India and UK: A Comparison of Parliamentary Systems

Two years after leading the Labour Party to a landslide victory in the 2024 general election, British Prime Minister Keir Starmer has resigned as both Prime Minister and leader of the Labour Party. His victory in 2024 ended 14 years of Conservative rule, with Labour securing 412 seats in the House of Commons.

Starmer had campaigned on a promise of “Change” to build a fairer, healthier and more secure Britain. However, his government struggled to meet public expectations amid persistent economic and political challenges linked to the post-Brexit period. His resignation means that the United Kingdom will have had seven Prime Ministers in a decade, reflecting continuing political instability.

Although the UK Prime Minister serves during the life of a Parliament, the five-year term applies to the government and Parliament rather than to an individual Prime Minister. Consequently, a Prime Minister may resign or be replaced before the completion of the parliamentary term. Among recent leaders, Boris Johnson served the longest, holding office from 2019 to 2022.

India and UK: A Comparison of Parliamentary Systems

India and the United Kingdom both follow the Westminster model of parliamentary democracy, sharing several institutional features while differing in important constitutional aspects.

Feature	United Kingdom	India
Head of State	King Charles III (Hereditary Monarch)	President of India (Indirectly elected)
Head of Government	Prime Minister	Prime Minister
Parliament	Bicameral: House of Commons & House of Lords	Bicameral: Lok Sabha & Rajya Sabha
Constitutional Basis	Unwritten Constitution and Parliamentary Sovereignty	Written Constitution and Constitutional Supremacy
Legislative Authority	Parliament can make or repeal any law	Parliament’s powers are limited by the Constitution
Executive Accountability	Executive responsible to Parliament	Executive responsible to Parliament

Key Similarities

• Both countries have a ceremonial head of state and a Prime Minister as the real executive authority.
• Both possess bicameral legislatures, consisting of an upper and lower house.
• Governance is based on majority party rule, with the Prime Minister heading the party or coalition commanding a majority in the lower house.
• In both systems, the executive remains collectively responsible to the legislature, ensuring democratic accountability.

Major Differences

1. Parliamentary Sovereignty vs Constitutional Supremacy

• The UK follows the doctrine of Parliamentary Sovereignty, under which Parliament has supreme law-making authority.
• India follows Constitutional Supremacy, where Parliament’s powers are subject to constitutional limitations and judicial review.

2. Head of State

• The British Monarch holds office through hereditary succession.
• The Indian President is indirectly elected for a fixed five-year term.

3. Membership Requirement for Prime Minister

• In India, a Prime Minister or minister who is not a member of Parliament must secure membership within six months.
• In the UK, the Prime Minister is conventionally a member of the House of Commons, ensuring direct electoral accountability.

4. Position of the Speaker

• In India, the Speaker generally remains associated with the ruling party.
• In the UK, the Speaker renounces party affiliation upon election and functions in a strictly non-partisan manner.

5. Party Discipline and Defection

• India enforces party discipline through the Tenth Schedule (Anti-Defection Law), which can lead to disqualification of legislators who defect.
• The UK has no anti-defection law. Although party whips play an important role, MPs enjoy comparatively greater freedom to vote according to conscience or constituency interests.

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