Prime ministers in republics and in monarchies[link]

The post of prime minister may be encountered both in constitutional monarchies (such as Belgium, Denmark, Japan, the Netherlands, Indonesia, Norway, Malaysia, Morocco, Spain,^[2] Sweden, Thailand, Canada, Australia, New Zealand, and the United Kingdom), and in parliamentary republics in which the head of state is an elected official (such as Finland, France, Germany, Greece, Hungary, India, Italy, Ireland, Pakistan, Portugal, Montenegro, Croatia, Bulgaria, Romania, Serbia and Turkey).

This contrasts with the presidential system, in which the president (or equivalent) is both the head of state and the head of the government. See also "First Minister", "Premier", "Chief Minister", "Chancellor", "Taoiseach" and "Secretary of State": alternative titles usually equivalent in meaning to, or translated as, "prime minister". The head of government of the People's Republic of China is referred to as the Premier.

In some presidential or semi-presidential systems, such as those of France, Russia or South Korea, the prime minister is an official generally appointed by the president but usually approved by the legislature and responsible for carrying out the directives of the president and managing the civil service. (The premier of the Republic of China is also appointed by the president, but requires no approval by the legislature.

Appointment of the prime minister of France requires no approval by the parliament either, but the parliament may force the resignation of the government. In these systems, it is possible for the president and the prime minister to be from different political parties if the legislature is controlled by a party different from that of the president. When it arises, such a state of affairs is usually referred to as (political) cohabitation.

Entry into Office[link]

In parliamentary systems a prime minister may enter into office by several means.

• By appointment by the head of state, without reference to parliament: While in practice most prime ministers under the Westminster system (including Australia, Canada, New Zealand, Malaysia, India and the United Kingdom) are the leaders of the largest party in parliament, technically the appointment of the prime minister is a royal prerogative exercised by the monarch or the governor-general. In India, the Prime Ministerial candidate must be a member of parliament either Lok Sabha (Lower House) or Rajya Sabha (Upper House). No parliamentary vote takes place on who is forming a government.

However as the government will have to outline its legislative programme to parliament in, for example, the Speech from the Throne, the speech is sometimes used to test parliamentary support. A defeat of the Speech is taken to mean a loss of confidence and so requires either a new draft, resignation, or a request for a dissolution of parliament. Until the early 20th century governments when defeated in a general election remained in power until their Speech from the Throne was defeated and then resigned. No government has done so for one hundred years, though Edward Heath in 1974 did delay his resignation while he explored whether he could form a government with Liberal party support.

In such systems unwritten (and unenforceable) constitutional conventions often outline the order in which people are asked to form a government. If the prime minister resigns after a general election, the monarch usually asks the leader of the opposition to form a government. Where however a resignation occurs during a parliament session (unless the government has itself collapsed) the monarch will ask another member of the government to form a government. While previously the monarch had some leeway in whom to ask, all British political parties now elect their leaders (until 1965 the Conservatives chose their leader by informal consultation). The last time the monarch had a choice over the appointment occurred in 1963 when the Earl of Home was asked to become Prime Minister ahead of Rab Butler.

During the period between the time it is clear that the incumbent government has been defeated at a general election, and the actual swearing-in of the new prime minister by the monarch or governor-general, that person is variously referred to as the "prime minister-elect", "...-designate" etc. Neither term is strictly correct from a constitutional point of view, but they have wide acceptance. In a situation in which a ruling party elects or appoints a new leader, the incoming leader will usually be referred as "prime minister-in-waiting". An example or this situation was in 2003 in Canada when Paul Martin was elected leader of the Liberal Party of Canada while Jean Chrétien was still prime minister.

• Appointment by the head of state after parliament nominates a candidate: Example: The Republic of Ireland where the President of Ireland appoints the Taoiseach on the nomination of the Dáil Éireann.
• The head of state nominates a candidate for prime minister who is then submitted to parliament for approval before appointment as prime minister: Example: Spain, where the King sends a nomination to parliament for approval. Also Germany where under 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.
• The head of state appoints a prime minister who has a set timescale within which s/he must gain a vote of confidence: (Example: Italy, Romania, Thailand)
• The head of state appoints the leader of the political party with the majority of the votes in the Parliament as Prime Minister: (Example: Greece)
• Direct election by parliament: (Example: Japan, Papua New Guinea, Pakistan.)
• Direct election by popular vote: (Example: Israel, 1996–2001, where the prime minister was elected in a general election, with no regard to political affiliation.)
• Nomination by a state office holder other than the head of state or his/her representative: (Example: Under the modern Swedish Instrument of Government, 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 no (i.e. he can be elected even if more MP:s vote no than yes).

Prime ministers and constitutions[link]

The position, power and status of prime ministers differ depending on the age of the constitution.

Australia's constitution makes no mention of a Prime Minister of Australia.

Bangladesh's constitution clearly outlines the functions and powers of the Prime Minister, and also details the process of his/her appointment and dismissal.

The People's Republic of China constitution set a premier just one place below the president of the PRC. While the president deals with international problems, the premier deals with national problems. For example, the earth quake in 2008, the premier will be the first to arrive, then the president arrived after to just examine the situation. Premier read as (Simplified Chinese: 总理; pinyin: Zŏnglĭ) in Chinese.

Canada's constitution, being a 'mixed' or hybrid constitution (a constitution that is partly formally codified and partly uncodified) originally did not make any reference whatsoever to a prime minister, with her or his specific duties and method of appointment instead dictated by "convention". In the Constitution Act, 1982, passing reference to a "Prime Minister of Canada" is added, though only regarding the composition of conferences of federal and provincial first ministers.

