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Canadian Government vs British – Observations from An American
I have studied the British Parliamentary system for some time, decades actually, and started watching Prime Minister’s Questions when they first started appearing on C-Span in the United States in the 1990s.
I have since viewed House of Commons sessions on the UK Parliamentary website from time to time, just as I have both the U.S. House and Senate on C-Span.
So when I started watching the Canadian House of Commons—especially recently because of the issues Trudeau’s government has been having—I noticed both similarities and differences. I’ve also noticed differences in how the Canadian Liberal Caucus operates compared to the British Conservative Party caucus in how they challenge their party leader within that caucus.
How the Canadians question their ministers
How a Canadian Prime Minister receives questions versus the British Prime Minister is essentially the same. The star questioner is the official Leader of the Opposition, with other opposition party leaders getting a shot, as well as backbenchers of all parties.
But I’ve noticed a difference in how subordinate cabinet ministers are questioned. In the British system, the opposition has a matching shadow cabinet against the ruling party’s equivalent cabinet minister. And those shadow cabinet members lead off the questioning of their cabinet equivalent. Not so much in the Canadian house. The shadow cabinet doesn’t seem to be recognized as such, so when a particular cabinet minister’s performance is being questioned, she or he might not even be there, in which case other cabinet ministers take turns defending the government’s position.
How the Speaker Presides
The British Speaker of the House is more direct when a member gets too rowdy, which can happen quite often. The Canadian Speaker is more restrained. So much so, it’s almost awkward. The British Speaker will shout out at members who misbehave. When this happens in the Canadian House, the Speaker stands up, and in a normal, restrained voice, tells off the offending member with awkward politeness.
Another awkward look is the Canadian House of Commons pages. They sit in front of the podium where the Speaker’s chair is and face away from the Speaker. But when the Speaker stands, they do too, and when the Speaker sits, so do they. I don’t know if they have a mirror showing them when the Speaker sits and stands, but they also seem to be looking kind of behind, while sort of not looking behind. Again, it looks awkward.
The Members
The British House has bench seating, and there are times when there’s not enough room for all the members to sit. A lot of members stand. It’s the only legislative body to seat their members that way, which I know of. Even the U.S. House, which doesn’t assign seats, still has individual seats for members to sit. In the Canadian House, members have assigned seating with desks. When the Canadian MPs express their approval, they clap and pound their desks. British MPs are not allowed to clap, so they will express approval by yelling “hear, hear” or outright cheer, or boo if expressing disapproval. There’s theater in both Canadian and British Houses. But the Canadians manage to subdue theirs. Again, to the point of awkwardness.
Also, Canada is officially a bilingual country, so a lot of the speechifying is in French. When someone is speaking French, and you’re watching on television (or YouTube), the audio goes completely silent, so you can’t even hear the cheering, clapping or booing, while the French-to-English translator talks. And when they do, it takes the passion out of what the member speaking actually is saying. More awkwardness.
And this awkwardness probably is a part of their culture with respect to the U.S. and the UK. Obviously, there are plenty of Canadians who are comfortable in their skins, but I don’t think Canadian culture as a whole is.
And I was somewhat amazed to find out that the Liberal caucus does not have the ability to fire their party leader. It’s understood that the party leader is elected in a national election by liberal party members. But the British Conservative MPs can get rid of a party leader without a national vote. Well, that’s awkward.
The members of the Liberal caucus can only advise their leader that he needs to resign. But they all acknowledge it’s his decision.
Like the British House of Commons, the Canadian House can vote on a motion of no confidence. If it passes, the Prime Minister is either required to resign or call a snap election (roughly, there are legalisms involving the Governor-General, who is the King’s representative in Canada). The members of the party in power can also vote for that motion of no confidence like any member of the House of Commons can.
Yet, even then, the resigning Prime Minister remains leader of his party, unless he resigns from that too. And the caucus members can’t do anything about it.
Published in General
Blame Sir Winston for the seating in the House in the UK. On 10. May 1941 the Luftwaffe scored a direct hit on Westminster, destroying the House, damaging the Lords Chamber, Westminster Hall and the clock tower. Churchill was determined that the House be restored and resisted the idea of additional seating. “We shape our buildings and afterwards our buildings shape us.”
