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Parliamentary system
Form of government From Wikipedia, the free encyclopedia
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A parliamentary system, or parliamentary democracy, is a form of government based on the fusion of powers. In this system the head of government (chief executive) derives their democratic legitimacy from their ability to command the support ("confidence") of a majority of the parliament, to which they are held accountable. This head of government is usually, but not always, distinct from a ceremonial head of state. This is in contrast to a presidential system, which features a president who is not fully accountable to the legislature, and cannot be replaced by a simple majority vote.
Parliamentary systems: Head of government is elected or nominated by and accountable to the legislature.
Presidential system: Head of government (president) is popularly elected and independent of the legislature.
Presidential republic
Hybrid systems:
Semi-presidential republic: Executive president is independent of the legislature; head of government is appointed by the president and is accountable to the legislature.
Assembly-independent republic: Head of government (president or directory) is elected by the legislature, but is not accountable to it.
Other systems:
Theocratic republic: Supreme Leader is both head of state and faith and holds significant executive and legislative power
Military junta: Committee of military leaders controls the government; constitutional provisions are suspended.
Governments with no constitutional basis: No constitutionally defined basis to current regime, i.e., provisional governments or Islamic theocracies.
Dependent territories or places without governments
Note: this chart represents the de jure systems of government, not the de facto degree of democracy.
Countries with parliamentary systems may be constitutional monarchies, where a monarch is the head of state while the head of government is almost always a member of parliament, or parliamentary republics, where a mostly ceremonial president is the head of state while the head of government is from the legislature. In a few countries, the head of government is also head of state but is elected by the legislature. In bicameral parliaments, the head of government is generally, though not always, a member of the lower house.
Parliamentary democracy is the predominant form of government in the European Union, Oceania, and throughout the former British Empire, with other users scattered throughout Africa and Asia. A similar system, called a council–manager government, is used by many local governments in the United States.
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History
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The first parliaments date back to Europe in the Middle Ages. The earliest example of a parliament is disputed, especially depending how the term is defined.
For example, the Icelandic Althing consisting of prominent individuals among the free landowners of the various districts of the Icelandic Commonwealth first gathered around the year 930 (it conducted its business orally, with no written record allowing an exact date).
The first written record of a parliament, in particular in the sense of an assembly separate from the population called in presence of a king was in 1188, when Alfonso IX, King of Leon (Spain) convened the three states in the Cortes of León.[1][2] The Corts of Catalonia were the first parliament of Europe that officially obtained the power to pass legislation, apart from the custom.[3] An early example of parliamentary government also occurred in today's Netherlands and Belgium during the Dutch revolt (1581), when the sovereign, legislative and executive powers were taken over by the States General of the Netherlands from the monarch, King Philip II of Spain.[citation needed] Significant developments Kingdom of Great Britain, in particular in the period 1707 to 1800 and its contemporary, the Parliamentary System in Sweden between 1721 and 1772, and later in Europe and elsewhere in the 19th and 20th centuries, with the expansion of like institutions, and beyond
In England, Simon de Montfort is remembered as one of the figures relevant later for convening two famous parliaments.[4][5][6] The first, in 1258, stripped the king of unlimited authority and the second, in 1265, included ordinary citizens from the towns.[7] Later, in the 17th century, the Parliament of England pioneered some of the ideas and systems of liberal democracy culminating in the Glorious Revolution and passage of the Bill of Rights 1689.[8][9]
In the Kingdom of Great Britain, the monarch, in theory, chaired the cabinet and chose ministers. In practice, King George I's inability to speak English led to the responsibility for chairing cabinet to go to the leading minister, literally the prime or first minister, Robert Walpole. The gradual democratisation of Parliament with the broadening of the voting franchise increased Parliament's role in controlling government, and in deciding whom the king could ask to form a government. By the 19th century, the Great Reform Act 1832 led to parliamentary dominance, with its choice invariably deciding who was prime minister and the complexion of the government.[10][11]
