confidence
of the legislature before its tenure is over.
7. The Parliamentary government is more
democratic, because the executive (council of
ministers) is accountable to the legislature
(Parliament).

8. There is less of separation of powers in the

Parliamentary government.

9. During war and other emergencies, the

Parliamentary government is relatively less
effective and successful.
Presidential Government:
1. The executive is completely separated from the
legislature. The members of executive are not the
members of the legislature.

2. The executive is not accountable to the II legislature.

The legislature cannot remove the executive from
power] through no-confidence motion.

3. In the Presidential government, i same person is

head of state as well as head of government.

4. In the Presidential system, the President is most

powerful.
5. In the Presidential system, the President
appoint persons from outside the legislature as
minister.

6. In the Presidential system, executive has a

fixed tenure normally, the executive head
(President) stays in power for the whole term.
It is not easy to remove him from power
through impeachment.

7. The Presidential government is democratic,

because the executive (President) is not
accountable to the legislature.
Differences between Presidential and Parliamentary
form of Government

1. In the Parliamentary form of government, there

are two heads. One is a nominal head while another
is the real head. For example, in Trinidad and
Tobago, the President is the nominal head while
the Prime Minister is the real head. The President
of T&T is the head of state while the Prime Minister
is the head of government. But in the Presidential
form of government, there is only one head. The
President of America is the head of state as well
as the head of government.
2. In the Parliamentary system, the Council of
Ministers headed by the Prime Minister is responsible
to the legislature. But in the Presidential type, the
President and his ministers are not directly responsible
to the legislature.

3. In the Parliamentary type, the Council of Ministers

will lose office if it loses the vote of confidence / no
confidence. But in the Presidential type, the President
cannot be ousted from power by a vote of no-
confidence. He can be removed from office though
impeachment which is much more difficult than the
vote of confidence/no confidence.
4. In the Parliamentary system, the government does
not enjoy a fixed tenure.” For example, in T&T the
government can stay in power for five years. But any
time during this period, the government can be removed
from power through a vote of no-confidence. In the
Presidential system, the President has generally a fixed
tenure because it is not easy to impeach him.

5. There is not strict separation of powers in the

Parliamentary type. The ministers are also members of
the legislature. But, in the Presidential type, the principle
of separation of powers is strictly followed. In the
US, the President and his Ministers (Secretaries) are
not members of the Congress.
6. In the Parliamentary system, the Prime Minister
is not fully free to choose his ministers. He has to
choose them from among the members of
Parliament. But in the Presidential system, the
President enjoys much more freedom in selecting
his ministers. He selects them from a much wider
field taking into account their experience and
expertise.

7. At the time of crisis the Presidential executive is

more successful in taking prompt and bold
decisions than the Parliamentary government.
8. The Presidential system of government
provides more political stability than the
Parliamentary form of government.

9. As the government in the parliamentary

system is responsible to the Parliament, it is
more democratic and respectful of public
opinion than the Presidential executive which is
not responsible to the legislature.
The Westminster-Whitehall Model In the Commonwealth Caribbean

1. The following quotation summarizes the essence of the

creation of the constitutional systems of government in the
Commonwealth Caribbean:

…[I]t is widely supposed that British policy, if it has ever had

any long term aims at all, has throughout the centuries of imperial
rule ‑ 'the Commonwealth experience' ‑ been at pains to
establish, even to impose, in the dependencies of the Crown a
Westminster model, irrespective of local wish or circumstance:
that the Mother of Parliaments was concerned to spawn a brood
of little Westminsters and to export them to the colonies.
Though this is the common currency of contemporary British
politicians, and of British schoolmasters, it seems on investigation to
be substantially quite untrue. (A. F. Madden, Journal of Imperial
and Commonwealth History, Vol. 8 (1) 1979).
The Westminster model has been described as:
a constitutional system in which the head of state is not
the effective head of government; in which the effective
head of government is a Prime Minister presiding over a
Cabinet composed of Ministers over whose appointment
and removal he has at least a substantial measure of
control; in which the effective executive branch of
government is parliamentary in as much as Ministers must
be members of the legislature; and in which Ministers are
collectively and individually responsible to a freely elected
and representative legislature. (S. A. de Smith, The New
Commonwealth and its Constitutions. London, Stevens
and Sons, 1964, pp. 77 ‑ 78.)
Whitehall Model