Germany's Basic Law (1949) lists the powers, functions and duties of the federal chancellor.

Greece's constitution (1975) lists the powers, functions and duties of the Prime Minister of Greece.

India's constitution (1950) lists the powers, functions and duties of the Prime Minister of India.

Ireland's constitution (1937), provides for the office of Taoiseach in detail, listing powers, functions and duties.

Italy's constitution (1948) lists the powers, functions and duties of the Prime Minister of Italy.

Japan's constitution (1946) lists the powers, functions and duties of the Prime Minister of Japan.

Malta's constitution (1964) lists the powers, functions and duties of the Prime Minister of Malta.

Malaysia's constitution (1957) lists the powers, functions and duties of the Prime Minister of Malaysia.

Pakistan's constitution (1973) lists the powers, functions and duties of the Prime Minister of Pakistan.

Spain's constitution (1978) regulates the appointment, dismissal, powers, functions and duties of the President of the Government.

Thailand's constitution (1932) lists the powers, functions and duties of the Prime Minister of Thailand.

The United Kingdom's constitution, being uncodified and largely unwritten, makes no mention of a prime minister. Though it had de facto existed for centuries, its first mention in official state documents did not occur until the first decade of the twentieth century. Accordingly, it is often said "not to exist", indeed there are several instances of parliament declaring this to be the case. The prime minister sits in the cabinet solely by virtue of occupying another office, either First Lord of the Treasury (office in commission), or more rarely Chancellor of the Exchequer (the last of whom was Balfour in 1905).

Exit from office[link]

Most prime ministers in parliamentary systems are not appointed for a specific term in office and in effect may remain in power through a number of elections and parliaments. For example, Margaret Thatcher was only ever appointed prime minister on one occasion, in 1979. She remained continuously in power until 1990, though she used the assembly of each House of Commons after a general election to reshuffle her cabinet.

Some states, however, do have a term of office of the prime minister linked to the period in office of the parliament. Hence the Irish Taoiseach is formally 'renominated' after every general election. (Some constitutional experts have questioned whether this process is actually in keeping with the provisions of the Irish constitution, which appear to suggest that a taoiseach should remain in office, without the requirement of a renomination, unless s/he has clearly lost the general election.) The position of prime minister is normally chosen from the political party that commands majority of seats in the lower house of parliament.

In parliamentary systems, governments are generally required to have the confidence of the lower house of parliament (though a small minority of parliaments, by giving a right to block supply to upper houses, in effect make the cabinet responsible to both houses, though in reality upper houses, even when they have the power, rarely exercise it). Where they lose a vote of confidence, have a motion of no confidence passed against them, or where they lose supply, most constitutional systems require either:

a) a letter of resignation or

b) a request for parliamentary dissolution.

The latter in effect allows the government to appeal the opposition of parliament to the electorate. However in many jurisdictions a head of state may refuse a parliamentary dissolution, requiring the resignation of the prime minister and his or her government. In most modern parliamentary systems, the prime minister is the person who decides when to request a parliamentary dissolution.

Older constitutions often vest this power in the cabinet. (In the United Kingdom, for example, the tradition whereby it is the prime minister who requests a dissolution of parliament dates back to 1918. Prior to then, it was the entire government that made the request. Similarly, though the modern 1937 Irish constitution grants to the Taoiseach the right to make the request, the earlier 1922 Irish Free State Constitution vested the power in the Executive Council (the then name for the Irish cabinet).

Titles[link]

Different terms are used to describe prime ministers. In Germany and Austria the prime minister is actually titled Federal Chancellor (Bundeskanzler). In the Russian constitution the prime minister is actually titled Chairman of the government while the Irish prime minister is called the Taoiseach (which is rendered into English as prime minister), and in Israel he is 'Rosh HaMemshalah' meaning head of government. In many cases, though commonly used, "prime minister" is not the official title of the office-holder; the Spanish prime minister is the President of the Government (Presidente del Gobierno).

Other common forms include president of the council of ministers (for example in Italy, Presidente del Consiglio dei Ministri), President of the Executive Council, or Minister-President. In the Scandinavian countries the prime minister is called statsminister in the native languages (i.e. minister of state). In federations, the head of government of subnational entities such as provinces is most commonly known as the premier, chief minister, governor or minister-president.

In non-Commonwealth countries the prime minister may be entitled to the style of Excellency like a president. In some Commonwealth countries prime ministers and former prime ministers are styled Right Honourable due to their position, for example in the Prime Minister of Canada. In the United Kingdom the prime minister and former prime ministers may appear to also be styled Right Honourable, however this is not due to their position as head of government but as a privilege of being current members of Her Majesty's Most Honourable Privy Council.^[3]

In the UK where devolved government is in place, the leaders of the Scottish, Northern Irish and Welsh Governments are styled First Minister. In India, The Prime Minister is referred to as "Pradhan Mantri", meaning "prime minister". In Pakistan, the prime minister is referred to as "Wazir-e-Azam", meaning "Grand Vizier".

Description of the role[link]

Wilfried Martens, who served as Prime Minister of Belgium, described his role as follows:

First of all [the Prime Minister] must listen a lot, and when deep disagreements occur, he must suggest a solution to the matter. This can be done in different ways. Sometimes during the discussion, I note the elements of the problem and think of a proposal I can formulate to the Council (cabinet), the Secretary taking notes. The Ministers then insist on changing game ages. The Prime Minister can also make a proposal which leaves enough room for amendments in order to keep the current discussion on the right tracks. When a solution must be found in order to reach a consensus, he can force one or two Ministers to join or resign.^{[citation needed]}

Lists of prime ministers[link]

The following table groups the list of past and present prime ministers and details information available in those lists.