Ludger Helms: Five Ways of Institutionalizing Political Opposition: Lessons From The Advanced Democracies

Ludger Helms
Five Ways of Institutionalizing Political

Opposition: Lessons from the Advanced
Democracies*
IT HAS LONG BEEN ACKNOWLEDGED BY DEMOCRATIC THEORY THAT

the principle of legitimate political opposition belongs to the most
fundamental components of any liberal democracy. In the major
works on the basic character of pluralist polities, freedom of speech
and the right to publicly and legitimately oppose the policies and
actions of the government of the day have been considered as central
to the overall concept of liberal democracy as the existence of free
and fair elections.1 This idea can also be found in many concepts of
democratic theory aspiring to reach beyond the level of constitu-
tional arrangements and the area of public policy. As Ian Shapiro has
contended, ‘democracy is an ideology of opposition as much as it
is one of government’.2 The fundamental role of political opposi-
tion, both as a normative value and an empirical manifestation, for
a proper working of liberal democracy has, finally, also come to be
acknowledged by the overwhelming majority of political elites and
citizens in the older and newer democracies alike.
Surprisingly enough, the high regard for the opposition principle
in democratic theory and the sound public interest in the state of the
political opposition in the majority of established liberal democracies
have scarcely been reflected in the more recent comparative politics
* I would like to thank Arend Lijphart for encouraging me to present my thoughts,
some of which have first been developed elsewhere, to a wider English-language read-
ership, and Tim Büthe and Wilfried Swenden for their valuable comments on an earlier
draft of this paper. Thanks are also due to the two anonymous referees and the editors
of this journal for their helpful suggestions. The usual disclaimer applies.
1
See, for instance, Robert A. Dahl, Polyarchy: Participation and Opposition, New
Haven and London, Yale University Press, 1971.
2
Ian Shapiro, ‘The Fallacies concerning Minorities, Majorities, and Democratic
Politics’, in Ian Shapiro, Democracy’s Place, Ithaca and London, Cornell University Press,
1996, p. 51.
© Government and Opposition Ltd 2004

Published by Blackwell Publishing, 9600 Garsington Road, Oxford OX4 2DQ, UK and 350 Main
Street, Malden, MA 02148, USA.
INSTITUTIONALIZING POLITICAL OPPOSITION 23
literature. The huge majority of works has tended to look

at political institutions and the democratic process from the gov-
ernment’s rather than from the opposition’s point of view. Thus,
although published as early as in the mid-1960s, Robert Dahl’s Politi-
cal Oppositions in Western Democracies remains the unchallenged point
of reference in a field that has seen few substantial contributions since.
While there have been valuable attempts at refining Dahl’s theoretical
framework for the study of political opposition in fundamentally dif-
ferent settings of democratic and non-democratic systems3 as well as
thoughtful reflections on the opposition’s role in the transition to
democracy,4 it is particularly striking how little the more recent body
of political research on the subject has to offer to constitution-makers
in democratizing countries. It would indeed hardly be an exaggera-
tion to argue that the relevant political science literature on ‘consti-
tutional engineering’5 has completely missed the study of different
institutionally anchored forms of political opposition.
To date, some of the most sophisticated comparative institutional
perspectives on political opposition, such as Kitschelt’s ‘political
opportunity’ approach,6 have been developed in the context of
research into social movements. The focus of works like this is,
however, on the impact that specific institutional arrangements may
have on the strategies and successes of protest movements operating
from outside the constitutionally defined decision-making system,7
3
See especially Jean Blondel, ‘Political Opposition in the Contemporary World’,
Government and Opposition, 32: 4 (1997), pp. 462–86.
4
Alfred Stepan, ‘On the Tasks of a Democratic Opposition’, Journal of Democracy,
1: 2 (1990), pp. 41–9; idem, ‘Democratic Opposition and Democratization Theory’,
Government and Opposition, 32: 4 (1997), pp. 657–73.
5
See in particular Giovanni Sartori, Comparative Constitutional Engineering. An
Inquiry into Structures, Incentives and Outcomes, London, Macmillan, 1994, and Arend
Lijphart, ‘Democracies: Forms, Performance, and Constitutional Engineering’,
European Journal of Political Research, 25: 1 (1994), pp. 1–17.
6
Herbert P. Kitschelt, ‘Political Opportunity Structures and Political Protest:
Anti-Nuclear Movements in Four Democracies’, British Journal of Political Research, 16:
1 (1986), pp. 57–85.
7
See for instance Hanspeter Kriesi et al., ‘New Social Movements and Political
Opportunities in Western Europe’, European Journal of Political Research, 22: 2 (1992),
pp. 219–44; J. Craig Jenkins and Bert Klandermans (eds), The Politics of Social Protest.
Comparative Perspectives on States and Social Movements, London, UCL Press, 1995;
Jack A. Goldstone (ed.), States, Parties, and Social Movements, Cambridge, Cambridge
University Press, 2003.

