Under somepresidential systems, such asSouth Korea andPeru, the prime minister is the leader or the most senior member of the cabinet, but not the head of government. As such, in South Korea, the prime minister is equivalent to that of a vice president which is the second in-command and assumes the presidency in the absence of the president.
In many systems, the prime minister selects and may dismiss other members of the cabinet, and allocates posts to members within the government. In most systems, the prime minister is the presiding member andchairman of the cabinet. In a minority of systems, notably insemi-presidential systems, a prime minister is the official appointed to manage thecivil service and execute the directives of thehead of state.
Today, the prime minister is often, but not always, a member of the legislature or its lower house, and is expected with other ministers to ensure the passage of bills through thelegislature. In somemonarchies the monarch may also exercise executive powers (known as theroyal prerogative) without the approval of parliament.
The term "prime minister" is attested in 17th century sources referring toCardinal Richelieu,[1] after he was namedpremier ministre to head the Frenchroyal council in 1624. The title was used alongside theprincipal ministre d'État ("chief minister of the state") more as a job description. After 1661,Louis XIV and his descendants refused to allow one of their Ministers to be more important than the others, so the term was no longer in use.[2]
In the 18th century in the United Kingdom, members of parliament disparagingly used the title in reference toSir Robert Walpole (whose official title wasFirst Lord of the Treasury). During the whole of the 18th century, Britain was involved in a prolonged conflict with France, periodically bursting into all-out war, and Britons took outspoken pride in their "Liberty" as contrasted to the "Tyranny" of French Absolute Monarchy; therefore, being implicitly compared with Richelieu was no compliment to Walpole. Over time, however, the title became honorific[where?] and remains so in the 21st century.[3]
The position of a head of government separate from the head of state, or as the most important government administrator or minister after the monarch in rank developed in multiple countries separate from each other. The names given could be "prime minister", although other terms were also used such as "chief minister", "grand chancellor", "chancellor", "grand vizier", "counselor", and others.
The literal title itself can be traced back to theAbbasid caliphate and theOttoman Empire . They both had an official title ofGrand Vizier simply theHead of the Government which is calledPrime Minister nowadays. The Grand Vizier was the most powerful person aftersultan but sometimes theGrand Vizier of Ottoman Empire was more powerful than sultan himself.[4][5][6] The position ofChancellor is the same or comparable in some countries as a prime minister, even if the label is different. The term goes back to ancient Roman times as head of the chancellery. This title as head of government or the administration existed in ancient China asGrand Chancellor (Chinese: 宰相; pinyin:Zǎixiàng), sometimes translated as "prime minister", existed since 685 BCE and ancient JapanChancellor of the Realm (太政大臣Daijō-daijin) since the 7th century CE. In theHoly Roman Empire the position ofArchchancellor was the highest dignitary and traces to 860 CE, out of which later derived the positions of head of government such as the modernChancellor of Germany, who is head of the federal government and an executive prime minister.
The power of these ministers depended entirely on the personal favour of the monarch. Although managing the parliament was among the necessary skills of holding high office, they did not depend on a parliamentary majority for their power. Although there was acabinet, it was appointed entirely by the monarch, and the monarch usually presided over its meetings.
The monarch could dismiss the minister at any time, or worse: Cromwell was executed and Clarendon driven into exile when they lost favour. Kings sometimes divided power equally between two or more ministers to prevent one minister from becoming too powerful. Late in Anne's reign, for example, theTory ministersHarley andViscount Bolingbroke shared power.
In the mid 17th century, after theEnglish Civil War (1642–1651), Parliament strengthened its position relative to the monarch then gained more power through theGlorious Revolution of 1688 and passage of theBill of Rights in 1689.[7] The monarch could no longer establish any law or impose any tax without its permission and thus the House of Commons became a part of the government. It is at this point that a modern style of prime minister begins to emerge.[8][9]
A tipping point in the evolution of the prime ministership came with the death of Anne in 1714 and the accession ofGeorge I to the throne. George spoke no English, spent much of his time at his home inHanover, and had neither knowledge of, nor interest in, the details of British government. In these circumstances it was inevitable that the king's first minister would become thede facto head of the government.