Other countries gradually adopted what came to be called the Westminster system of government,[12] with an executive answerable to the lower house of a bicameral parliament, and exercising, in the name of the head of state, powers nominally vested in the head of state – hence the use of phrases such as Her Majesty's government (in constitutional monarchies) or His Excellency's government (in parliamentary republics).[13] Such a system became particularly prevalent in older British dominions, many of which had their constitutions enacted by the British parliament; such as Australia, New Zealand, Canada, the Irish Free State and the Union of South Africa.[14][15][16] Some of these parliaments were reformed from, or were initially developed as distinct from their original British model: the Australian Senate, for instance, has since its inception more closely reflected the US Senate than the British House of Lords; whereas since 1950 there is no upper house in New Zealand. Many of these countries such as Trinidad and Tobago and Barbados have severed institutional ties to Great Britain by becoming republics with their own ceremonial presidents, but retain the Westminster system of government. The idea of parliamentary accountability and responsible government spread with these systems.[17]
Democracy and parliamentarianism became increasingly prevalent in Europe in the years after World War I, partially imposed by the democratic victors,[how?] the United States, Great Britain and France, on the defeated countries and their successors, notably Germany's Weimar Republic and the First Austrian Republic. Nineteenth-century urbanisation, the Industrial Revolution and modernism had already made the parliamentarist demands of the Radicals and the emerging movement of social democrats increasingly impossible to ignore; these forces came to dominate many states that transitioned to parliamentarism, particularly in the French Third Republic where the Radical Party and its centre-left allies dominated the government for several decades. However, the rise of Fascism in the 1930s put an end to parliamentary democracy in Italy and Germany, among others.
After the Second World War, the defeated fascist Axis powers were occupied by the victorious Allies. In those countries occupied by the Allied democracies (the United States, United Kingdom, and France) parliamentary constitutions were implemented, resulting in the parliamentary constitutions of Italy and West Germany (now all of Germany) and the 1947 Constitution of Japan. The experiences of the war in the occupied nations where the legitimate democratic governments were allowed to return strengthened the public commitment to parliamentary principles; in Denmark, a new constitution was written in 1953, while a long and acrimonious debate in Norway resulted in no changes being made to that country's strongly entrenched democratic constitution.
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Characteristics
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A parliamentary system may be either bicameral, with two chambers of parliament (or houses) or unicameral, with just one parliamentary chamber. A bicameral parliament usually consists of a directly elected lower house with the power to determine the executive government, and an upper house which may be appointed or elected through a different mechanism from the lower house.
A 2019 peer-reviewed meta-analysis based on 1,037 regressions in 46 studies finds that presidential systems generally seem to favor revenue cuts, while parliamentary systems would rely more on fiscal expansion characterized by a higher level of spending before an election.[18]
Types
Scholars of democracy such as Arend Lijphart distinguish two types of parliamentary democracies: the Westminster and Consensus systems.[19]
Westminster system
- The Westminster system is usually found in the Commonwealth of Nations and countries which were influenced by the British political tradition.[20][21][22] These parliaments tend to have a more adversarial style of debate and the plenary session of parliament is more important than committees. Some parliaments in this model are elected using a plurality voting system (first past the post), such as the United Kingdom, Canada, India and Malaysia, while others use some form of proportional representation, such as Ireland and New Zealand. The Australian House of Representatives is elected using instant-runoff voting, while the Senate is elected using proportional representation through single transferable vote. Regardless of which system is used, the voting systems tend to allow the voter to vote for a named candidate rather than a closed list. Most Westminster systems employ strict monism, where ministers must be members of parliament simultaneously; while some Westminster systems, such as Bangladesh,[23] permit the appointment of extra-parliamentary ministers, and others (such as Jamaica) allow outsiders to be appointed to the ministry through an appointed upper house, although a majority of ministers (which, by necessity, includes the prime minister) must come from within (the lower house of) the parliament.
Consensus system
- The Western European parliamentary model (e.g., Spain, Germany) tends to have a more consensual debating system and usually has semi-circular debating chambers. Consensus systems have more of a tendency to use proportional representation with open party lists than the Westminster Model legislatures. The committees of these parliaments tend to be more important than the plenary chamber. Most Western European countries do not employ strict monism, and allow extra-parliamentary ministers as a matter of course. The Netherlands, Slovakia and Sweden outright implement the principle of dualism as a form of separation of powers, where Members of Parliament have to resign their place in Parliament upon being appointed (or elected) minister.
