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Westminster system

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The Westminster system, or Westminster model, is a type of parliamentary government that incorporates a series of procedures for operating a legislature, first developed in England. Key aspects of the system include an executive branch made up of members of the legislature, and that is responsible to the legislature; the presence of parliamentary opposition parties; and a ceremonial head of state who is separate from the head of government. The term derives from the Palace of Westminster, which has been the seat of the Westminster Parliament in England and later the United Kingdom since the 13th century. The Westminster system is often contrasted with the presidential system that originated in the United States,[1] or with the semi-presidential system, based on the government of France.

The Houses of Parliament in Westminster
The Palace of Westminster, after which the Westminster system is named. It is the home of the UK Parliament.

The Westminster system is used, or was once used, in the national and subnational legislatures of most former colonies of the British Empire, upon gaining self-government (with the exception of the United States and Cyprus),[2][3] beginning with the first of the Canadian provinces in 1848 and the six Australian colonies between 1855 and 1890.[4][5][6] It is the form of government bequeathed to New Zealand,[4] and former British Hong Kong.[7][8] Israel adopted a largely Westminster-inspired system of government upon declaring independence from the British Mandate of Palestine. However, some former colonies have since adopted either the presidential system (Nigeria for example) or a hybrid system (like South Africa) as their form of government.

Characteristics

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The Westminster system of government may include some of the following features:[9]

Most of the procedures of the Westminster system originated with the conventions, practices, and precedents of the Parliament of the United Kingdom, which form a part of what is known as the Constitution of the United Kingdom. Unlike the uncodified British constitution, most countries that use the Westminster system have codified the system, at least in part, in a written constitution.

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 the Australian constitutional crisis of 1975, the Governor-General of Australia, Sir John Kerr, dismissed Prime Minister Gough Whitlam and replaced him with opposition leader Malcolm Fraser.

Summary of the typical structure of the Westminster model

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Type Bicameral (unicameral in some circumstances) Elected or appointed upper house to approve and/or scrutinise laws.
  • Senate, Legislative Council, House of Lords
Elected lower house to represent the people and (normally) initiate legislation.
  • House of Commons, House of Representatives, Legislative Assembly
Leadership Head of state Monarch (sometimes represented by a vice-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).

  • Prime minister in a sovereign state/country
  • Premier/chief minister in provinces, states, or territories.
  • Other titles include first minister, chief executive, president of the council of ministers.
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.

  • Executive ministers are chosen (normally) from members of the government party or coalition, by the head of government. They may be from either house in bicameral systems.
  • A Cabinet is formed from the most senior ministers, but may include some civil servants.
  • In parliaments without political parties, ministers are either chosen by the prime minister or elected by members at large.
  • Government sits in and is responsible to the legislature, to which it reports and is accountable (in particular, to the lower house, if bicameral).
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.

Operation

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The pattern of executive functions within a Westminster system is quite complex. In essence, the head of state, usually a monarch or president, is a ceremonial figurehead who is the theoretical, nominal or de 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.

The head of government, usually called the prime minister or premier, will ideally have the support of a majority in the responsible house, and must, in any case, be able to ensure the existence of no absolute majority against the government. If the parliament passes a motion of no confidence, or refuses to pass an important bill such as the budget, then the government must either resign so that a different government can be appointed or seek a parliamentary 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 junior ministers, however, in effect, the head of government dominates the executive as the head of government is ultimately the person from whom the head of state will take advice (by constitutional convention) on the exercise of executive 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 a cabinet reshuffle for "underperforming".

In the United Kingdom, the sovereign theoretically holds executive authority, even though the prime minister and the cabinet effectively implement executive powers. In a parliamentary republic like India, the president is the de jure executive, even though executive powers are essentially instituted by the prime minister and the Council of Ministers. In Israel, however, executive power is vested de jure and de facto in the cabinet and the president is de jure and de facto a ceremonial figurehead.