24 GOVERNMENT AND OPPOSITION
rather than on the structural features, actual workings and systemic

effects of the existing constitutional channels designed to facilitate
‘loyal’ and ‘conventional’ political opposition within a given system.
The theoretical and analytical shortcomings of the comparative
opposition literature have been reflected in the narrow focus of most
empirical works in the field, which usually tackle only the various
manifestations of parliamentary opposition. A typology of different
patterns of parliamentary opposition (which tends to be very much
based on the given structure of the party system), or a comparative
historical assessment of the development of the parliamentary oppo-
sition in selected established democracies is the best these works have
to offer.8 The basic ‘quasi-theoretical’ distinction between different
forms of political opposition in western democracies, to which most
authors subscribe, is between parliamentary opposition, considered
to be the ‘true’ form of opposition, and other ‘deviant’ forms of polit-
ical opposition. The latter are by no means considered to include
only the various forms of ‘unconventional’, and possibly unconstitu-
tional, opposition. Rather, all possible alternatives to parliamentary
opposition – including forms of opposition which are clearly located
within the respective constitutional parameters, and even draw
specifically on the constitutionally provided devices for voicing oppo-
sition and dissent – tend to be viewed as ‘deviations’ from the par-
liamentary type of political opposition.9 It is easy to see that such a
position is viable only as long as the focus is strictly confined to the
numerical proliferation of different types of institutionalized oppo-
sition within the family of established democracies, the large major-
ity of which are in fact parliamentary systems of government. While
it is possible to identify some kind of parliamentary opposition in vir-
tually any liberal democracy, there is a considerably larger variety of
different institutional devices for political opposition than has been
8
See for instance Klaus von Beyme, ‘Parliamentary Oppositions in Western
Europe’, in Eva Kolinsky (ed.), Opposition in Western Europe, London, Croom Helm,
1987, pp. 30–47.
9
The volume by Kolinsky (ed.), Opposition in Western Europe, op. cit., offered
in its section ‘concepts of opposition’ assessments by three heavyweights of West
European comparative politics (Klaus von Beyme, Peter Pulzer, and Gordon Smith).
However, the focus of these chapters remained almost exclusively confined to high-
lighting the more recent empirical developments until the mid-1980s. A certain appre-
ciation of the legitimate democratic role of social movements is the only issue raised
in these chapters that could possibly qualify as some kind of ‘conceptual’ innovation.

