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TheWestminster system, orWestminster model, is a type ofparliamentary government modelled on that of theParliament of the United Kingdom. Key aspects of the system include anexecutive branch made up of members of the legislature which isresponsible to the legislature; the presence ofparliamentary opposition parties; and a ceremonialhead of state who is separate from thehead of government. The term derives from thePalace of Westminster, the seat of the British parliament. The Westminster system can be contrasted with thepresidential system, which originated in theUnited States,[1] and with thesemi-presidential system based on the government ofFrance.
The Westminster system is used, or was once used, in the national andsubnational legislatures of mostformer colonies of theBritish Empire upon gainingself-government, beginning with theProvince of Canada in 1848.[2] However, many former colonies have since adopted other forms of government.
The Westminster system of government may include some of the following features:[3]
Most of the procedures of the Westminster system originated with theconventions, practices, andprecedents of theParliament of the United Kingdom, which form a part of what is known as theConstitution of the United Kingdom. Unlike theuncodified British constitution, most countries that use the Westminster system havecodified the system, at least in part, in a writtenconstitution.
However, uncodified conventions, practices, and precedents continue to play a significant role in most countries, as many constitutions do not specify important elements of procedure. For example, some older constitutions using the Westminster system do not mention the existence of the cabinet or the prime minister, because these offices were taken for granted by the authors of these constitutions. Sometimes these conventions,reserve powers, and other influences collide in times of crisis and in such times the weaknesses of the unwritten aspects of the Westminster system, as well as the strengths of the Westminster system's flexibility, are put to the test. As an illustrative example, in theAustralian constitutional crisis of 1975, the Governor-General of Australia,Sir John Kerr, dismissed Prime MinisterGough Whitlam and replaced him with opposition leaderMalcolm Fraser.
| Type | Bicameral (unicameral in some circumstances) | Elected or appointed upper house to approve and/or scrutinise laws.
|
|---|---|---|
Elected lower house to represent the people and (normally) initiate legislation.
| ||
| Leadership | Head of state | Monarch (sometimes represented by avice-regal representative, such as a governor or governor-general) or ceremonial president. |
| Head of government | Usually the leader of the largest party in the lower house (legislature if unicameral).
| |
| Presiding officers of legislative chambers | Speaker (or president) of the upper house | |
| Speaker of the lower house | ||
| General | Government | Formed by the largest party/coalition in the lower house (legislature if unicameral), and led by the head of government.
|
| Opposition | Led by the leader of the opposition. A shadow cabinet is formed out of the elected members of the largest party or coalition in the legislature not in government, chosen by the party leader (the leader of the opposition). | |
| Public service | Politically independent and available to the people of the state, that will work for various government organisations (health, housing, education, defence). | |
| Armed forces | Defensive organisation of the state/country. |
The pattern of executive functions within a Westminster system is quite complex. In essence, thehead of state, usually amonarch or president, is a ceremonial figurehead who is the theoretical, nominal orde jure source of executive power within the system. In practice, such a figure does not actively exercise executive powers, even though executive authority is nominally exercised in their name.
Thehead of government, usually called theprime minister orpremier, will ideally have the support of a majority in the responsible house, and must, in any case, be able to ensure the existence of noabsolute majority against the government. If the parliament passes amotion of no confidence, or refuses to pass an importantbill such as thebudget, then the government must either resign so that a different government can be appointed or seek aparliamentary dissolution so that new general elections may be held in order to re-confirm or deny the government's mandate.
Executive authority within a Westminster system is de jure exercised by the cabinet as a whole, along with more juniorministers, however, in effect, the head of government dominates the executive as the head of government is ultimately the person from whom thehead of state will takeadvice (by constitutional convention) on the exercise ofexecutive power, including the appointment and dismissal of cabinet members. This results in the situation where individual cabinet members in effect serve at the pleasure of the prime minister. Thus the cabinet is strongly subordinate to the prime minister as they can be replaced at any time, or can be moved ("demoted") to a different portfolio in acabinet reshuffle for "underperforming".