From 1721, this was theWhig politicianRobert Walpole, who held office for twenty-one years. Walpole chaired cabinet meetings, appointed all the other ministers, dispensed the royal patronage and packed theHouse of Commons with his supporters. Under Walpole, the doctrine of cabinet solidarity developed. Walpole required that no minister other than himself have private dealings with the king, and also that when the cabinet had agreed on a policy, all ministers must defend it in public, or resign. As a later prime minister,Lord Melbourne, said, "It matters not what we say, gentlemen, so long as we all say the same thing."
Walpole always denied that he was "prime minister", and throughout the 18th century parliamentarians and legal scholars continued to deny that any such position was known to the Constitution.George II andGeorge III made strenuous efforts to reclaim the personal power of the monarch, but the increasing complexity and expense of government meant that a minister who could command the loyalty of the Commons was increasingly necessary. The long tenure of the wartime prime ministerWilliam Pitt the Younger (1783–1801), combined with the mental illness of George III, consolidated the power of the post. The title "prime minister" was first referred to on government documents during the administration ofBenjamin Disraeli but did not appear in the formal BritishOrder of precedence until 1905.
The prestige of British institutions in the 19th century and the growth of theBritish Empire saw the British model of cabinet government, headed by a prime minister, widely copied, both in other European countries and in British colonial territories as they developed self-government.[10][11][12] In some places alternative titles such as "premier", "chief minister", "first minister of state", "president of the council" or "chancellor" were adopted, but the essentials of the office were the same.
Royal decree appointing the Prime Minister of Cambodia in 2023
In the late 20th century,[13][14] many of the world's countries had prime ministers or equivalent ministers, holding office under eitherconstitutional monarchies or ceremonial presidents. The main exceptions to this system include Switzerland and the United States, as well as the presidential republics in Latin America, such as Chile and Mexico, modelled on the U.S. system in which the president directly exercises executive authority.
Bahrain's former prime minister,SheikhKhalifah bin Sulman Al Khalifah, occupied the post for about 50 years, from 1970 to November 2020, making him the longest serving non-elected prime minister.
Appointment of the prime minister of France does not require any approval by the parliament either, but the parliament may force the resignation of the government. In these systems, it is possible for the president and the prime minister to be from different political parties if the legislature is controlled by a party different from that of the president. When it arises, such a state of affairs is usually referred to as (political)cohabitation.[15]
In parliamentary systems a prime minister may enter into office by several means.
The head of state appoints a prime minister, of their personal choice: Example:France, where the president has the power to appoint the prime minister of their choice, though theNational Assembly can force a government to resign, they cannot nominate or appoint a new candidate.
While in practice most prime ministers under theWestminster system (including Australia, Canada, New Zealand,Malaysia, India and the United Kingdom) are the leaders of the largest party orcoalition in parliament, technically the appointment of the prime minister isde jure exercised by the head of state.
The head of state appoints a prime minister who has a set timescale within which they must gain a vote of confidence: Example:Italy,Romania
The head of state appoints aformateur from among the members of Parliament, who then has a set timescale within which they must form a cabinet, and receive the confidence of Parliament after presenting the Cabinet Composition and Legislative Program to Parliament, and the formateur becomes prime minister once approved by parliament: Example: Israel
The head of state appoints the leader of the political party with the majority of the seats in the parliament as prime minister. If no party has a majority, then the leader of the party with a plurality of seats is given anexploratory mandate to receive the confidence of the parliament within three days. If this is not possible, then the leader of the party with the second highest seat number is given the exploratory mandate. If this fails, then the leader of the third largest party is given it and so on: Example: Greece, seePrime Minister of Greece
The head of statenominates a candidate for prime minister who is then submitted to parliament for approval before appointment as prime minister: Example: Spain, where the King sends a nomination to parliament for approval. Also Germany where under theGerman Basic Law (constitution) theBundestag votes on a candidate nominated by the federal president. In the Philippines under the 1973 Constitution as amended after martial law, the prime minister was elected by theBatasang Pambansâ (Legislature) upon nomination by the president. In these cases, parliament can choose another candidate who then would be appointed by the head of state (or, in the case of the Philippines, outright elect that candidate).
