What Extent Is the British Prime Minister Different From German Chancellor?

COMPARATIVE POLITICS, 2nd take-home paper

“A good way to evaluate parliamentary systems is analyzing how easy (or difficult) is for any parliamentary majority to unseat the head of government when in office. In this respect, to what extent is the British Prime Minister different from the German Chancellor? Which is the strongest (i.e. most stable) type? And, according to you, why? ”

The Chancellor of Germany

The federal government of Germany consists of the Bundeskanzler (chancellor) and the Cabinet ministers that he or she directly elects. The Chancellor has the central executive authority and “plays such a central role in the political system that some observers describe the German system as a ‘Chancellor democracy’” (Almond, 265). Also, according to the 65th article of the Grundgesetz: “The Federal Chancellor shall determine and be responsible for the general guidelines of policy. Within these limits each Federal Minister shall conduct the affairs of his department independently and on his own responsibility. The Federal Government shall resolve differences of opinion between Federal Ministers. The Federal Chancellor shall conduct the proceedings of the Federal Government in accordance with rules of procedure adopted by the Government and approved by the Federal President.” Every four years, after national elections and the placing of the new elected Bundestag components, the Bundespräsident (literally, the “Federal President”) suggests a Chancellor candidate to that parliamentary group. The Chancellor is elected by the Bundestag, represents its majority, and can rely on its support for how it concern government’s legislative proposals.

The control of the Bundestag over the Chancellor and the Cabinet is limited: if the Parliament wants to remove the Chancellor, the Basic Law says it must propose a constructive vote of no confidence: “(1) The Bundestag may express its lack of confidence in the Federal Chancellor only by electing a successor by the vote of a majority of its Members and requesting the Federal President to dismiss the Federal Chancellor. The Federal President must comply with the request and appoint the person elected. (2) Forty-eight hours shall elapse between the motion and the election” (article 67, Basic Law for the Federal Republic of Germany, Grundgesetz, GG)

This rule divides the removing procedure in two steps, being the absolute majority of the Bundestag agreeing on:

removing the Chancellor

proposing a new successor

The simple vote of no-confidence, which is nowadays applied in some European parliaments, was overused during the Weimar Republic (1919-1933) by extremist parties in disfavour of the democratic process. This legislative procedure guarantees both a methodical transfer of power and a first support of the parliamentary majority towards the new Bundeskanzler.

From 1949 to present, the Bundestag tried to attempt a constructive no-confidence vote twice, succeeding only once. In 1972 head of the CDU/CSU coalition, Rainer Barzel tried to replace Chancellor Willy Brandt of the SPD but the motion fell two votes shy of the necessary majority. The 1st October 1982, the CDU convinced the FDP to propose another constructive vote of no-confidence over differences on economic and foreign policy and to form a new government with the CDU and the CSU. The actual Chancellor Helmut Schmidt was replaced with Helmut Kohl, the CDU party leader.

The Chancellor can also use a second type of no-confidence vote to gain legislative support in the Parliament, adding a simple no-confidence condition to any government legislative proposal. If the Parliament refuses the proposal, the chancellor can ask the federal president to dissolve the parliament and request new elections. Even though is not common, this procedure lets the Bundeskanzler to test the support in the Bundestag for the government and to stress the Bundestag to vote in accord of legislation that the government judge significant. Also, governments believe that this simple no-confidence proposal could be useful for setting off early Bundestag elections. For example, after Kohl became chancellor in 1982, his government intentionally planned to lose a simple no-confidence condition with the intention of let new elections happen and give the electorate a possibility to approve the new government through a democratic election.

The British Prime Minister

The power of the British Prime Minister can be institutional, political, and personal, which means depending on his or her personality. The institutional powers derive from his or her duties; so the prime minister:

Is the Head of Government

Is the Chairman of the cabinet

Chooses Cabinet ministers

Nominates other government’s members (ministers that don’t belong to the Cabinet)

Can reshuffle ministers

Has the power of dismissal for both Cabinet and government ministers

Is the one responsible for his nation in its domestic and international affairs

Has patronage to elect people in several public, judicial, and ecclesiastic offices

Is the head of the Civil Service

Can dismiss the parliament and call for political elections.

