The latter half of the 20th century saw the integration of the countries of Europe on an unprecedented scale into what is now known as the European Union. The countries of the EU, however, whilst adhering to the principles of liberal democracy, have vastly different democratic systems. These differences can be seen in the hugely different roles that the Prime Minister has in different countries within the Union. This essay will compare and contrast the differences in power that can be observed in the Prime Ministers of France and Italy, together with the Chancellor in Germany.
In the Italian political system the Council of Ministers is the government, headed by the prime minister. The Italian President has a non-executive role and is not expected, as in Germany, to intervene in politics on a day-to-day basis. This is left to the Prime Minister who is appointed by the President. The Prime Minister relies on the confidence of Parliament so the President has little freedom choosing his appointment because he must choose someone who has the backing of the members of Parliament.
Unlike the German patronage system, the Italian prime minister does not appoint ministers – this is left to the party chiefs. Furthermore, compared to the German Chancellor’s high level of job security the Italian Prime Minister’s position is rather shakier. He cannot count on the support of a closely controlled party base or a loyal cabinet as he often heads a fragile coalition. Ministers have the right to withdraw from the government at any time, usually leading to the fall of the prime minister.
In the Italian system it can be argued that it is the party leader who is the more important figure. Although technical possible, in practice the office of Prime Minister is never held by a party boss, mostly due to political and personal rivalry. De Mita attempted this in the 1980s but it failed and he ended up losing both positions. This gives little chance for the prime minister to establish a strong personal position to develop policy or pursue long-term strategies.
In the 1980s Prime Ministers Spandolini and Craxi attempted to strengthen the office of the prime minister. Spandolini’s reforms, however, did not really achieve a great deal as they were too formal and missed the essential weakness of the office – the dependence on the party divisions. Craxi made attempts to create a more decisive and enterprising government, based not on compromise and negotiating but taking the initiative itself. Once again, this failed, due in part to a lack of support from the party and the feeling the reforms were intended to further his own political ambitions.
Changes to the electoral system have been made with a view to creating coalitions before elections in order to govern for a full term with a stable majority. Berlusconi had a personal mandate in 1994, against the principle of the new system of party unity. He took the prime ministership for himself but only lasted eight months.
It is fair to say that the Italian Prime Minister has a certain amount of power but there are many constraints that prevent him from exercising this power. When compared to the German Chancellor, the Italian Prime Minister appears to be far less important and less powerful; the different levels of job security that they both enjoy illustrate this.
The German system has a federal president and Chancellor who is head of government. He is elected by the Bundestag and is accountable to it. The federal president is essentially symbolic, a figurehead for the nation. They rarely intervene in day-to-day politics. The German constitution (Basic Law) clearly states that it is the Chancellor, not the president, who proposes policy and instigates legislation. The Chancellor is nominated by the president at the start of each legislature and must receive an absolute majority of all bundestag members to be elected.
The Chancellor’s term of office is extremely secure as he can only be removed by a constructive vote of no confidence. This requires an absolute majority of all members of the bundestag agreeing for the Chancellor to be replaced by a named candidate. This has happened only once when the FDP broke their coalition with the Social Democrats; Helmut Kohl (the Christian Democrat leader), was installed as a result.
This constitutional security for the office of Chancellor has ensured that in the last 50 years there have only been seven Chancellors. This contrasts with Italy where there were 20 prime ministers between 1945 and 1992.
Ministers appointed by the Chancellor head the various departments of the federal government. The federal Chancellery now has over 400 officials that coordinate the activities of government; this is an office that has grown in size and power through the work of successive Chancellors.
Different Chancellors have different methods and levels of intervention in the work of their ministries; Adenauer and Schmidt dominated their governments whilst Kohl allowed his ministers a greater degree of freedom. The office of the Chancellery has varied in power through the years; in the early years of the federal republic there was talk of a “Chancellor democracy”1 The advantage of having the backing of the party was illustrated with Adenauer, the first Chancellor, who enjoyed support from the party and the Western powers, as well as a strong personality and the will to intervene in the activities of his ministers.