Appointment of the head of government
Implementations of the parliamentary system can also differ as to how the prime minister and government are appointed and whether the government needs the explicit approval of the parliament, rather than just the absence of its disapproval. While most parliamentary systems such as India require the prime minister and other ministers to be a member of the legislature, in other countries like Canada and the United Kingdom this only exists as a convention, some other countries including Norway, Sweden and the Benelux countries require a sitting member of the legislature to resign such positions upon being appointed to the executive.
- The head of state appoints a prime minister who will likely have majority support in parliament. While in the majority of cases prime ministers in the Westminster system are the leaders of the largest party in parliament, technically the appointment of the prime minister is a prerogative exercised by the head of state (be it the monarch, the governor-general, or the president). This system is used in:
- The head of state appoints a prime minister who must gain a vote of confidence within a set time. This system is used in:
- The head of state appoints the leader of the political party holding a plurality of seats in parliament as prime minister. For example, in Greece, if no party has a majority, the leader of the party with a plurality of seats is given an exploratory mandate to receive the confidence of the parliament within three days. If said leader fails to obtain the confidence of parliament, then the leader of the second-largest party is given the exploratory mandate. If that fails, then the leader of the third-largest political party is given the exploratory mandate, and so on. This system is used in:
- The head of state nominates a candidate for prime minister who is then submitted to parliament for approval before appointment. Example: Spain, where the King sends a proposal to the Congress of Deputies for approval. Also, Germany where under the German Basic Law (constitution) the Bundestag votes on a candidate nominated by the federal president. In these cases, parliament can choose another candidate who then would be appointed by the head of state. This system is used in:
- Parliament nominates a candidate whom the head of state is constitutionally obliged to appoint as prime minister. Example: Japan, where the Emperor appoints the Prime Minister on the nomination of the National Diet. Also Ireland, where the President of Ireland appoints the Taoiseach on the nomination of Dáil Éireann. This system is used in:
- A public officeholder (other than the head of state or their representative) nominates a candidate, who, if approved by parliament, is appointed as prime minister. Example: Under the Swedish Instrument of Government (1974), the power to appoint someone to form a government has been moved from the monarch to the Speaker of 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 against the candidate (i.e. they can be elected even if more members of parliament vote No than Yes). This system is used in:
- 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, and whose procedure can also be described as of a semi-parliamentary system.[26][27] This system was used in:
Israel (1996–2001)
Power of dissolution and call for election
Furthermore, there are variations as to what conditions exist (if any) for the government to have the right to dissolve the parliament:
- In some countries, especially those operating under a Westminster system, such as the United Kingdom, Denmark, Malaysia, Australia and New Zealand, the prime minister has the de facto power to call an election, at will. In Spain, the prime minister is the only person with the de jure power to call an election, granted by Article 115 of the Constitution.
- In Israel, parliament may vote to dissolve itself in order to call an election, or the prime minister may call a snap election with presidential consent if his government is deadlocked. A non-passage of the budget automatically calls a snap election.
- Other countries only permit an election to be called in the event of a vote of no confidence against the government, a supermajority vote in favour of an early election or a prolonged deadlock in parliament. These requirements can still be circumvented. For example, in Germany in 2005, Gerhard Schröder deliberately allowed his government to lose a confidence motion, in order to call an early election.
- In Sweden, the government may call a snap election at will, but the newly elected Riksdag is only elected to fill out the previous Riksdag's term. The last time this option was used was in 1958.
- In Greece, a general election is called if the Parliament fails to elect a new head of state when his or her term ends. In January 2015, this constitutional provision was exploited by Syriza to trigger a snap election, win it and oust rivals New Democracy from power.
- In Italy the government has no power to call a snap election. A snap election can only be called by the head of state, following a consultation with the presidents of both houses of parliament.
- Norway is unique among parliamentary systems in that the Storting always serves the whole of its four-year term.
- In Australia, under certain, unique conditions, the prime minister can request the Governor General to call for a double dissolution, whereby all rather than only half of the Senate, is dissolved – in effect electing all of the Parliament simultaneously.
The parliamentary system can be contrasted with a presidential system which operates under a stricter separation of powers, whereby the executive does not form part of—nor is appointed by—the parliamentary or legislative body. In such a system, parliaments or congresses do not select or dismiss heads of government, and governments cannot request an early dissolution as may be the case for parliaments (although the parliament may still be able to dissolve itself, as in the case of Cyprus). There also exists the semi-presidential system that draws on both presidential systems and parliamentary systems by combining a powerful president with an executive responsible to parliament: for example, the French Fifth Republic.