In the United Kingdom, the sovereign theoretically holds executive authority, even though theprime minister and thecabinet effectively implement executive powers. In aparliamentary republic like India, thepresident is thede jure executive, even though executive powers are essentially instituted by theprime minister and theCouncil of Ministers. InIsrael, however, executive power is vestedde jure andde facto in the cabinet and thepresident isde jure andde facto a ceremonial figurehead.
As an example, the prime minister and cabinet (as thede facto executive body in the system) generally must seek the permission of the head of state when carrying out executive functions. If, for instance theBritish prime minister wished todissolve Parliament in order for ageneral election to take place, the prime minister is constitutionally bound to request permission from thesovereign in order to attain such a wish. However, the sovereign, in modern times, has virtually always followed the advice of their prime minister without their own agency. This owes to the fact that the British sovereign is aconstitutional monarch: he or she abides by the advice of his or her ministers, except when executingreserve powers in times of crisis. The sovereign's power to appoint and dismiss governments, appoint cabinetministers to serve in the government, appointdiplomats, declarewar, and to signtreaties (among other powers de jure held by the sovereign) is known as theroyal prerogative, which in modern times is exercised by the sovereign solely on theadvice of the Prime Minister.
This custom also occurs in other countries are regions around the world using the Westminster System, as a legacy ofBritish colonial rule. InCommonwealth realms such as Canada, Australia and New Zealand, the day-to-day functions that would be exercised by the sovereign personally in the United Kingdom are instead exercised by thegovernor-general. In such nations, the prime minister is obligated to formally seek permission from thegovernor-general when implementing executive decisions, in a manner similar to the British system.
An analogous scenario also exists inrepublics in the Commonwealth of Nations, such asIndia orTrinidad and Tobago, where there is a president who functions similarly to a governor-general.
An unusual case lies inIsrael andJapan, where the respective prime ministers have the full legal power to implement executive decisions, andpresidential (in Israel) orimperial (in Japan) approval is not required; the prime ministers of these nations are fully thede jure source of executive authority, and not the head of state.
The head of state will often hold meetings with the head of government and cabinet, as a means of keeping abreast of governmental policy and as a means of advising, consulting and warning ministers in their actions. Such a practice takes place in the United Kingdom and India. In the UK, the sovereign holds confidential weekly meetings with the prime minister to discuss governmental policy and to offer his or her opinions and advice on issues of the day. In India, the prime minister is constitutionally bound to hold regular sessions with the president, in a similar manner to the aforementioned British practice. In essence, the head of state, as the theoretical executive authority, "reigns but does not rule". This phrase means that the head of state's role in government is generally ceremonial and as a result does not directly institute executive powers. Thereserve powers of the head of state are sufficient to ensure compliance with some of their wishes. However, the extent of such powers varies from one country to another and is often a matter of controversy.
Such an executive arrangement first emerged in the United Kingdom. Historically, theBritish sovereign held and directly exercised all executive authority.George I of Great Britain (reigned 1714 to 1727) was the first British monarch to delegate some executive powers to a prime minister and a cabinet of the ministers,[citation needed] largely because he was also the monarch ofHanover in Germany and did not speak English fluently. Over time, further arrangements continued to allow the execution of executive authority on the sovereign's behalf and more and more de facto power ended up lying in thePrime Minister's hands. Such a concept was reinforced inThe English Constitution (1876) byWalter Bagehot, who distinguished between the separate "dignified" and "efficient" functions of government. The sovereign should be a focal point for thenation ("dignified"), while the PM and cabinet actually undertook executive decisions ("efficient").[7]
Theelectoral system is often set out in aRepresentation of the People Act.[8][9] Common ministerial titles includeparliamentary secretary andunder-secretary. Ministers are supported byprivate secretaries and government departments are run bypermanent secretaries,principal secretaries orchief secretaries.
Thehead of state or their representative (such as agovernor-general) formally appoints as thehead of government whoever commands theconfidence of thelower orsole house of the legislature and invites him or her to form a government. In the UK, this is known askissing hands. Although the dissolution of the legislature and the call for new elections is formally performed by the head of state, the head of state, by convention, acts according to the wishes of the head of government.