1. The Whitehall model is the name that has been given

to the systems of government that were established
in the Commonwealth Caribbean when the various
territories were granted their independence by Great
Britain. While the title was given to these systems of
government by Leslie Wolf‑Phillips, (Parliamentary
Affairs, Vol. 37(4), 1984), the structure was further
researched by Hamid Ghany for his doctoral
dissertation at the London School of Economics and
Political Science
1] All of the constitutions in the Commonwealth
Caribbean are written.

2] There are five basic tenets of the Westminster-

Whitehall model. These tenets are:
(1) a Bill of Rights in the Constitution;
(2) a unique bicameral system;
(3) a more rigid separation of powers;
(4) codification of Westminster constitutional
conventions; and,
(5) the entrenchment of constitutional
provisions.
 A Bill of Rights in the Constitution

1] The inclusion of a Bill of Rights in the

Constitution recognizes,
declares and protects the
fundamental human rights and freedoms of
the citizen.
2] The citizen is empowered to challenge the
State on the ground that his / her human
rights have been, is being or are likely to
infringed.
3] The courts are empowered to overturn
legislation or actions by the State that are
 Unique Bicameralism
1] There are 12 independent countries in the
Commonwealth Caribbean and 8 of them have
bicameral systems.
2] The 4 unicameral ones cannot be compared to the
Westminster model in the U.K.
3] The 8 bicameral ones are different from the U.K.
insofar as (1) Caribbean Senators do not enjoy
security of tenure; (2) all Senators must vacate office at
the next dissolution of Parliament.
4] In the Westminster model in the U.K., members of
the House of Lords have security of tenure and they do
not vacate their seats until death.
5] Of the 54 countries in the Commonwealth, 18 of
them have bicameral systems and 8 are in the
Commonwealth Caribbean.
 More rigid separation of powers
1] The only similarity between the Commonwealth
Caribbean and the Westminster model in the U.K. is
the overlap between a majority in the elected House
and the formation of the Executive branch of
government.
2] In the U.K., the House of Lords is both a legislative
and a judicial body.
3] In the U.K., the Lord Chancellor is a Cabinet
Minister, Officer in the House of Lords, and the Head
of the Judiciary.
4] In the Commonwealth Caribbean, there is an
Attorney General in Cabinet, a President of the
Senate to preside over the Upper House, and, a Chief
Justice as head of the Judiciary.
 Codified Constitutional Conventions
1] Most Commonwealth Caribbean countries
have U.K. constitutional conventions written into
their constitutions.
2] The effect is to create rigidity and also forced
choice for interpretation between
competing views.
3] An example of rigidity relates to the motion of
no confidence against Prime Minister Erskine
Sandiford in Barbados in 1994.
4] An example of forced choice between
competing interpretations relates to the power of
dissolution in St. Lucia, St. Vincent and the
Grenadines, and Belize in relation to the rest of the
Commonwealth Caribbean.
 Entrenched Provisions
1] There is no written constitution in the U.K. and,
therefore, nothing to entrench.
2] All of the Constitutions in the Commonwealth
Caribbean have entrenched provisions which protect
them from easy amendment.
3] There are three main types of entrenchment
procedures.
4] Special majorities in the Parliament for Bills
seeking to amend the Constitution.
5] Time delay procedures for Bills seeking to amend
the Constitution.
6] Post-parliamentary referenda for Bills passed by
Parliament seeking to amend the Constitution.