Parliamentarianism may also apply to regional and local governments. An example is Oslo which has an executive council (Byråd) as a part of the parliamentary system. The devolved nations of the United Kingdom are also parliamentary and which, as with the UK Parliament, may hold early elections – this has only occurred with regards to the Northern Ireland Assembly in 2017 and 2022.
Anti-defection law
A few parliamentary democratic nations such as India, Pakistan and Bangladesh have enacted laws that prohibit floor crossing or switching parties after the election. Under these laws, elected representatives will lose their seat in the parliament if they go against their party in votes.[28][29][30]
In the UK parliament, a member is free to cross over to a different party. In Canada and Australia, there are no restraints on legislators switching sides.[31] In New Zealand, waka-jumping legislation provides that MPs who switch parties or are expelled from their party may be expelled from Parliament at the request of their former party's leader.
Parliamentary sovereignty
A few parliamentary democracies such as the United Kingdom and New Zealand have weak or non-existent checks on the legislative power of their Parliaments,[32][33] where any newly approved Act shall take precedence over all prior Acts. All laws are equally unentrenched, wherein judicial review may not outright annul nor amend them, as frequently occurs in other parliamentary systems like Germany. Whilst the head of state for both nations (Monarch, and or Governor General) has the de jure power to withhold assent to any bill passed by their Parliament, this check has not been exercised in Britain since the 1708 Scottish Militia Bill.
Whilst both the UK and New Zealand have some Acts or parliamentary rules establishing supermajorities or additional legislative procedures for certain legislation, such as previously with the Fixed-term Parliaments Act 2011 (FTPA), these can be bypassed through the enactment of another that amends or ignores these supermajorities away, such as with the Early Parliamentary General Election Act 2019 – bypassing the 2/3rd supermajority required for an early dissolution under the FTPA[34] -, which enabled the early dissolution for the 2019 general election.
Metrics
Parliamentarism metrics allow a quantitative comparison of the strength of parliamentary systems for individual countries. One parliamentarism metric is the Parliamentary Powers Index.[35]
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Advantages
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Electoral Systems and Political Representation
Before addressing the main points, it is important to begin by explaining the voting system. One of the first advantages of the British parliamentary system (which is the historic model of parliamentary systems) but directly illustrating the Westminster model is that the Prime Minister is the leader of the party that won the general election. As a result, the electoral majority produced at the polls becomes a parliamentary majority, which in turn provides political support for the government. This creates an organic fusion between Parliament and the executive, giving the Prime Minister strong democratic legitimacy and enabling greater efficiency in the implementation of policies. More broadly speaking, electoral systems in parliamentary regimes are proportional representation, mixed systems or majoritarian systems (like in the U.K). It offers a stronger political representation because governments emerge from parliament, citizens often feel their vote has a direct influence on who governs. PR systems in particular allow smaller parties and diverse viewpoints to be represented, promoting pluralism and inclusiveness. This system also encourages the formation of coalitions government which therefor fosters compromise, cooperations and leads to more consensus-based policies according to Giovanni Sartori [36] in Parties and Party Systems (1976). Since the executive comes from the legislature, policy coordination tends to be more efficient, with fewer institutional blockages. According to Hanna Pitkin in The Concept of Representation (1967) [37] , proportional electoral systems enhance the substantive dimension of representation by including a wider range of voices in parliament. Parliamentary systems, by linking the executive to parliament, strengthen responsibility and visibility of government action according to Bernard Manin [38] in The Principles of Representative Government (1995)
Adaptability
Parliamentary systems like that found in the United Kingdom are widely considered to be more flexible, allowing a rapid change in legislation and policy as long as there is a stable majority or coalition in parliament, allowing the government to have 'few legal limits on what it can do'[39] When combined with first-past-the-post voting, this system produces the classic "Westminster model" with the twin virtues of strong but responsive party government.[40] This electoral system providing a strong majority in the House of Commons, paired with the fused power system results in a particularly powerful government able to provide change and 'innovate'.[39]
Although some may argue that the historic Westminster model has faced serious challenges in recent years, particularly during the Brexit crisis, and that it no longer represents a model of adaptability, one could just as well claim that this very turbulence reflects a healthy democracy at work. As highlighted by Gulcin Ozkan and Richard McManus, [41] the political deadlock that characterised the UK during the Brexit debates can be seen as a sign of democratic vitality, with the system of checks and balances functioning as intended. While one might criticise the lack of clear political leadership or bipartisan consensus, Parliament was fulfilling its holding the government to account. This process can certainly create instability, but that is the price to pay, the other side of the coin, for a functioning democracy. In short, this helps to nuance the view that the Westminster model is failing; rather, it shows that it continues to operate according to its core democratic principles.