acknowledged to date in the international literature on contempo-

rary democracies.
This paper is organized around two major topics or issues. First of
all, it makes the case for distinguishing different – but equal – sets
of constitutional devices designed to facilitate and channel legitimate
political opposition to the government. With its concentration on
the constitutional level, the typology of opposition models suggested
here differs markedly from several other approaches that focus more
broadly on different ‘patterns’ of political opposition, which include
the party system alongside a host of other political, social and cul-
tural factors. The much more specific focus provided here is basically
confined to the area that Dahl once described as the institutional
components of the ‘primary conditions’ of political oppositions.10
The next sections offer a brief portrait of what is here being con-
sidered to represent the five key models of institutionalizing politi-
cal opposition at the constitutional level. For each of these models a
‘prototype’ may be found among the consolidated liberal democra-
cies. The five models, and their respective prototypes, include: (1)
parliament-centred opposition with no veto and/or co-governing powers for
the minority parties (United Kingdom), (2) parliament-centred opposition
with strong veto and/or co-governing powers for the minority parties
(Germany), (3) a parliamentary-presidential model of political opposition
(Fifth French Republic), (4) a separation-of-powers model of political
opposition (United States) and (5) a direct-democratic model of opposition
(Switzerland).
Whereas many compilations of case studies still pass as ‘compara-
tive’ studies, the individual country sections presented here do not
claim to develop a comparative perspective, which would make it ne-
cessary to agree on a set of reasonable criteria for comparison. The
specific problems of creating a list of criteria that may be used to eval-
uate different models of opposition have been addressed many years
ago.11 There is, most importantly, an obvious and inevitable trade-
off between those functions aimed at enhancing integration and
inclusiveness, and others focusing on the capacity of democratically
elected majorities to govern effectively. As constitution-makers in
10
Robert A. Dahl, ‘Some Explanations’, in R. Dahl (ed.), Political Oppositions in
Western Democracies, New Haven and London, Yale University Press, 1966, pp. 348–52.
11
Robert A. Dahl, ‘Epilogue’, in Dahl (ed.), Political Oppositions in Western Demo-
cracies, op. cit., pp. 387–8.

different countries have different normative preferences, which are

likely to be reflected at the level of the agreed constitutional arrange-
ments, there is the obvious danger of confronting a model with a set
of ‘unreasonable’ criteria for evaluation.
Therefore, the aim pursued here is rather to sketch out the spe-
cific institutional parameters and the overarching constitutional
doctrine of each model, which will then be evaluated in light of the
respective constitutional practice. A genuinely comparative perspec-
tive will be developed in the second part of this paper. Here the focus
will be more specifically on the potential lessons that constitution-
makers in democratizing countries may draw from the experiences
of some of the major established liberal democracies.
UNITED KINGDOM: PARLIAMENT-CENTRED OPPOSITION WITH

NO VETO AND/OR CO-GOVERNING DEVICES FOR THE
MINORITY PARTIES
No other institutional model of political opposition has acquired a

similarly famous status worldwide as the British model, which to many
continues to represent the most genuine form of institutionalized
political opposition. This may in part be attributed to the very age
of the British model whose origins may be traced back to the first
half of the eighteenth century.12 The key features of the British
model, to be highlighted here, include the parliament-centredness
of the constitutionally provided devices of political opposition and
the highly specific character of opposition instruments within the
parliamentary arena. ‘Parliament-centredness’ in this context is
meant to be understood as the absence of direct democratic devices
of political opposition, i.e., the chance of the minority parties or the
citizens to launch a referendum on governmental decisions.
Arguably the most important, certainly the most well-known
feature of the British model of political opposition is to be seen in
the highly specific concept of an opposition with a capital ‘O’13 –
12
S. A. Foord, His Majesty’s Opposition 1714–1830, Oxford, Oxford University Press,
1964.
13
Allen Potter, ‘Great Britain: Opposition with a Capital “O” ’, in Dahl (ed.),
Political Oppositions in Western Democracies, op. cit., pp. 3–33.