Parliamentnominates a candidate who the head of state is then constitutionally obliged to appoint as prime minister: Example:Ireland, where thepresident appoints theTaoiseach on the nomination ofDáil Éireann. AlsoJapan,Thailand.
Election by the legislature: Example:Solomon Islands andVanuatu. Also thePhilippines under the unamended 1973 Constitution, where the prime minister was supposed to be elected by the Batasang Pambansâ; these provisions were never used because the Philippines was under martial law at the time.
Direct election by popular vote: Example:Israel, 1996–2001, where the prime minister was elected in a general election, with no regard to political affiliation.
Nomination by a state office holder other than the head of state or his or her representative: Example: Under the modern SwedishInstrument of Government, the power to appoint someone to form a government has been moved from themonarch to the speaker of the parliament and the parliament itself. The speaker nominates a candidate, who is then elected to prime minister (statsminister) by the parliament if an absolute majority of the members of parliament does not vote no (i.e. the candidate can be elected to the post even if more MP:s voteno thanyes).
In older, convention-basedparliamentary systems, prime ministers are not appointed for a specific term in office and in effect may remain in power through a number ofelections and parliaments. For example,Margaret Thatcher was only ever appointed prime minister onone occasion, in 1979. She remainedcontinuously in power until 1990, though she used the assembly of eachHouse of Commons after ageneral election toreshuffle her cabinet.
Newer parliamentary systems that operate based on a codified constitution, however, do have a term of office of the prime minister linked to the period in office of the parliament. Hence, for example, Latvian prime ministerKrišjānis Kariņš, who wasfirst appointed in 2018, had to be reappointed as head ofa new government following the2022 Latvian parliamentary election.
The position of prime minister is usually chosen from the political party that commands – whether by itself or as the largest member of a coalition – the majority of seats in the lower house of parliament, though this is not a requirement either; for example, following the2018 Latvian parliamentary election, after two failed attempts by larger parties to form a coalition headed by them, the leader of the smallest party in parliament –Krišjānis Kariņš – was eventually appointed as a compromise candidate.Italy has seen several emergencytechnocratic governments, such asCarlo Azeglio Ciampi's andMario Draghi's governments, where the prime minister was a non-partisan expert backed by theconfidence and supply of abroad cross-section of the parliament.
In parliamentary systems,governments are generally required to have the confidence of thelower house of parliament (though a small minority of parliaments, by giving a right to blocksupply toupper houses, in effect make thecabinet responsible to both houses, though in reality upper houses, even when they have the power, rarely exercise it). Where they lose avote of confidence, have amotion of no confidence passed against them, or where they lose supply, mostconstitutional systems require either:
a letter of resignation or
a request for parliamentary dissolution.
The latter in effect allows the government to appeal theopposition of parliament to theelectorate. However, in manyjurisdictions a head of statemay refuse a parliamentary dissolution, requiring the resignation of the prime minister and his or her government. In most modern parliamentary systems, the prime minister is the person who decides when to request a parliamentary dissolution.
Older constitutions often vest this power in thecabinet. In the United Kingdom, for example, the tradition whereby it is the prime minister who requests a dissolution of parliament dates back to 1918. Prior to then, it was theentire government that made the request. Similarly, though the modern 1937 Irish constitution grants to the Taoiseach the right to make the request, the earlier 1922Irish Free State Constitution vested the power in theExecutive Council (the then name for the Irish cabinet).
Some systems, such asGermany andSpain, require motions of no confidence to beconstructive: i.e., they must include the name of an alternative prime minister; if the motion of no confidence is successful, the alternative prime minister automatically takes office in place of the incumbent government, which cannot appeal this replacement to the electorate.
The prime minister's executive office is usually called the Office of the Prime Minister orCabinet Office. The U.K.’sCabinet Office includes the Prime Minister’s Office. Conversely, some Prime Minister's Offices incorporate the role of Cabinet, while Australia’s Department of the Prime Minister and Cabinet joins them at par. In Israel, the prime minister's executive office is officially titled the "Prime Minister's Office" in English, but the original Hebrew term can also be translated as the Prime Minister's Ministry. The Prime Minister's Department is also used, as is Cabinet Department.