Economic Stability
Another important point to mention, is the way parliamentary systems foster more inclusive institutions contributing to better economic performance and stability compared to the presidential systems. [42]
Indeed, in presidential systems, the concentration of power in a single executive participates to political volatility disrupting economic planning and implementation. One very strong indicator is the GPD growth rate. A study [43] carried out by the Australian Institute for International Affairs in August 2024 found out that countries with presidential system experience, on average, growth rates between 0.6 to 1.2 percentage points lower than those of parliamentary systems. In other words, for every dollar earned in a presidential country, $4.39 was earned in a parliamentary one. Additionally, inflation rates tends to be higher in presidential systems. Income inequality is also a greater issue in presidential systems where the concentration of power leads to policies favouring the elite. The study found that income inequality is between 16% and 20% percent worse in presidential countries. Further evidence comes from a study by Gulch Ozkan, [44] professor or economics at the University of York and Richard McManus, senior Lecturer in Economics at the Canterbury Christ Church University also highlights the role of parliamentary systems on economies. Using data from 119 countries between 1950 and 2015, they concluded that, on average, annual output growth is up to 1.2 percentage points higher, inflation is 6 percentage points lower, and income inequality up to 20% lower in countries governed by parliamentary systems. This represents a significant and meaningful difference in the economic outcomes of the two forms of government.
Scrutiny and accountability
The United Kingdom's fused power system is often noted to be advantageous with regard to accountability. The centralised government allows for more transparency as to where decisions originate from, this contrasts with the American system with Treasury Secretary C. Douglas Dillon saying "the president blames Congress, the Congress blames the president, and the public remains confused and disgusted with government in Washington".[45] Furthermore, ministers of the U.K. cabinet are subject to weekly Question Periods in which their actions/policies are scrutinised; no such regular check on the government exists in the U.S. system.
Another relevant example that highlights the strong advantages of a parliamentary system, [46] where parliament holds the government to account, is the example of 2016 reform in France aimed at strengthening parliamentary scrutiny of the executive. Even though France is not a Parliamentary regime but more a semi-presidential system, this example illustrates that many countries tend to adopt certain characteristics of parliamentary governance to get the advantages of it.
It is both a constitutional function and a political practice. According to Article 24 of the Constitution, “Parliament passes laws, monitors government action, and evaluates public policies.”
The French Parliament exercise non binding oversight through a range of mechanisms that don’t involve questioning the government’s political survival.
These include : written and oral question to ministers every week; parliamentary resolutions (article 34-1) through which the National Assembly or Senate can express an opinion; committees of inquiry and information mission (article 51-2) which investigate specific policy failures or scandals; Budgetary oversight, ensuring that public spending aligns with governmental priorities, Scrutiny of military operations abroad, introduced by the 2008 constitutional reform:
Distribution of power
A 2001 World Bank study found that parliamentary systems are associated with less corruption.[47]
A good illustration of all that has been detailed above is probably the report of the World Bank because it encompasses scrutiny and transparency
In the 2001 World Bank Report entitled Accountability and Corruption: Political Institutions Matter (2001) by Daniel Lederman, Norman Loayza & Rodrigo R. Soares This report is particularly important as it seeks to confirm or challenge the theoretical assumptions outlined above regarding the relationship between different types of government and their corresponding levels of corruption.