understood to be the largest opposition party in the House of

Commons. The political preconditions of this concept are to be
found at the level of the British two-party system. The concept itself
rests, however, on a whole set of sophisticated rules and conventions
designed to sharpen the organizational profile of ‘Her Majesty’s Offi-
cial Opposition’. This includes in particular the provision of a public
salary for the leader of the Opposition, and the existence of a
‘shadow cabinet’, which since the 1950s has in fact turned into a full-
scale ‘shadow government’.14 What most obviously distinguishes the
major and the many minor opposition parties in the British House
of Commons from their counterparts in most other parliamentary
democracies, though, is their notable lack of any major veto or
co-governing devices. From parliamentary agenda-setting to the
staffing of the standing committees and the majority requirements
for passing bills, the whole legislative process in Britain is very much
‘government-managed’. This has had a strong, almost determinat-
ing, impact on the behavioural logic among the major political
actors. In contrast to the situation in most other parliamentary
systems, the British understanding of parliamentary opposition does
not include the expectation that opposition parties launch inde-
pendent legislative initiatives or struggle to improve the legislative
programme of the government (even if only to prevent the worst of
its feared negative outcomes). Rather, there is the conviction ‘that it
is better to give the government enough rope to hang itself with, and
Oppositions hope that an extravagant administration will be pun-
ished by loss of popularity with the electors’,15 as a seasoned observer
has put it. In fact, both the constitutional doctrine and the British
political culture put a premium on the largest possible degree of
transparency (of the decision-making process) and accountability (of
the party in power). Voters shall be given a clear choice between
the government and the ‘alternative government’, i.e., the official
Opposition. Given this rather specific working character of
government/opposition relations, much of the legitimacy of the
British model has rested on the expectation of regular alternations
of the parties in office.
14
R. M. Punnett, Front-Bench Opposition. The Role of the Leader of the Opposition, the
Shadow Cabinet and Shadow Government in British Politics, London, Heinemann, 1973.
15
Anthony H. Birch, The British System of Government, 8th edn, London and Boston,
Unwin Hyman, 1991, p. 131.

Yet how has this venerable model functioned in constitutional

practice over the past decades, and what are its inherent dangers and
potential weaknesses? As may have been expected, the parliamentary
procedure in the House of Commons has in fact been dominated by
the ‘opposition mode’, a pattern of interaction involving more often
than not conflict between the competing parties.16 Although it is a
myth that all, or even most, bills are fiercely contested by the oppo-
sition,17 there has been a very high degree of transparency in the
legislative process, and a remarkable ability of the electorate to judge
the governing and opposition parties on their actual performances
during a given period of time.
Apart from more specific issues of criticism,18 the party system is
easily identified as a potential ‘Achilles heel’ of the British model of
political opposition. The existence of a workable two-party system –
understood to include two parties that are able to form a single-party
majority government on alternating terms – marks a sine qua non for
the model to work properly. At least two possible party-system related
problems of the British model may be distinguished.
The first one is the possibility of extended periods of one-party
rule. In a system that justifies the almost complete exclusion of the
parliamentary minority from the public policy-making process with
the promise of regular alternations in the office of government, the
existence of a hegemonic party threatens to undermine the system’s
16
Philip Norton, ‘Old Institution, New Institutionalism? Parliament and Govern-
ment in the UK’, in Philip Norton (ed.), Parliaments and Governments in Western Europe,
London, Frank Cass, 1998, pp. 16–43.
17
Dennis Van Mechelen and Richard Rose, Patterns of Parliamentary Legislation,
Aldershot, Gower, 1986, pp. 59–60, found that during the first four post-war decades
of British politics no less than three-quarters of parliamentary bills were passed without
the explicit opposition of the non-governing parties in the House of Commons.
18
For instance, observers have pointed to the negative effects that the institutional
arrangements in place may have on the credibility of opposition politicians who may
feel virtually forced to oppose the government due to the system’s pressure ‘to play
by the rules’, even when they consider a given policy proposal worthy of being sup-
ported. The inherent dangers of radically simplifying issues for the sake of competi-
tion, and the potential decay of constructive political thinking are other aspects of the
British model that have drawn the attention of critics. Compared to earlier decades
these problems have even intensified, as there are now so many issues that cannot
properly be integrated into the traditional logic of two-party politics. See Nevil
Johnson, ‘Opposition in the British Political System’, Government and Opposition, 32: 4
(1997), pp. 509–10.

