There’s talk of David Cameron having to step down and of course the chorus of calls for Silvio Berlusconi to resign is rising. So a little comparison of the two systems might be interesting.
Both countries have prime ministerial systems – that means that the head of government stays in power for as long as he or she has the confidence of Parliament. If they lose that confidence, either in an explicit vote or because they lose the support of their party or their coalition, then they will normally give their resignation to Queen or President. The latter then follows a clear procedure to find a successor which sometimes takes a few days but has on occasions taken months. The former normally has a pre-chosen successor ready in waiting.
The Italian method is well tried and pretty straightforward, only as with many things in this country, it can take some time.
Despite the plethora of no confidence votes recently and despite the 57 governments since Italy became a republic, almost none of them fell after a vote. Normally, internal opposition made it known to the serving prime minister that he no longer had the support of the House (it was normally the Chamber of Deputies). He would then offer his resignation to the President who would follow the Constitution, consult with party leaders and former presidents, try and find a likely candidate to take over and give him a mandate to form a government. The negotiations sometimes took months. In the so-called First Republic, this process was even used after general elections. Since then, from 1994, the candidate for prime minister has been explicit but even then, sometimes it has taken time to form a government.
Today, there is a contradiction between the prime minister who was listed as the leader of a coalition (and therefore is in a sense an “elected” prime minister, or at least someone with a personal popular mandate) and the constitution which still gives supremacy to parliament. So Berlusconi argues that he is “anointed by the people” and that if he loses support (as he did in 1994), there should be new elections (which did not happen then). So if and when he goes, especially if it is soon, he will certainly demand new elections and almost certainly he will not get them. The most likely scenario is that Napolitano will follow the constitution, consult party leaders and, most likely, find a suitable non-party “technician” to lead a government of national unity. Alternatively, in theory at least, there could be a new centre-right leader with the same majority but somehow that does not seem likely.
In Britain, without a codified constitution, everything is much more flexible. Since World War II, six serving prime ministers have stood down: Churchill (1955), Eden (1957), Macmillan (1963), Wilson (1976), Thatcher (1990), Blair (2007). The first three were Tories who at the time had an informal consensus system of choosing leaders – the party grandees decided who was the best chap to run the show and he became leader. If they were in power, then he became prime minister. Any backbiting or infighting was kept well behind closed doors. Wilson was succeeded by James Callaghan in a vote by Labour MPs. Thatcher was ousted by her own party most of whom felt by 1989 that she was a liablity to their chances of winning the next election. It was a bitter and difficult series of campaigns in which Thatcher felt she had been betrayed by her party and said so very openly. Again as with the Labour party, it was the MPs who elected John Major as her successor and PM. Gordon Brown was elected leader of the Labour Party to replace Blair in what was in practice a non-contested election.
In all these cases, the party in power had a clear majority in the Commons so the leadership and the premiership went together. This is not the case today.
Today, if Cameron were to resign, the Conservatives would have to elect a new leader but he or she would not automatically become PM. For the first time since the war, Britain has a coalition and just as we were in uncharted waters last year when there was no majority, so there are no precedents today.
There have been some suggestions that “Nick Clegg must lead” and create a new Lib-Lab coalition with Ed Milliband’s Labour Party. That is a possibility but at the moment, not a very likely one. Another is that Clegg could take over the existing coalition but I can’t see many Tories accepting that. Or they could follow previous precedents which would mean a new Conservative leader taking over the party and Downing Street.
It will be new, it might be messy but paradoxically, despite the uncertainties, it will definitely be quicker and cleaner than the Italian succession whenever that takes place.
I’ll come back to the questions of the Italian succession very soon as it is a pressing problem.
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