This contrasted with his successors Erhard and Kiesinger whose party infighting hurt their ability to govern effectively in the same vein as Adenauer. From this we can see that there are constraints on the power of the Chancellor, despite the office’s apparent dominance over the government. Kohl was seen as being indifferent to many policy issues; the power of the office, however, allowed him to intervene as and when he saw fit; he showed his power over issues such as the single currency and reunification.
The concept of patronage can be seen to both aid and hinder Chancellors. In theory, they may appoint anyone to ministerial positions but in practice the majority of ministers are parliamentarians chosen by the parties. This relates back to the Chancellors relationship with, and to some extent, control of, the party. A Chancellor must take into account high-powered members of the party, particularly if they have strong support and wish to be included in the government. The bargaining theme that underlies German politics is apparent in the appointments process as the Chancellor negotiates with the various parties in the coalitions over ministerial appointments.
Unlike most European countries, France has a strong president who is popularly elected and then appoints the prime minister. Article 8 allows the president to nominate the prime minister; whether confirming the appointment of the leader of the party with a parliamentary majority or actually making his own choice. Article 21 of the constitution states that the prime minister directs the action of the government with issues of national defence and the nomination of officials attributed to both the president and the prime minister. The powers of the Prime Minister include appointing members of the government team, definition of objectives, driving policy, decision making and policy implementation. He is seen in the political world as the embodiment of the collective will of the government.
Under the constitution, the French president’s power are fairly limited, mostly to head of state ceremonious roles such as signing treaties, presiding over committees of national defence, acting as commander-in-chief, appointing high ranking judges and dissolving the national assembly. The period of 1958 – 69 saw the presidency of Charles de Gaulle; characterised in one sense by his interpretation of the constitution for his, and the office of the president’s own benefit. Selection of ministers became a presidential power, despite the constitution giving this power to the prime minister. By the end of his term de Gaulle had left the legacy of a strong presidency; one basing itself on long-term strategy and leaving presidential appointments to the prime minister.
If the French President does not have a political majority in the elected lower house – the National Assembly – then he must appoint a prime minister from the opposition party. This causes him to lose much power and it helps to strengthen the power of the opposition party prime minister. The term cohabitation is used to describe the situation whereby the electorate has voted in a political majority opposed to the President. The Prime Minister’s powers may be said to increase during such times as he has the backing of the majority grouping in the National Assembly.
The relevant ministerial department usually handles policy proposals in France but the system allows the prime minister or the president to intervene with their own ideas through their own personal departments, the Matignon and the Elysï¿½e respectively. This creates a fairly equal balance of power when dealing with such issues.
The Prime Minister is usually perceived as the natural leader of the majority party in Parliament and his authority over the members of that majority is a powerful factor in keeping political unity. Without the support of the majority, however, the Prime Minister’s and his government’s position with regards to pushing through legislation would be impossible. A stable parliamentary majority, united around the Prime Minister, gives him considerable power in Parliament to drive the government’s policy proposals.
The French Prime Minister also has other powers with regards to Parliament; he signs and tables bills in the name of the government, he can ask the President to convene a special session of Parliament, he can submit a law to the Constitutional Court prior to it’s assent and, perhaps most importantly, make recommendations to the President to initiate a Constitutional review.
Comparison between the French prime minister and, for example the German Chancellor proves difficult, as the French president is a powerful actor in the political landscape. This contrasts with the German president who is essentially symbolic. French Presidents will try to rise above day-to-day politics; by distancing themselves from their own governments they can let the Prime Minister take the criticism and stand back away from the problem.
In conclusion it is fair to say that within the French political system there exists a constant power struggle between the elected president and the nominated prime minister. The system has a strong executive with a weak parliament and within the executive the president is usually the centre of power. The balance of power, however, is not constant, especially when the president faces a parliament in which he does not have a majority.
Furthermore, then, that the German system of coalition governments in the federal parliament is generally stable. In order to function, the Chancellor must balance the views of the different factions; this in turn prevents him from accumulating excessive power. Despite these constraints, it is fair to say that the German Chancellor has the ability to exercise more power than the Italian Prime Minister.
Furthermore, it is clear that the Prime Minister of France faces a constant power struggle with the French President and as such could not be considered to exercise as much political power as either the German Chancellor or the Italian Prime Minister. In all cases the ability of any political figure, especially a Prime Minister or Chancellor, depends not just on institutional powers but also on personalities and political bases.