Holding Prime Ministers to Account: A Comparative Study of Canada, Australia, Ireland and the UK

Executive power in parliamentary democracies is defined by a tension between prime ministerial responsibility, individual ministerial responsibility, and collective cabinet responsibility. As heads of government, prime ministers derive their authority from parliament, and must in turn give account to parliament for their actions and decisions, as well as for the actions and decisions of the government. Prime ministers wield considerable authority and visibility in parliamentary democracies, especially in the light of the personalisation or ‘presidentialisation’ of politics. Yet their precise powers and responsibilities are scarcely defined in constitutional documents, and are often the result of an accrual of conventions and practice. The relationship between heads of government and parliaments thus concerns the direct relationship between powerful political leaders and the institution to which they are accountable. Holding the government to account is one of the main functions of legislatures, and allowing parliamentarians to question prime ministers contributes to this function. Yet, considering this ambiguous place of the prime minister within the executive, little is known about how this process of request and provision of information and explanation plays out in different political systems: What are prime ministers questioned and held to account for? To what degree are they asked to give account for their own actions and decisions, and to what degree are they asked to speak for the government? This paper investigates the practice of holding prime ministers to account in Canada, Australia, Ireland, and in the UK. Using quantitative and qualitative text analysis, it looks at oral questions asked in parliamentary procedures where prime ministers are questioned together with ministers (Question Period in Canada and Question Time in Australia) versus procedures where they are questioned alone (PMQs in the UK and Oral Questions to the Taoiseach in Ireland), and investigates the degree to which prime ministers are questioned for matters that are directly within their remit, or shared with a minister, and the extent to which they are asked about matters for which other ministers or the government are responsible. This provides important comparative conclusions about a crucially overlooked aspect of executive-legislative relations in parliamentary democracies: the direct accountability relationship between prime ministers and legislatures, and how this relationship is enacted and practiced through routine questioning in parliament. It also provides a starting point for conceptualising the effectiveness of parliamentary questioning mechanisms, as well as suggestions for institutional design.