very democratic legitimacy. Most obviously, extended terms of one

party in office weaken the opposition parties, whose elites may (seem
to) lack the proper experience to lead a government after having
been socialized exclusively on the opposition benches. As more
recent empirical research into the inner workings of the British
majoritarian democracy has revealed, the capacity for major policy
reversals and innovations of newly incoming governments is also sig-
nificantly more limited than most text book accounts of the West-
minster model would acknowledge.19 Particularly, a party that has
been out of office for a decade or even longer, will de facto have to
accept many of its predecessor’s choices. But the possible negative
effects of quasi-one-party rule are not confined to the opposition
parties. There has also been widespread concern among scholars
in countries that have experienced periods of a dominant party
system,20 that very large and virtually unchallenged governing majori-
ties tend to produce bad policies.21
The second party system-related problem of the British opposition
model concerns the possibility of third parties gaining substantial
proportions of the vote, or even seats in parliament. Strong electoral
performances of third parties may undermine the very concept of
an official Opposition being provided with special resources both
inside and outside the parliamentary arena. Whereas there have
been Oppositions in the more recent chapters of British political
history that enjoyed a notably modest lead in votes, if not in seats,
over the numerous ‘oppositions’ in the House of Commons,22 this
has not proved a major problem in Britain itself. Nevertheless, the
rigorous application of the ‘winner-takes-all’ approach at the level
of opposition parties may well develop into a potential source of
19
Richard Rose and Phillip L. Davies, Inheritance in Public Policy. Change without
Choice in Britain, New Haven, Yale University Press, 1994.
20
These include Britain, among other countries with a significantly more impres-
sive record of one-party rule, such as Japan in particular. See Helen Margetts and
Gareth Smyth (eds), Turning Japanese? Britain with a Permanent Party of Government,
London, Lawrence & Wishart, 1994.
21
Anthony King, ‘The Implications of One-Party Government’, in Anthony King
(ed.), Britain at the Polls 1992, Chatham, Chatham House, 1993, pp. 223–48.
22
The primary example remains the 1983–87 parliament, in which the ‘Opposi-
tion’ (Labour) was just 2.2 percentage points ahead of the second largest opposition
party (the Alliance) – a distribution of the vote that was effectively disguised at the
parliamentary level due to the strong distortional effects of the British electoral system.

conflict in countries with a less tolerant and democratically mature

political culture than the British one.23
GERMANY: PARLIAMENT-CENTRED OPPOSITION WITH

STRONG VETO AND/OR CO-GOVERNING DEVICES FOR THE
MINORITY PARTIES
The constitutional arrangements to be found in Germany may be

considered to represent a second basic model of institutionalizing
the opposition principle. Like the British one, the German model is
characterized by a notable ‘parliament-centredness’ of institutional
devices of political opposition. Whereas there is a large arsenal of
direct democratic instruments at sub-national level in Germany, no
such devices can be found at the national level. In stark contrast to
the British case, this emphasis on representative democracy has been
combined, however, with very strong co-determinative powers for
the parliamentary opposition and their supporters throughout the
political system.
To begin with, there are powerful co-governing devices in the par-
liamentary arena itself. These include in particular a close involve-
ment of the minority parties in the parliamentary agenda-setting
process through the Bundestag’s Ältestenrat (‘elderly council’); the
assignment of a significant proportion of chairs in the Bundestag’s
standing committees (whose very structure favours a deliberative and
consensual, rather than an ‘adversarial’ style of government/oppo-
sition relations); and a strong veto-potential of the opposition parties
at parliamentary divisions, as any constitutional amendments (which
are quite numerous in Germany) require a two-thirds majority in
order to be passed by the Bundestag.
Then, there is what many observers consider to be the single most
important ‘weapon’ in the hands of the opposition parties: the very
powerful role of the Bundesrat, the Federal Republic’s ‘second
23
Arguably the most famous case in point, to be found in another established
western democracy, relates to the spectacular 1993 Canadian general election. Then,
the role of the official ‘Opposition’ fell into the hands of the Bloc Québecois, a sep-
aratist newcomer party, which received fewer votes than two of the three other oppo-
sition parties. See Lynda Erickson, ‘The October 1993 Election and the Canadian
Party System’, Party Politics, 1: 1 (1995), pp. 133–43.