This paper is relevant in the sense that it does not just argue that the presence of a parliament is associated with a lower rate of corruption, but it also shows it is the whole structure of the government that matters. The key explanatory political-insitutional variables are : whether the country is a democracy, whether its system is parliamentary, measures of political stability, freedom of the press… The dependent variable is a corruption indicator. The indices used to quantify corruption are numerous. There is the International Country Risk Guide (ICRG) evaluates corruption within the political system primarily as a risk factor for foreign investors. The World Development Report (WDR) considers corruption an obstacle to business activity. The GALLUP index measures the frequency of corrupt practices among public officials. The Global Competitiveness Survey (GCS) provides two indicators: the first (GCS1) assesses the incidence of irregular payments linked to activities such as imports, exports, business licensing, police protection, or loan applications, while the second (GCS2) focuses on irregular payments to officials and the judiciary. These indices are highly correlated but the report focuses mostly on the ICRG index because it offers the longest temporal coverage and enable panel data analysis. The report founds that democracy and having a parliamentary systems are associated with lower corruption. This is due to the fact that parliamentary systems enhance accountability and reduces rent-seeking : in parliamentary systems, the government is accountable to the legislature, can more easily be removed, parliament oversees budgets and actions — thereby reducing opportunities for corruption.
This is an empirical evidence showing a statistical association between parliamentary systems and lower corruption levels
Still this analysis is correlational not definitive about causality. Parliamentarism might correlate with other institutional features like rule of law or civil service quality that drive lower corruption.
The distribution of legislative power and control is another critical aspect of Parliamentary systems. Indeed, when the power is concentrated in the hands of the President, it can lead to unchecked authority and abuses. The example of Recep Tayyip Erdogan is relevant. He used his presidential power to consolidate its control over the judiciary, media, and other key institutions. On the contrary, the presence of check and balances in parliamentary systems limits the power of a single actor and it diminishes corruption. This is what Linz and Stephan found in 1996 showing that in parliamentary systems, there is a stronger monitoring of the executive by the legislature which therefore increase accountability and reduce corruption.
Another key thing developed in this report is the relation between transparency and accountability and therefor corruption. The report based itself on the freedom of press and expression and the degree of centralization in the system. It showed that when there is a good freedom of press, the good as well as the bad actions of the government can be exposed in the press to the public and reduce informational problems (Fackler and Lin, 1995; Rose-Ackerman, 1999; and Djankov et al, 2001)
This assumption is still accurate today. Transparency International’s 2024 Corruption Perceptions Index shows that the least corrupt countries in the world, Denmark, Finland, New Zealand, Norway, Sweden all have parliamentary systems. Maintaining transparency and accountability is crucial. For instance in Finland and Norway, the civil service is insulated from partisan influence thanks to strict meritocratic recruitment processes and well-defined ethical standards.
Calling of elections
In his 1867 book The English Constitution, Walter Bagehot praised parliamentary governments for producing serious debates, for allowing for a change in power without an election, and for allowing elections at any time. Bagehot considered fixed-term elections such as the four-year election rule for presidents of the United States to be unnatural, as it can potentially allow a president who has disappointed the public with a dismal performance in the second year of his term to continue on until the end of his four-year term. Under a parliamentary system, a prime minister that has lost support in the middle of his term can be easily replaced by his own peers with a more popular alternative, as the Conservative Party in the UK did with successive prime ministers David Cameron, Theresa May, Boris Johnson, Liz Truss, and Rishi Sunak.
Although Bagehot praised parliamentary governments for allowing an election to take place at any time, the lack of a definite election calendar can be abused. Under some systems, such as the British, a ruling party can schedule elections when it believes that it is likely to retain power, and so avoid elections at times of unpopularity. (From 2011, election timing in the UK was partially fixed under the Fixed-term Parliaments Act 2011, which was repealed by the Dissolution and Calling of Parliament Act 2022.) Thus, by a shrewd timing of elections, in a parliamentary system, a party can extend its rule for longer than is feasible in a presidential system. This problem can be alleviated somewhat by setting fixed dates for parliamentary elections, as is the case in several of Australia's state parliaments. In other systems, such as the Dutch and the Belgian, the ruling party or coalition has some flexibility in determining the election date. Conversely, flexibility in the timing of parliamentary elections can avoid periods of legislative gridlock that can occur in a fixed period presidential system. In any case, voters ultimately have the power to choose whether to vote for the ruling party or someone else.
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Disadvantages
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Incomplete separation of power
As Arturo Fontaine notes, when a single party holds an overwhelming majority in the legislature—usually around two-thirds of the seats—power can become concentrated even under a parliamentary system. Hungary is often cited as an example of this path: once one party gained dominance in parliament, it was able to amend the constitution and reorganize key institutions in ways that weakened democratic checks and balances.