A president, monarch, or governor-general might possess clearly significantreserve powers. Examples of the use of such powers include theAustralian constitutional crisis of 1975 and the CanadianKing–Byng affair in 1926. TheLascelles Principles were an attempt to create a convention to cover similar situations, but have not been tested in practice. Because of differences in their written constitutions, the formal powers of monarchs, governors-general, and presidents vary greatly from one country to another. However, as sovereigns and governors-general are not elected, and some presidents may not be directly elected by the people, they are often shielded from any public disapproval stemming from unilateral or controversial use of their powers.
In manyCommonwealth realms a governor-general formally represents the monarch, who is usually absent from the realm. In such countries, the identity of the "head of state" may be unclear.[10]
In the bookThe English Constitution,Walter Bagehot emphasised the divide of the constitution into two components, the Dignified (that part which is symbolic) and the Efficient (the way things actually work and get done), and called the Efficient "Cabinet Government".[7]
Members of the Cabinet are collectively seen as responsible for government policy, a policy termedcabinet collective responsibility. All Cabinet decisions are made by consensus, a vote is rarely taken in a Cabinet meeting. All ministers, whether senior and in the Cabinet, or junior ministers, must support the policy of the government publicly regardless of any private reservations. When aCabinet reshuffle is imminent, a lot of time is taken up in the conversations of politicians and in the news media, speculating on who will, or will not, be moved in and out of the Cabinet by the Prime Minister, because the appointment of ministers to the Cabinet, and threat of dismissal from the Cabinet, is the single most powerful constitutional power which a Prime Minister has in the political control of the Government in the Westminster system.
TheOfficial Opposition and other major political parties not in the Government, will mirror the governmental organisation with their ownShadow cabinet made up of Shadow Ministers.
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In a Westminster system, some members of parliament are elected by popular vote, while others are appointed. Nearly all Westminster-based parliaments have alower house with powers based on those of theHouse of Commons (under various names), comprising local, elected representatives of the people (withthe only exception being elected entirely by nationwide Proportional Representation). Most also have a smaller upper house, which is made up of members chosen by various methods:
In the UK, the lower house is thede facto legislative body, while the upper house practices restraint in exercising its constitutional powers and serves as a consultative body. In other Westminster countries, however, the upper house can sometimes exercise considerable power, as is the case for the Australian Senate.
Some Westminster-derived parliaments areunicameral for two reasons:
Hong Kong, a former Britishcrown colony and currently aspecial administrative region of thePeople's Republic of China, has a unicameralLegislative Council. While the Legislative Councils in British Australasian and North American colonies were unelected upper houses and some of them had since abolished themselves, the Legislative Council of Hong Kong has remained the sole chamber and had in 1995 evolved into a fully elected house, yet only 20 of the 90 seats are returned by universal suffrage. Responsible government was never granted during British colonial rule, and theGovernor remained thehead of government until the transfer of sovereignty in 1997, when the role was replaced by theChief Executive. Secretaries had remained to be chosen by the Chief Executive not from the Legislative Council, and their appointments need not be approved by the Legislative Council. Although essentially more presidential than parliamentary, the Legislative Council had inherited many elements of the Westminster system, including parliamentary powers, privileges and immunity, and the right to conduct inquiries, amongst others. The theme colour of the meeting chamber is red as in other upper houses. The Chief Executive may dissolve the Legislative Council under certain conditions, and is obliged to resign, e.g., when a re-elected Legislative Council passes again a bill that he or she had refused to sign.
The waters of theThames and of thePotomac both flow intoLake Burley Griffin.
Australian constitutional law is, in many respects, a unique hybrid with influences from theUnited States Constitution as well as from the traditions and conventions of the Westminster system and some indigenous features. Australia is exceptional because the government faces a fully elected upper house, theSenate, which must be willing to pass all its legislation. Although government is formed in the lower house, the House of Representatives, the support of the Senate is necessary in order to govern.[12][13][14][15][16][17]
The Australian Senate is unusual in that it maintains an ability towithhold supply from the government of the day – a power similar to that held in the UKuntil 1911 by the House of Lords, which has since then been impossible, in the Westminster system. A government that has lost supply is severely restricted in its abilities to act; unless a solution can be negotiated and supply can be restored, such an occurrence would normally trigger a federal election. Since thegovernor-general, technically speaking, can dismiss a federal government at any time, loss of supply is sometimes, controversially, considered a suitable trigger for a dismissal (such as with the1975 Australian constitutional crisis). This is controversial because it conflicts with the Westminster tradition of government by a party with the confidence of the lower house (not an upper house like the Senate). Some political scientists have held that theAustralian system of government was consciously devised as a blend or hybrid of the Westminster and theUnited States systems of government, especially since the Australian Senate is a powerful upper house like the US Senate; this notion is expressed in the nickname "the Washminster mutation".[18] The ability of upper houses to block supply also features in theparliaments of most Australian states.