Wilfried Martens, who served as Prime Minister of Belgium, described his role as follows:
First of all the Prime Minister must listen a lot, and when deep disagreements occur, he must suggest a solution to the matter. This can be done in different ways. Sometimes during the discussion, I note the elements of the problem and think of a proposal I can formulate to the Council (cabinet), the Secretary taking notes. The Ministers then insist on changing game ages. The Prime Minister can also make a proposal which leaves enough room for amendments in order to keep the current discussion on the right tracks. When a solution must be found in order to reach a consensus, he can force one or two Ministers to join or resign.[citation needed]
In many cases, though commonly used, "prime minister" is not the official title of the office-holder. In theRussian constitution, the prime minister is titledChairman of the government. The Irish prime minister is called theTaoiseach (which is rendered into English asprime minister), inIsrael the prime minister isRosh HaMemshalah, meaning "head of the government", and the Spanish prime minister is thePresident of the Government (Presidente del Gobierno). The head of government of thePeople's Republic of China is referred to as thePremier of the State Council.[16]
It is convention in the English language to call nearly all national heads of government "prime minister" (or sometimes the equivalent term "premier"), except in cases where the head of state and head of government are one position (usually a presidency), regardless of the correct title of the head of government as applied in his or her respective country. The few exceptions to the rule are Germany and Austria, whose head of government's title is FederalChancellor; Monaco, whose head of government is referred to as the Minister of State; and Vatican City, for which the head of government is titled the Secretary of State. A stand-out case is the president of Iran, who is not actually a head of state, but the head of the government of Iran. He is referred to as "president" in both thePersian and English languages.
In the UK, where devolved government is in place, the leaders of theScottish,Northern Irish andWelsh Governments are styledFirst Minister. Between 1921 and 1972, when Northern Ireland had amajority rule Parliament, the head of government was theprime minister of Northern Ireland. InBangladesh, the prime minister is calledProdhān Montrī, literally meaning "the head of ministers" or "prime minister". In India, the prime minister is calledPradhān Mantrī, literally meaning "the head of ministers" or "prime minister". In Pakistan, the prime minister is referred to asWazir-e-Azam, meaning "grand vizier".
Constitutional basis for the position in different countries
English: Prime Minister of the Republic of Singapore Malay: Perdana Menteri Republik Singapura Chinese: 新加坡共和国总理, Xīnjiāpō gònghéguó zǒnglǐ Tamil: சிங்கப்பூர் குடியரசின் பிரதமர், Ciṅkappūr kuṭiyaraciṉ piratamar
Bangladesh'sconstitution clearly outlines the functions and powers of theprime minister, and also details the process of his/her appointment and dismissal.
Canada has a 'mixed' or hybridconstitution, partly formally codified and partly uncodified. The codified part originally made no reference whatsoever to a prime minister[18] and still gives no parameters of the office. Instead, their powers, duties, appointment and termination follow uncodified conventions. TheConstitution Act, 1867 only establishes theQueen's Privy Council for Canada, to which all federal ministers (among others) are appointed and with Members[note 3] of which the Monarch or their Governor General normally performs executive government (asKing- or Governor-in-Council).[19] TheConstitution Act, 1982, adds passing reference to the "Prime Minister of Canada" [French:premier ministre du Canada] but as detail ofconferences of federal and provincialfirst ministers.)[20]
India'sconstitution (1950) lists the powers, functions and duties of theprime minister of India. In India, prime ministerial candidates must be a member of parliament, i.e. of either the Lok Sabha (Lower House) or Rajya Sabha (Upper House). No parliamentary vote takes place on who forms a government.
Ireland'sconstitution (1937), provides for the office ofTaoiseach in detail, listing powers, functions and duties.
TheUnited Kingdom'sconstitution, beinguncodified and largely unwritten, makes no mention of aprime minister. Though it hadde facto existed for centuries, its first mention in official state documents did not occur until the first decade of the twentieth century. Accordingly, it is often said "not to exist"; indeed there are several instances of parliament declaring this to be the case. The prime minister sits in the cabinet solely by virtue of occupying another office, eitherFirst Lord of the Treasury (office in commission) or more rarelyChancellor of the Exchequer (the last of whom wasBalfour in 1905).