To this day, members must show up very early, fill out a “prayer card” and reserve a seat in the House.
Many of the artifacts destroyed in the air raid were replaced by gifts from the parliaments of the Commonwealth. The Speaker’s chair is from Australia, the Table of the House is from Canada, and the Entrance doors from India and Pakistan, just to name a few.
I hope this goes main feed so we can ask j. J. McCullough to give his reaction. It might be fun.
I favor the intimacy I see in the British House. And it’s not always full, just like any legislative chamber where the legislators have other duties.
So I’ll credit Sir Winston instead of blaming him.
Fun fact, I have a picture of me sitting in the speaker’s chair in Sydney thanks to my cousin’s friend who gave us a private tour in 2013.
Were you arrested for insurrection?
Had I been, I wouldn’t have been allowed back in last year.
Kinda off on a few points… The inability to get rid of a leader is quirk (perversion even?) of the Liberal Party. Other parties can and do have more frequent leadership reviews. Kinda like a partisan recall election were caucus MPs vote on the confidence of the leader – and if he fails (he so far) there is a national convention for the membership to either affirm the leader or replace him… Another Quirk of the Liberal Party – you dont have to be a citizen to be a member and vote in leadership races… The Chinese Embassy was caught bussing students into nomination meetings to vote on particular races.
If a confidence motion fails – an election must be called, the PM does not have the option to resign as a delay tactic… If you could imagine the PM resigns, there will be a 4 or 5 month leadership race, and the New PM will recall parliament and have a throne speech…Generally the New PM will call an election to seek a fresh mandate from the people with in 6 months or so of taking power.
This is why I dont want Trudeau to resign … IF he resigns parliamentary tradition will push the election back 8 or 9 months – I want the election now… The earliest the government could fall is in February, as the house has risen for Christmas break, and is not back until Jan 27. So that could push the election back to late March. Traditionally Canada has a roughly 40 day election campaign. Its why I find it comical, that Kamala complains about only having 107 days to run… Almost 3 times what a normal Canadian election would be…
We are currently in what the British call a Hung Parliament. The opposition parties divided between them have more seats than the governing party. We call it a Minority Government. At first Trudeau was very excited to have a Minority Government as he thought it would be an excellent opportunity to wear black face regularly. This difference is largely because of Alberta, out here a Hung Parliament, just sounds like a sensible suggestion.
I sent him a link.
Well…no. If they had insufficient seating before, and the same seating after, it’s not Churchill’s fault they have insufficient seating.
Earlier this year I donated to Goodwill the VHS 2-tape set I had of the Great Speeches in Parliament compilation published by Politico’s Publishing in 1999 to celebrate the first ten years of television coverage of the House of Commons. Full versions of both tapes are available on YouTube: Volume 1, Volume 2.
From House of Commons Procedure and Practice:
Basically the Governor General has the option of asking someone else to form a government if the Prime Minister resigns. It needn’t be a party leader.
In a parliamentary system – particularly one that doesnt have a constitution, like Britain or a very weak constitution like Canada – Practice and Tradition are just as important as the actual legal framework… It maybe a proper legal response for a PM to resign in the face of a non-confidence vote – but its never been done. Its a non-confidence in the government – not just the person.
I know it famously happened in WW ii, once Neville Chamberlain resigned, the King asked Winston Churchill to form a government. That’s the only instance of that happening that I am aware of – I can’t think of a single event like that in Canadian history…
It’s more likely to happen if a government fails just after an election. The sovereign – or in the case of a republic like Germany, the president – will try to avoid having another election so close to the previous one.
That’s not the issue right now in Canada.
As far as the Brits are concerned, the King asked Churchill to form a government on the advice of the more prominent members of majority party in power at that time (they didn’t have formal party leaders then). It was because Chamberlin resigned.
And after Boris Johnson won a landslide victory in 2019, he was kicked out as Conservative party leader ostensibly because of his conduct during Covid, with two other Prime Ministers appointed by the sovereign before elections were called. But still, he resigned as Prime Minister.
It’s true that the British House of Commons did not pass a motion of no confidence, either when Churchill was appointed or when Boris Johnson (and Liz Truss) resigned.