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.