As an example, the prime minister and cabinet (as the de facto executive body in the system) generally must seek the permission of the head of state when carrying out executive functions. If, for instance the British prime minister wished to dissolve Parliament in order for a general election to take place, the prime minister is constitutionally bound to request permission from the sovereign 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 a constitutional monarch; he or she abides by the advice of his or her ministers, except when executing reserve powers in times of crisis. The sovereign's power to appoint and dismiss governments, appoint cabinet ministers to serve in the government, appoint diplomats, declare war, and to sign treaties (among other powers de jure held by the sovereign) is known as the royal prerogative, which in modern times is exercised by the sovereign solely on the advice of the Prime Minister.

This custom also occurs in other countries are regions around the world using the Westminster System, as a legacy of British colonial rule. In Commonwealth 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 the governor-general. In such nations, the prime minister is obligated to formally seek permission from the governor-general when implementing executive decisions, in a manner similar to the British system.

An analogous scenario also exists in republics in the Commonwealth of Nations, such as India or Trinidad and Tobago, where there is a president who functions similarly to a governor-general.

An unusual case lies in Israel and Japan, where the respective prime ministers have the full legal power to implement executive decisions, and presidential (in Israel) or imperial (in Japan) approval is not required; the prime ministers of these nations are fully the de 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. The reserve 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, the British 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 of Hanover 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 the Prime Minister's hands. Such a concept was reinforced in The English Constitution (1876) by Walter Bagehot, who distinguished between the separate "dignified" and "efficient" functions of government. The sovereign should be a focal point for the nation ("dignified"), while the PM and cabinet actually undertook executive decisions ("efficient").[13]

Electoral system, ministers and officials

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The electoral system is often set out in a Representation of the People Act.[14][15] Common ministerial titles include parliamentary secretary and under-secretary. Ministers are supported by private secretaries and government departments are run by permanent secretaries, principal secretaries or chief secretaries.

Role of the head of state

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The head of state or their representative (such as a governor-general) formally appoints as the head of government whoever commands the confidence of the lower or sole house of the legislature and invites him or her to form a government. In the UK, this is known as kissing 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 significant reserve powers. Examples of the use of such powers include the Australian constitutional crisis of 1975 and the Canadian King–Byng affair in 1926. The Lascelles 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 many Commonwealth 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.[16]

Cabinet government

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Main article: Cabinet collective responsibility

In the book The 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".[13]

Members of the Cabinet are collectively seen as responsible for government policy, a policy termed cabinet 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 a Cabinet 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.

The Official Opposition and other major political parties not in the Government, will mirror the governmental organisation with their own Shadow Cabinet made up of Shadow Ministers.

Bicameral and unicameral parliaments

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Canadian Parliament at night
 
The Sansad Bhavan (Parliament House) building in New Delhi, India
 
Knesset Building, Jerusalem

In a Westminster system, some members of parliament are elected by popular vote, while others are appointed. Nearly all Westminster-based parliaments have a lower house with powers based on those of the House of Commons (under various names), comprising local, elected representatives of the people (with the 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:

  • A prime minister can be elected without gaining a majority of the popular vote.

In the UK, the lower house is the de 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 are unicameral for two reasons:

Hong Kong, a former British crown colony and currently a special administrative region of the People's Republic of China, has a unicameral Legislative 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 part of the seats are returned by universal suffrage. Responsible government was never granted during British colonial rule, and the Governor remained the head of government until the transfer of sovereignty in 1997, when the role was replaced by the Chief 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. Minutes are known as Hansards, and the theme colour of the meeting chamber is red as in other upper houses. Government secretaries and other officials are seated on the right hand side of the President in the chamber. 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.

"Washminster system"

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The Australian Senate

The waters of the Thames and of the Potomac both flow into Lake Burley Griffin.

— James Killen, Farewell Parliament House - Sunday May 8, 1988

Australian constitutional law is, in many respects, a unique hybrid with influences from the United 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, the Senate, 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.[18][19][20][21][22][23]

The Australian Senate is unusual in that it maintains an ability to withhold supply from the government of the day – a power similar to that held in the UK until 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 the governor-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 the 1975 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 the Australian system of government was consciously devised as a blend or hybrid of the Westminster and the United 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".[24] The ability of upper houses to block supply also features in the parliaments of most Australian states.

