A Comparison of the Australian, British, and American Political Systems

John Kilcullen
Macquarie University
Copyright (c) 1995, 2000, R.J. Kilcullen.

The Australian political system is in some ways like the British, in others like the American.

1. Like the American system ours is federal: i.e., there are two levels of government, neither of which can change the powers of the other or make laws within certain fields assigned to the other. The British system is 'unitary': the British parliament can make laws on any matter, local government has whatever powers the national government delegates to it.
   
2. Like the British, ours is a system of responsible government. The Government (the Prime Minister and cabinet) is 'responsible' to parliament. This means that at any time, simply by vote of no confidence, carried on whatever grounds, the parliament can remove the Government from office or force it to call an election. In the American system the head of the executive Government, the President, cannot be removed by the Congress (except by impeachment, which requires a kind of trial).
   
3. As in the British system, a general election can be called at any time (by the Governor-General, on the advice of the Prime Minister). There is a maximum term by which an election must be called, but an election can be held short of term. This makes the parliament responsible to the electorate -- for example, if Government policy that has general community support is blocked by the opposition or minor parties, the Government can appeal to the electorate. In the American system the terms of office of the House of Representatives, Senate, and President are all 'fixed', so that an early election cannot be held. If a President dies or resigns, the Vice-President serves out the remaining part of his term. There are no circumstances in which the American President can dissolve Congress and call an early election.
   
4. The U.S. constitution has separation of powers, i.e., the members of the Executive (in our terms, the Government) do not have seats in Congress or participate in its sessions, and they are not removable by Congress and cannot dissolve Congress. The Judiciary is also separate from both Executive and Congress (though judges are appointed by the Senate on the nomination of the President, and can in exceptional cases be removed). Our system (like the British) has an independent judiciary, but government and parliament are not separated. Ministers are members of parliament, the Government can be removed by parliament, and the Prime Minister can dissolve parliament.
   
5. Like the Americans, we have a written constitution, whereas the British constitution is unwritten. Actually this is not accurate. Parts of the British constitution are 'written', not only in text books but also in the statute book, e.g., the Parliament Act of 1911, and parts of our constitution (and also of the U.S. constitution) consist in conventions (some of which are written down, though not in the statute book). The statutory parts of the constitution are enforced by the law courts, but conventions are not. Conventions are enforced by conscience and public opinion. The provisions of the Australian and U.S. constitutional statutes are entrenched, i.e. they cannot be changed by the ordinary law-making process (in Australia amendment to the constitution requires a referendum), whereas the British constitution can be amended by simple act of parliament.

The most important of these differences is the third. A Prime Minister can make any matter a 'question of confidence', forcing his opponents either to support him on that point or face an election in which that question will be the most prominent issue. A fixed parliamentary term would be a large step toward the American system, in which Congress (and especially the Senate) can block policies supported by many electors (e.g. on medicare, gun control, campaign funding) without risk of having to fight an election on those issues.

See also A Comparison of the Australian and Canadian Political Systems.

Shortcomings

The political systems of Australia,  Britain, Canada and the United States all have shortcomings. In the not-too-distant future these societies will  need to deal with issues that may require extensive changes to life-style and social organisation, issues such as global warming, terrorism, religious conflict, energy shortages, war. None of these "democratic" systems does well in focussing the attention of a large enough proportion of the population on a problem and giving people suggesting possible solutions an opportunity to mobilise enough public support to carry any solution out.

The US political system is particularly unsatisfactory. This is a worry, since the United States is the chief source of global warming, the most influential model of an unsustainable way of life, the most powerful negotiator in trade deals, the country with the most powerful armaments, and in various ways the key country in addressing the most serious problems facing the human race. The chief defect of the US political system is that the terms of office of Congress and President are absolutely fixed, so that the executive government cannot call Congressional opponents to account by dissolving the Congress and (except by impeachment) the Congress cannot call the executive government to account--i.e. the United States do not have what we call "responsible government". (See above, points 2 and 3.) As a result, US elections do not give electors the opportunity to choose a party with a coherent policy package that it will have enough political power to implement (as Westminster systems do--see here and here). It is so difficult to change the US Constitution that there seems no possibility of fixing these defects.  

Britain, Canada and the US should adopt compulsory voting and preferential voting (specifically, optional preferential voting). That is, it should be compulsory to attend the polling place, but not compulsory to actually vote, and not compulsory to express any more than one's top prefence (though possible to express lower preferences if one chooses). Voluntary voting and "first past the post" force voters to engage in "strategic" voting based on guesses about what other (potential) voters will do. A voter should be able to cast a vote that straightforwardly expresses their view. Preferential voting gives a better chance for smaller parties to compete with the traditional "major" parties, thereby making possible the political realignments that may be needed to deal with emerging problems. (In a first past the post system, a voter who votes for a "minor" party has no opportunity to express a preference between the two major parties, so when that preference is really important many voters cannot express their first preference but have to vote for one of the major parties.)

Australia, Britain, Canada and the US all have single-member constituencies in their "lower house". Single-member constituencies give a distorted reflection of public opinion, since it is possible for a party to win a majority of seats with less than 50% of the vote. This system also results in a distinction between "safe" and "marginal" seats, which leads parties to concentrate their campaigns on the undecided voters in marginal seats; it also makes the sitting members in safe seats unresponsive to public opinion and intensifies factionalism within parties. One remedy for all of this would be the adoption of multi-member constituencies and  proportional representation (see also here). If single-member constituencies are retained, something needs to be done to eliminate the safe/marginal distinction and reduce the concentration on undecided voters: see here and here. 

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