chamber’.24 The Bundesrat basically represents the state govern-

ments, rather than a given state’s population. Its members are not
elected, but appointed by the state government, and are in effect the
delegates of the latter. The number of seats a state may have in the
Bundesrat varies according to demographics, but each state has to
cast its vote as a bloc vote. The Bundesrat may veto any bill that has
been passed by the Bundestag, but only some bills (so-called Zustim-
mungsgesetze or ‘approval bills’) require the explicit approval of the
Bundesrat. Today, almost 60 per cent of all bills count as approval
bills. Vetoes on other bills may be overruled by the Bundestag.
However, if the Bundesrat blocks a decision by a two-thirds majority,
the Bundestag has to overturn this veto with an equivalent majority,
even if a bill does not fall into the category of approval bills. More-
over, bills including changes to the constitution invariably require
the support of a two-thirds majority of the Bundesrat.
Finally, a group of at least one-third of the members of the
German Bundestag may challenge any law that they think may con-
flict with the Basic Law before the Constitutional Court. This proce-
dure is called ‘abstract norm control’; it is ‘abstract’ in the sense that
the question of the law’s validity may be purely hypothetical and need
not have arisen in the course of a legal dispute. In practice, most
cases within this category are initiated by the opposition parties.25
Needless to say, this extra-parliamentary opposition instrument has
a strong impact on the parliamentary decision-making process. It
clearly provides the opposition parties in parliament with another
important institutional resource. In fact, the mere threat of blocking
a bill in the Bundesrat or invoking the Constitutional Court usually
24
In a 1974 judgment the German Federal Constitutional Court explicitly
dismissed the idea of referring to the Bundesrat as the second chamber of a split
but integrated legislative assembly. See Entscheidungen des Bundesverfassungsgerichts,
vol. 37, Tübingen, Mohr, 1974, p. 380. Still, in comparative works the Bundesrat has
long been accepted to be very much a second chamber in functional terms. See Klaus
von Beyme, ‘Die Funktionen des Bundesrates. Ein Vergleich mit Zwei-Kammer-
Systemen im Ausland’, in Der Bundesrat (ed.), Der Bundesrat als Verfassungsorgan
und politische Kraft, Bad Honnef and Darmstadt, Neue Darmstädter Verlagsanstalt,
1974, pp. 365–93.
25
Klaus Stüwe, ‘Das Bundesverfassungsgericht als verlängerter Arm der Opposi-
tion? Eine Bilanz seit 1951’, Aus Politik und Zeitgeschichte, B 37–8 (2001), pp. 34–
44.

increases the willingness of governments to seriously consider the

opposition’s stance on a given legislative project.26
Like its British counterpart, the German model has both advan-
tages and disadvantages. Among the most remarkable achievements
of the German model of opposition is the notably high amount of
political and social integration of the opposition forces, which has
been effectively secured even during extended terms of the same
parties in office. A significant proportion of legislative ‘key decisions’
in the past decades emerged from intense negotiations between
government and opposition, and included key components of both
major parties’ programmatic agenda.27 The costs of this approach
to legislative decision-making are almost too obvious to require any
detailed description: what is possibly gained at the level of legislative
‘quality’ and social integration has to be paid for in terms of policy
innovation and, in particular, transparency and accountability. As to
the former, there is ample evidence that the strong veto-powers of
the opposition may very seriously limit the government’s capacity to
act – in fact to a degree which makes the government the hostage of
the opposition. This is especially the case during periods marked
by slim parliamentary majorities and/or severely restricted fiscal
resources, both of which have marked the more recent past in
German politics.28
The costs in terms of transparency and accountability are by no
means less significant. Barely any bills emerge from an open show-
down between the two legislative chambers. Much more typical are
bills that have been carefully redrafted behind closed doors. The most
important body for such negotiations to take place is the Vermitt-
lungsausschuß (‘mediation committee’) – a body specifically designed
to prevent, or overcome, legislative gridlock between the Bundestag
and the Bundesrat. In fact, the Bundesrat may only veto a bill after it
26
Christine Landfried, Bundesverfassungsgericht und Gesetzgeber: Wirkungen der Ver-
fassungsrechtsprechung auf parlamentarische Willensbildung und soziale Realität, Baden-
Baden, Nomos, 1984.
27
Klaus von Beyme, The Legislator: German Parliament as a Centre of Political Decision-
Making, Aldershot, Ashgate, 1998.
28
Ludger Helms, ‘Deutschlands semi-souveräner Staat: Kontinuität und Wandel
parlamentarischer Regierung in der Bundesrepublik’, Aus Politik und Zeitgeschichte, B
43 (2003), pp. 3–8.