Korean scholarship on comparative politics and constitutional law offers an additional layer to this discussion. Many scholars argue that excessive power concentration cannot be explained simply by whether a country has a presidential or parliamentary system. Instead, it depends on how various institutional factors interact—such as whether the legislature is bicameral, how rigid the constitutional amendment process is, the degree of judicial independence, and the type of electoral system (majoritarian versus proportional representation). They also emphasize how party structure and discipline shape these dynamics. Comparative studies in Korea point out that what matters is not just the formal authority of the parliament, but its actual capacity to exercise power, which depends heavily on the details of institutional design.
Another recurring theme in Korean research is the internal organization of political parties. When parties maintain tight control over candidate selection and legislative behavior, party leaders can accumulate significant policymaking and legislative authority. Without proper institutional checks, this can lead to personal or collective domination within the legislature. Scholars therefore highlight that the internal democracy of parties and their coordination mechanisms with government bodies play a crucial role in determining how power is distributed and exercised.
Finally, Korean studies also warn that similar patterns of power concentration can appear in presidential systems. From this perspective, the risks of concentrated power depend less on the formal type of government and more on broader structural factors—such as authoritarian legacies, electoral competitiveness, and the independence of the judiciary and legislature. Thus, when analyzing separation of powers from a comparative institutional viewpoint, it is essential to move beyond simple typologies and consider both institutional design and the surrounding political context to reach a more accurate understanding and policy response.
Legislative flip-flopping
The ability for strong parliamentary governments to push legislation through with the ease of fused power systems such as in the United Kingdom, whilst positive in allowing rapid adaptation when necessary e.g. the nationalisation of services during the world wars, in the opinion of some commentators does have its drawbacks. For instance, the flip-flopping of legislation back and forth as the majority in parliament changed between the Conservatives and Labour over the period 1940–1980, contesting over the nationalisation and privatisation of the British Steel Industry resulted in major instability for the British steel sector.[39]
Political fragmentation
Some scholars contend that strong party discipline in parliamentary systems can restrict legislators’ freedom to vote or express differing opinions, which in turn suppresses the diversity of viewpoints represented in the legislature. Korean scholars, in particular, have noted that the ways parties handle candidate nominations, internal primaries, and decision-making processes have a major impact on how much autonomy individual legislators can exercise. The tighter the central party’s control over nominations, the more legislators tend to rely on party leadership and align with its policy direction. Reports from Korean electoral and parliamentary research bodies further observe that closed and highly centralized nomination procedures often weaken local representation. This structure reinforces a “party-centered” form of politics, making it institutionally difficult for minority perspectives and diverse voices to be heard in the legislature. Over time, such mechanisms can also fuel broader political fragmentation, seen in the dispersal of voter bases and periodic realignments of party systems. At the same time, several studies have found that certain institutional reforms—such as opening up party primaries, strengthening intra-party democracy, and adjusting the share of proportional representation seats—can help legislators better represent local and voter interests, thereby promoting greater political diversity. From this perspective, the notion that “parliamentary systems inherently produce political fragmentation” is overly simplistic. A fuller understanding requires examining how party organization, nomination systems, and electoral design interact to shape political outcomes.
Democratic unaccountability
In parliamentary systems, the head of government is selected by the parliamentary majority rather than through direct popular vote. As a result, voters often find it harder to hold specific leaders directly accountable for government performance. This indirect relationship can weaken citizens’ capacity to demand responsibility for policy outcomes. Korean scholars argue that accountability is shaped less by the type of political system than by its institutional design. They commonly distinguish between vertical accountability and horizontal accountability, which refers to oversight among branches of government. In parliamentary settings, coalition politics and intra-party bargaining can blur these lines of responsibility, making it difficult to pinpoint who should answer for policy failures. Researchers further emphasize that closed candidate selection, opaque party governance, and weak oversight bodies seriously undermine effective accountability. When legislatures, courts, and audit agencies lack independence, citizens’ ability to monitor those in power is diminished. Hence, democratic unaccountability should not be seen as an intrinsic weakness of parliamentarism itself, but rather as a symptom of broader institutional and party-structural deficiencies.
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Africa
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