The Australian system has also been referred to as asemi-parliamentary system.[19]
The Westminster system has a very distinct appearance when functioning, with many British customs incorporated into day-to-day government function. A Westminster-style parliament is usually a long, rectangular room, with two rows of seats and desks on either side. Many chambers connect the opposing rows, either with a perpendicular row of seats and desks at the furthermost point from the Speaker's Chair at the opposite end of the chamber (e.g. UK House of Lords or Israel Knesset) or the rows of chairs and desks are rounded at the end, opposite to the Speaker's Chair (e.g. Australian chambers, Ireland, South Africa, India). The chairs in which both the government and opposition sit, are positioned so that the two rows are facing each other. This arrangement is said to have derived from an early Parliament which was held in achurchchoir. Traditionally, the opposition parties will sit in one row of seats, and the government party will sit in the other. In some countries, the mace will face the government’s side whilst lying on thetable of the House. In mostmajority governments, the number of government-party MPs is so large that it must use the "opposition" seats as well. In the lower house at Westminster (the UK's House of Commons) there are lines on the floor in front of the government and opposition benches that members may cross only when exiting the chamber.
At one end of the room sits a large chair, for theSpeaker of the House. The speaker usually wears black robes, and in some countries, awig. Robed parliamentaryclerks often sit at narrow tables between the two rows of seats, as well. These narrow tables in the centre of the chamber, is usually where ministers or members of the house come to speak. A newly elected Speaker is symbolically dragged to the Chair upon being elected.
Other ceremonies sometimes associated with the Westminster system include an annualSpeech from the Throne (or equivalent thereof) in which the head of state gives a special address (written by the government) to parliament about what kind of policies to expect in the coming year, and lengthyState Opening of Parliament ceremonies that often involve the presentation of a largeceremonial mace. Some legislatures retain Westminster's colour-coded chambers, with the upper houses associated with the colour red (after the House of Lords) and the lower with green (after the House of Commons). This is the case in India, Australia, Canada, New Zealand, and Barbados.
Countries that use variations on the theme of the Westminster system, as of 2023, include the following:
| Country | Legislature | System ofgovt. | Notes/Differences from the standard Westminster model |
|---|---|---|---|
 Antigua and Barbuda | Parliament: Senate House of Representatives | Monarchy | |
 Australia | Parliament: Senate House of Representatives | Monarchy | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and state governments. Lower house is elected usinginstant-runoff voting. Upper house is elected bysingle transferable vote (a form ofproportional representation) with each state and territory treated as individual electorates.Queensland has a unicameralstate parliament while all other states have bicameral parliaments. TheAustralian Capital Territory and theNorthern Territory have unicameral legislatures. |
 The Bahamas | Parliament: Senate House of Assembly | Monarchy | |
 Bangladesh | Jatiya Sangsad | Republic | Allows some extra-parliamentary ministers to be appointed, which is a variation from the strict monism of most Westminster systems. |
 Barbados | Parliament: Senate House of Assembly | Republic | |
 Belize | National Assembly: Senate House of Assembly | Monarchy | |
 Canada | Parliament: Senate House of Commons | Monarchy | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and provincial governments. Caucuses requireofficial party status for some parliamentary privileges. Two of its territorial parliaments operatewithout any caucuses other than cabinet, and therefore have no leader of the opposition. |
 Cayman Islands | Parliament | Monarchy | British Overseas Territory, meaning ultimate authority for its government resides with the UK Parliament in Westminster |
 Denmark | Folketing | Monarchy | Essentially identical to the Westminster system in function, but developed independently, though with inspiration from the UK[citation needed].Proportional representation is used to elect theFolketing. One of five countries other than the UK to use a Westminster system witha native monarch, along with Japan, Lesotho, Malaysia, and Thailand. |