has been dealt with by the mediation committee.29 Over the past
decades the mediation committee has been used rather frequently,
with about 90 per cent of all cases being initiated by the Bundesrat. Its
proposals are usually accepted by the Bundestag and Bundesrat. On
average only 10 per cent of all proposals fail to secure the final support
of the two legislative assemblies.30
Much of the unique character of German politics, and of the
German model of political opposition in particular, is owed to the
rare combination of parliamentary/party government and federal-
ism. As early as in the mid-1970s, Gerhard Lehmbruch identified
at the centre of the German polity what he then thought marked a
structural tension between two fundamentally different decision-
making logics, namely between a competitive one usually associated
with party government in parliamentary democracies, and a con-
sociational one considered typical of decision-making in federal
systems.31 Even though unification has altered the institutional and
social parameters of federalism in Germany,32 the political process at
the federal level continues to be shaped by party and regional factors.
Not only have the parties left their mark on the Bundesrat, but the
existence of a fully-fledged federal system has also had an important
effect on the parties. Underscoring the independent impact of the
parliamentary form of government, the effects of the federal system
on the parties have not been those that David Truman attributed to
29
Unlike their American or Swiss counterparts, the now 32 members of
the German mediation committee are not identical to the actors that have been
involved with the matter in question before. Rather, they are specifically chosen in
equal numbers by the Bundestag and the state governments, and many of them
serve for the whole legislative period. They are free to agree on any conceivable
compromise.
30
Peter Schindler, Datenhandbuch zur Geschichte des Deutschen Bundestages 1949 bis
1999, Baden-Baden, Nomos, 1999, pp. 2450–1.
31
Gerhard Lehmbruch, Parteienwettbewerb im Bundesstaat, Stuttgart, Kohlhammer,
1976.
32
Roland Sturm, ‘Party Competition and the Federal System: The Lehmbruch
Hypothesis Revisited’, in Charlie Jeffery (ed.), Recasting German Federalism,
London, Pinter, 1999, pp. 197–216. The two key developments to be highlighted
here relate to the dramatically widened gap between the wealthier and the poorer
(mostly eastern) states, and the significantly greater variation of different coalition for-
mulas at state level. Both of these developments have made it more difficult for the
opposition parties in the Bundestag to keep ranks with ‘their’ state governments
closed.

them many years ago in the American context.33 Rather, the strongly
power-sharing features of the German decision-making system
have been highly effective in moving the major parties to the centre
ground, thereby providing the basis for policy-compromises in the
legislative process. There are few better examples in West European
party history of the capability of constitutional structures to shape
the strategic choices of political actors than the programmatic
transformation of the German Social Democrats at their famous
Godesberg conference in 1959.34
FRANCE: THE PARLIAMENTARY-PRESIDENTIAL MODEL OF

POLITICAL OPPOSITION
The peculiar character of the parliamentary-presidential model of

opposition, our third model, springs directly from the institutional
structure of the so-called ‘semi-presidential’ systems of government.
Semi-presidential systems are marked by a combination of the prin-
ciple of parliamentary responsibility of the government (which
characterizes the parliamentary democracies) and a directly elected
president enjoying significant powers of office. If there is a prototype
of semi-presidential democracy among the contemporary advanced
democracies it is certainly France, if only because the creator of
the term, Maurice Duverger, developed his conception of semi-
presidentialism in the French context.35 Another reason is that,
unlike some other contemporary West European countries that
possess the formal attributes of a ‘semi-presidential’ governmental
33
Truman contended that the relative absence of strong disciplined parties in
the American political system was mainly produced by the federal system. See
David Truman, ‘Federalism and the Party System’, in Arthur W. Macmahon (ed.),
Federalism: Mature and Emergent, Garden City, NY, Doubleday, 1955, pp. 115–36.
34
Manfred G. Schmidt, ‘The Parties-Do-Matter-Hypothesis and the Case of the
Federal Republic of Germany’, German Politics, 4: 3 (1995), p. 10. The SPD’s trans-
formation into a moderate ‘people’s party’ took place against the background of a
series of disappointing electoral performances of the party, and on the basis of a
growing conviction that a staunchly ‘adversarial’ style of opposition would no longer
work in a strongly power-sharing institutional environment.
35
Maurice Duverger, ‘A New Political System Model: Semi-Presidential Govern-
ment’, European Journal of Political Research, 8: 2 (1980), pp. 165–87.