For how it concern political powers, a Prime Minister is chosen by his or her party and so he or she is also the leader of the majority party within the Parliament. This means that no one can become Prime Minister without a given party support and without a relatively long parliamentary career. Therefore, the strength of the Prime Minister depends on how high it is his control over his party. The strongest he is as the party leader, the more authoritative he is being the Prime minister and vice versa.

According to Almond, “a Prime Minister is chosen by his or her party for an indefinite term and is thus vulnerable to losing office if its confidence wanes” (168). The British prime minister can be forced to resign because of health or political reasons, and just in the second after war this happened seven times: in 1955 Winston Churchill resigned for Anthony Eden; in 1957 Anthony Eden resigned for Macmillan; in 1963 Alec Douglas-Home replaced Macmillan; in 1976 Callaghan replaced Wilson; in 1990 Major took the place of Margaret Thatcher; in 2007 Tony Blair resigned for Gordon Brown whose place was took in 2010 by David Cameron.

Therefore, the Prime Minister isn’t a priori guaranteed to be stable while in charge. His stability depends on his capacity to maintain control over the parliamentary majority and over the Cabinet, but it’s just a political capability, not a position acquired by his office or by an electoral legitimacy (like for example in Italy). In fact, the Prime Minister is not chosen by the electorate but by his or her party. Conservative and Labor party have different rules to revoke “their” Prime Minister: the conservative party needs the 15% of signatures of the parliamentary group to propose a no-confident vote while the labor needs the 20% plus other rigid protections.

As we said before, the Prime Minister has the power to reshuffle ministers within the Cabinet, but this means more a new distribution of ministerial tasks rather than the imposition of resignation. To force a senior minister to resign is not an easy operation and also relatively exceptional, because of the political risks that would let the Prime Minister become weaken and unstable. The most common occasion is one minister himself resigning for different reasons. In the case of political disagreement, the resigning of an important minister could be fatal for a Prime Minister leadership. This is the case of Margaret Thatcher governments, where form 1986 to 1990 six ministers resigned due to profound political disagreements. This list of dismissal was the prelude of a parliamentary party revolt against its premier that leaded to her defeat during the leadership competition and to her inevitable dismissal from Prime Minister (December 1990). As in Germany, a constructive no-confidence vote exists also in the United Kingdom, but it has to be applied only by the parliamentary group and by the majority party. However, the British Parliament never applied the no-confidence vote: the government has changed before the elections just because of internal party reasons, as for example with Thatcher and Blair.

Summin’ Up

To determine which is the most stable type between the British Prime Minister and the German Chancellor is not very easy, although the last one seems to me to be the strongest leader. The German system has a written constitution and the rules to unseat the head of government are very clear, while the British system doesn’t possess any written constitution, so it’s a matter of circumstances and conventions that determines the removal of the Prime minister. The Germanic constructive no-confidence vote, with its two-steps procedure lets the Chancellor being very safe and strong until the majority of the bundestag agrees on his successor. The British system has the strongest concentration of democratic power in one person, but in reality, prime ministers do not exercise power in the same way: some of them may be decisive and innovators while others may prefer a more conciliating approach. Still, the examples of the most powerful and long-lasting leaderships often end with the dismissal of the Prime Minister: in 1989 Margaret Thatcher slowly lost her party support because of an unpopular financial reform and because of her skepticism towards the rest of Europe that leaded to the dismissal of her Vice Prime Minister Geoffrey Howe. In 1990, after 11 years of a unique political experience, she decided to resign. Last but not least, this complicated comparison can be helped by data: from 1950 to present, the United Kingdom changed fourteen different Prime Ministers, while Germany changed only eight Chancellors, which suggests everyone interested in undertaking a political career that it’s better to move to Berlin.