 Dominica | House of Assembly | Republic | |
 Fiji | Parliament | Republic | |
 Grenada | Parliament: Senate House of Representatives | Monarchy | |
 India | Parliament: Rajya Sabha Lok Sabha | Republic | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and state governments. TheLok Sabha (lower house) is popularly elected via first past the post. TheRajya Sabha (upper house) is mostly elected by the members of state/union territory legislatures usingsingle transferable vote with a handful of members being appointed by thePresident of India. |
 Ireland | Oireachtas: Seanad Éireann Dáil Éireann | Republic | Dáil Éireann (the lower house) is elected by universal suffrage by single transferable vote from constituencies of 3 to 5 members.President is directly elected using instant-runoff voting. The Head of government has the title ofTaoiseach (in theIrish language meaning roughly "captain" or "leader") and is appointed by the president on the nomination of the Dáil. |
 Italy | Italian Parliament: Senate of the Republic Chamber of Deputies | Republic | Very similar to the Westminster system but developed independently, though with inspiration from the UK[citation needed]. Notably, theItalian Parliament employsperfect bicameralism, with theSenate of the Republic andChamber of Deputies exercising identical powers; thus, a government must maintain majorities in both. The Chamber of Deputies and most of the Senate are directly elected throughparallel voting. Five people appointed by thePresident of Italy, as well as previous Presidents of Italy, serve assenators for life. |
 Israel | Knesset | Republic | Modified Westminster system[citation needed]: Powers which would have been exercised by thePresident of Israel are divided between thePrime Minister, the Cabinet, and the speaker of the legislature. The Prime Minister was directly elected from 1996 to 2001.[20]Closed listparty-list proportional representation is used to elect members to the Knesset. |
 Japan | National Diet: House of Councillors House of Representatives | Monarchy | Modified Westminster system[citation needed]: many non-reserve powers which would have been exercised by theEmperor of Japan on the advice of theCabinet in an unmodified system are exercised directly by thePrime Minister, and Imperialreserve powers do not exist. Both houses of theNational Diet are elected usingparallel voting. One of five countries other than the UK to use a Westminster system witha native monarch, along with Denmark, Lesotho, Malaysia, and Thailand. |
 Jamaica | Parliament: Senate House of Representatives | Monarchy | |
 Lesotho | Parliament: Senate National Assembly | Monarchy | Constitutional monarchy that operates under a Westminster system. One of five countries other than the UK to use a Westminster system witha native monarch, along with Denmark, Japan, Malaysia, and Thailand. |
 Malaysia | Parliament: Dewan Negara Dewan Rakyat | Monarchy (elective) | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and state governments. The Yang-di-Pertuan Agong shares characteristics of heads of state in both monarchies and republics. |
 Malta | Parliament | Republic | |
 Mauritius | National Assembly | Republic | |
 Nepal | Parliament: National Assembly House of Representatives | Republic[21] | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and state governments. |
 New Zealand | Parliament | Monarchy | Usesmixed-member proportional representation to elect members to its unicameral Parliament.Several seats in NZ Parliament arereserved for election by IndigenousMāori voters. |
 Pakistan | Parliament: Senate National Assembly | Republic | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and provincial governments. |
 Papua New Guinea | Parliament | Monarchy | One significant deviation it has from the traditional Westminster model is that a person is nominated for the position ofGovernor-General not by thePrime Minister but by a majority vote in Parliament, then they are appointed by the monarch. Members are elected to the Parliament by instant-runoff voting. |
 Saint Kitts and Nevis | National Assembly | Monarchy | Federated nation, meaning that the power to govern the country and its people is shared and divided between national and subnational governments. |
 Saint Lucia | Parliament: Senate House of Assembly | Monarchy | |
 Saint Vincent and the Grenadines | House of Assembly | Monarchy | |
 Samoa | Legislative Assembly | Republic | |
 Singapore | Parliament | Republic | President is directly elected byfirst-past-the-post voting. |