The Australian system has also been referred to as a semi-parliamentary system.[25]

Ceremonies

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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 a church choir. 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 the table of the House. In most majority 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 the Speaker of the House. The speaker usually wears black robes, and in some countries, a wig. Robed parliamentary clerks 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.

Other ceremonies sometimes associated with the Westminster system include an annual Speech 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 lengthy State Opening of Parliament ceremonies that often involve the presentation of a large ceremonial 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.

Current countries

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Countries that use variations on the theme of the Westminster system, as of 2023, include the following:

Country Legislature System of govt. 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 using instant-runoff voting. Upper house is elected by single transferable vote (a form of proportional representation) with each state and territory treated as individual electorates. Queensland has a unicameral state parliament while all other states have bicameral parliaments. The Australian Capital Territory and the Northern 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 require official party status for some parliamentary privileges.
Two of its territorial parliaments operate without 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. Proportional representation is used to elect the Folketing.

One of five countries other than the UK to use a Westminster system with a 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. The Lok Sabha (lower house) is popularly elected via first past the post. The Rajya Sabha (upper house) is mostly elected by the members of state/union territory legislatures using single transferable vote with a handful of members being appointed by the President 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 of Taoiseach (in the Irish 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. Notably, the Italian Parliament employs perfect bicameralism, with the Senate of the Republic and Chamber 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 through parallel voting. Five people appointed by the President of Italy, as well as previous Presidents of Italy, serve as senators for life.
  Israel Knesset Republic Modified Westminster system: Powers which would have been exercised by the President of Israel are divided between the Prime Minister, the Cabinet, and the speaker of the legislature.
The Prime Minister was directly elected from 1996 to 2001.[26] Closed list party-list proportional representation is used to elect members to the Knesset.
  Japan National Diet:
House of Councillors
House of Representatives 		Monarchy Modified Westminster system: many non-reserve powers which would have been exercised by the Emperor of Japan on the advice of the Cabinet in an unmodified system are exercised directly by the Prime Minister, and Imperial reserve powers do not exist. Both houses of the National Diet are elected using parallel voting.

One of five countries other than the UK to use a Westminster system with a 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 with a 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[27] 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 Uses mixed-member proportional representation to elect members to its unicameral Parliament. Several seats in NZ Parliament are reserved for election by Indigenous Māori 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 of Governor-General not by the Prime 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 by first-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 of Governor-General not by the Prime 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 One of five countries other than the UK to use a Westminster system with a 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

Former countries

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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 instance South Africa and Botswana, 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.