In such systems unwritten (and unenforceable) constitutional conventions often outline the order in which people are asked to form a government. If the prime minister resigns after a general election, the monarch usually asks the leader of the opposition to form a government. Where however a resignation occurs during a parliament session (unless the government has itself collapsed) the monarch will ask another member of the government to form a government. While previously the monarch had some leeway in whom to ask, all British political parties now elect their leaders (until 1965 theConservatives chose their leader by informal consultation). The last time the monarch had a choice over the appointment occurred in 1963 when theEarl of Home was asked to become prime minister ahead ofRab Butler.
During the period between the time it is clear that the incumbent government has been defeated at a general election, and the actual swearing-in of the new prime minister by the monarch, governor-general, or president, that person is referred to as the "prime minister-elect" or "prime minister-designate". Neither term is strictly correct from a constitutional point of view, but they have wide acceptance. In a situation in which a ruling party elects or appoints a new leader, the incoming leader will usually be referred as "prime minister-in-waiting". An example or this situation was in 2016 in the United Kingdom whenTheresa May was elected leader of theConservative Party whileDavid Cameron was still prime minister.
^ The posts of Prime Minister and First Lord of the Treasury are separate and need not be held by the one person, though the last prime minister not to be First Lord of the Treasury was Lord Salisbury at the turn of the 20th century.10 Downing Street is actually the First Lord's residence, not the prime minister's. As Salisbury was not First Lord, he had to live elsewhere as prime minister.
^ Although the roles of the Spanish head of government coincide with the definition of a 'prime minister', in Spain the position is in fact referred to as 'the Presidency of the Government'.
^Which Members, though, are left to uncodified convention. As appointment to the Privy Council normally lasts for life,former Cabinet ministers predominate. The convention ofResponsible Government, however, requires the Governor General to only act on the advice of the current Cabinet (or its ministers relevant to the issue at hand).
^Ancien RégimeArchived 31 October 2018 at theWayback Machine in Encyclopédie Larousse ("Après 1661, Louis XIV impose une nouvelle formule, qui joue à la fois sur les ministres et sur les conseils, sans accepter la primauté d'un ministre.")
^"Britain's unwritten constitution". British Library. Archived fromthe original on 8 December 2015. Retrieved27 November 2015.The key landmark is the Bill of Rights (1689), which established the supremacy of Parliament over the Crown.... The Bill of Rights (1689) then settled the primacy of Parliament over the monarch's prerogatives, providing for the regular meeting of Parliament, free elections to the Commons, free speech in parliamentary debates, and some basic human rights, most famously freedom from 'cruel or unusual punishment'.
^Dr Andrew Blick and Professor George Jones — No 10 guest historian series, Prime Ministers and No. 10 (1 January 2012)."The Institution of Prime Minister". Government of the United Kingdom: History of Government Blog.Archived from the original on 10 March 2016. Retrieved15 April 2016.{{cite web}}: CS1 maint: numeric names: authors list (link)
^Carter, Byrum E. (2015) [1955]. "The Historical Development of the Office of Prime Minister".Office of the Prime Minister. Princeton University Press.ISBN9781400878260.Archived from the original on 1 June 2016. Retrieved15 April 2016.
^Constitution Act, 1867 (U.K.), 30 & 31 Vict., c. 3. See also “Constitution Act, 1867,” in: Justice Canada, ed.,A Consolidation of The Constitution Acts, 1867 to 1982, Government of Canada Catalogue №YX1‑1/2012 (Ottawa: 2012),ISBN9780660674582, pp. 1–52.
^SeeConstitution Act, 1867 (U.K.), 30 & 31 Vict., c. 3, Part 2 (§ 11 in particular). See also “Constitution Act, 1867,” in: Justice Canada, ed.,A Consolidation of The Constitution Acts, 1867 to 1982, Government of Canada Catalogue №YX1‑1/2012 (Ottawa: 2012),ISBN9780660674582, pp. 3–4.
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