 Solomon Islands | Parliament of the Solomon Islands | Monarchy | One significant deviation it has from the traditional Westminster model is that a person is nominated for the position ofGovernor-General not by thePrime Minister but by a majority vote in Parliament, then they are appointed by the monarch, similar to neighboring Papua New Guinea. |
 Thailand | National Assembly: Senate House of Representatives | Monarchy | Political parties must nominate a person they want to beprime minister to theElection Commission before the general election, a party can nominate of candidate list up to three names, the nominee does not have to be a member of the party, and a political parties must receive at least 5% of the seats in theHouse of Representatives in order to be able to nominate the person that the party previously proposed to the Election Commission to the House of Representatives for approval. Members of the House of Representatives are elected using parallel voting. One of five countries other than the UK to use a Westminster system witha native monarch, along with Denmark, Japan, Lesotho, and Malaysia. |
 Trinidad and Tobago | Parliament: Senate House of Representatives | Republic | |
 Tuvalu | Parliament | Monarchy | |
 United Kingdom | Parliament: House of Lords House of Commons | Monarchy | Between 2011 (Fixed-term Parliaments Act 2011) and 2022 (Dissolution and Calling of Parliament Act 2022), the Prime Minister did not have the ability to call early elections. |
 Vanuatu | Parliament | Republic |
The Westminster system was adopted by a number of countries which subsequently evolved or reformed their system of government departing from the original model. In some cases, certain aspects of the Westminster system were retained or codified in their constitutions. For instanceSouth Africa andBotswana, unlike Commonwealth realms or parliamentary republics such as India, have a combined head of state and head of government but the President remains responsible to the lower house of parliament; it elects the President at the beginning of a new Parliament, or when there is a vacancy in the office, or when the sitting President is defeated on a vote of confidence. If the Parliament cannot elect a new President within a short period of time (a week to a month) the lower house is dissolved and new elections are called.
Ireland between the 14th century and 1800 (seeParliament of Ireland), when theAct of Union joined it withGreat Britain to form theUnited Kingdom.
Union of South Africa between 1910 and 1961, and theRepublic of South Africa between 1961 and 1984. The 1983 constitution abolished the Westminster system in South Africa.
Dominion of Newfoundland between 1907 and 1934, the year self-government was suspended and theCommission of Government assumed direct rule from London. Use of the Westminster system resumed in 1949 whenNewfoundland became aprovince ofCanada.
Rhodesia between 1965 and 1979, and
Zimbabwe between 1980 and 1987. The 1987 constitution abolished the Westminster system.
Nigeria following the end of British colonial rule in 1960, which resulted in the appointment of a Governor-General and then a President,Nnamdi Azikiwe. The system ended with themilitary coup of 1966.
Ceylon between 1948 and 1972, and
Sri Lanka from 1972 until 1978 when the constitution was remodelled into an Executive presidential system.
Burma following independence in 1948 until the 1962 military coup d'état.
Ghana between 1957 and 1960, then 1969 and 1972.
State of Somaliland during its brief independence in 1960, withMuhammad Haji Ibrahim Egal as its first and only Prime Minister.
Eswatini (then known as Swaziland) between 1968 and 1973.
Tanganyika between 1961 and 1962.
Sierra Leone between 1961 and 1971.
Uganda between 1962 and 1963.
Indonesia between 1949 and 1959.
Kenya between 1963 and 1964.
Malawi between 1964 and 1966.
The Gambia between 1965 and 1970.
Guyana between 1966 and 1980.
Kingdom of Iraq between 1921 and 1958; during the monarchy, the Parliament of Iraq was a bicameral parliament made of an upper house of lords and a lower house of commons and was modelled after the Westminster system with some adjustments.
Kingdom of Egypt between 1923 and 1953; after the1919 Egyptian revolution the Parliament of Egypt was made to follow the exact model of the Westminster system.
Kingdom of Afghanistan between 1964 andthe end of the monarchy in 1973.
Empire of Japan between 1890 and 1940; under theMeiji Constitution theDiet of Japan was a bicameral legislature modelled after both the GermanReichstag and the Westminster system.[22] Influence from the Westminster system remained in Japan'sPostwar Constitution.[23][24][25]
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