See also

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References

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  1. ^ "Varieties of public representation". Political Representation. Cambridge University Press. 2010. ISBN 978-0521128650.
  2. ^ Julian Go (2007). "A Globalizing Constitutionalism?, Views from the Postcolony, 1945–2000". In Arjomand, Saïd Amir (ed.). Constitutionalism and political reconstruction. Brill. pp. 92–94. ISBN 978-9004151741.
  3. ^ "How the Westminster Parliamentary System was exported around the World". University of Cambridge. 2 December 2013. Retrieved 16 December 2013.
  4. ^ a b Seidle, F. Leslie; Docherty, David C. (2003). Reforming parliamentary democracy. McGill-Queen's University Press. p. 3. ISBN 9780773525085.
  5. ^ Johnston, Douglas M.; Reisman, W. Michael (2008). The Historical Foundations of World Order. Leiden: Martinus Nijhoff Publishers. p. 571. ISBN 978-9047423935.
  6. ^ Fieldhouse, David; Madden, Frederick (1990). Settler self-government, 1840–1900 : the development of representative and (1. publ. ed.). New York: Greenwood Press. p. xxi. ISBN 9780313273261.
  7. ^ Cooray, Anton (2019). "5: Customary Law, Unwritten Law, and General Principles of Law". Constitutional Law in Hong Kong. Kluwer Law International B.V. ISBN 9789403518213.
  8. ^ Yu, Gu (2015). "8: Conclusion". Hong Kong's Legislature under China's Sovereignty: 1998–2013. Hotei Publishing. p. 215. ISBN 9789004276284.
  9. ^ "The Westminster System – Public Service Commission". www.psc.nsw.gov.au. Retrieved 22 August 2017.
  10. ^ a b "OBA.org – Articles". www.oba.org.
  11. ^ "Reinvigorating The Westminster Tradition". Archived from the original on 27 March 2013. Retrieved 28 February 2013.
  12. ^ "The Role of the Opposition". academic.oup.com. Retrieved 18 October 2023.
  13. ^ a b Bagehot, Walter (1876). The English Constitution (1st ed.). London: Chapman & Hall.
  14. ^ Alder and Syrett. Constitutional and Administrative Law. (Palgrave Law Masters). 11th Edition. 2017. p 294. Birch. The British System of Government. 10th Edition. Routledge. 1998. Taylor & Francis e-Library. 2006. p 17.
  15. ^ See, for example, the definition in section 8(1) of the Representation of the People Act 1884, read with the definition of the Registration Acts in section 8(2)
  16. ^ Ireland, Ian (28 August 1995). "Who is the Australian Head of State?" (PDF). Research Note (1). Canberra: Dept. of the Parliamentary Library: 1. ISSN 1323-5664. Archived from the original (PDF) on 17 January 2011. Retrieved 22 January 2011.
  17. ^ "Chapter 2: The development of the Westminster system". Parliament of Australia. Retrieved 22 August 2017.
  18. ^ Aroney, Nicholas (2009). The constitution of a federal commonwealth : the making and meaning of the Australian constitution. Cambridge, UK: Cambridge University Press. ISBN 978-1-139-12968-8. OCLC 774393122.
  19. ^ Williams, George; Brennan, Sean; Lynch, Andrew (2014). Blackshield and Williams Australian Constitutional Law and Theory (6 ed.). Leichhardt, NSW: Federation Press. pp. 77–88. ISBN 978-1-86287-918-8.
  20. ^ Aroney, Nicholas; Kincaid, John. "Analysis | Comparing Australian and American federal jurisprudence". Washington Post. ISSN 0190-8286. Retrieved 4 November 2020.
  21. ^ James A. Thomson, American and Australian Constitutions: Continuing Adventures in Comparative Constitutional Law, 30 J. Marshall L. Rev. 627 (1997)
  22. ^ Zelman Cowan, A Comparison of the Constitutions of Australia and the United States, 4 Buff. L. Rev. 155 (1955).
  23. ^ Evans, Harry (December 2009). "The Other Metropolis: The Australian Founders' Knowledge of America". Papers on Parliament No. 52. Retrieved 4 November 2020.
  24. ^ Thompson, Elaine (1980). "The 'Washminster' mutation". Politics. 15 (2): 32–40. doi:10.1080/00323268008401755.
  25. ^ Ganghof, S (May 2018). "A new political system model: Semi-parliamentary government". European Journal of Political Research. 57 (2): 261–281. doi:10.1111/1475-6765.12224.
  26. ^ Arian, Asher; Shamir, Michal (November 2008). "A Decade Later, the World Had Changed, the Cleavage Structure Remained". Party Politics. 14 (6): 685–705. doi:10.1177/1354068808093406. S2CID 144231226.
  27. ^ "CONSTITUTION OF NEPAL 2015" (PDF). Archived from the original (PDF) on 23 December 2015. Retrieved 18 February 2016.
  28. ^ Hein, Patrick (2009). How the Japanese became foreign to themselves : the impact of globalization on the private and public spheres in Japan. Berlin: Lit. p. 72. ISBN 978-3643100856.
  29. ^ Moore, Ray A.; Robinson, Donald L. (2004). Partners for democracy : crafting the new Japanese state under MacArthur. Oxford University Press. p. 85. ISBN 978-0195171761.{{cite book}}: CS1 maint: multiple names: authors list (link)
  30. ^ Hook, Glenn D., ed. (2005). Contested governance in Japan : sites and issues. London: RoutledgeCurzon. p. 55. ISBN 978-0415364980.
  31. ^ "Special Issue Constitutional Law in Japan and the United Kingdom". King's Law Journal. 2 (2). 2015.

Bibliography

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