system, France has actually experienced recurrent manifestations of

presidential power.36
The complex institutional structure of semi-presidential systems
leaves much room for competing conceptions of political opposition,
especially during times of split party control of parliament and the
government on the one hand and the office of president on the
other (which the French call cohabitation). As Alain Peyrefitte has
pointed out, the only interpretation of cohabitation acceptable to the
founder of the Fifth French Republic and its first president, General
Charles de Gaulle, was a ‘cohabitation americaine’, in which a coherent
executive (including the president, and the prime minister and his
cabinet) would face a largely independent and potentially opposing
National Assembly.37
Of course, neither constitutional theory nor constitutional prac-
tice in France have built on this idea. There is now an unchallenged
consensus that the minority parties in the National Assembly, rather
than the legislature as a whole, represent the key opposition actor.
What distinguishes the parliamentary-presidential model of op-
position from the British or the German model is the fact that –
during times of split party control of parliament, government and
the presidency – the opposition function is performed by the par-
liamentary minority and the president.38 This notwithstanding, the
basic logic of parliamentary government remains in force both
during periods of ‘unified government’ and cohabitation. The latter
feature distinguishes the semi-presidential type of government from
36
For a comparative assessment of the semi-presidential type of liberal democracy
see Robert Elgie (ed.), Semi-Presidentialism in Europe, Oxford, Oxford University Press,
1999.
37
Alain Peyrefitte, ‘Les trois cohabitations’, Pouvoirs, 91 (1999), pp. 28–9.
38
If the focus is less on the potential tension between representatives from dif-
ferent parties in the offices of president and prime minister, and more on the com-
petition between offices and their holders, it could be argued that the president
represents an opposition actor restricting the room for manoeuvre of the prime min-
ister and his government even, and especially, during times of ‘unified government’.
Whereas the character of the president as a potential opposition actor is much more
obvious during times of cohabitation, his resources are considerably more limited than
during times of unified government. This line of reasoning has, however, played no
role in the French literature on the Fifth Republic, which can be explained by the
prevailing notions of the president as the ‘chief executive’ in the French political
system.

the American separation-of-powers system to be discussed in the

next section.39
In a forceful attempt to install a system which would enable the
government to govern even in the absence of stable parliamentary
majorities, the founding fathers of the Fifth French Republic dimin-
ished the role of parliament in the political system to the largest
possible extent. The French type of parlementarisme rationalisé even
minimizes the room for manoeuvre of the parliamentary majority
towards ‘its’ government; it leaves precious little room for an influ-
ential parliamentary opposition.40 There is neither a permanent
involvement of the opposition parties in the parliamentary agenda-
setting process, such as in Germany, nor any kind of compensation
in the form of ‘opposition days’, as in Britain. Very much like in the
British House of Commons, the members of the minority parties
even lack the right to initiate most types of legislation. There are also
few serious qualified majority requirements to pass particular impor-
tant bills, which would provide strong parliamentary minorities in
the National Assembly with a veto or co-governing potential. Also the
veto power of the French Senate has more in common with that
one of the British House of Lords than with that of the German
Bundesrat. Most commentators consider the right of 60 deputies or
senators to challenge a planned legislative measure by invoking the
Conseil constitutionnel as the only serious weapon of a qualified par-
liamentary minority.41
As to the constitutional veto-powers of the president, the follow-
ing devices would appear to be particularly worth highlighting. By
far the most important constitutional ‘weapon’ against a parliamen-
39
This is why in the more recent literature many authors prefer to describe the
Fifth French Republic and other ‘semi-presidential’ democracies as ‘parliamentary
systems with presidential dominance’. See for instance Alan Siaroff, ‘Comparative
Presidencies: The Inadequacy of the Presidential, Semi-Presidential and Parliamen-
tary Distinction’, European Journal of Political Research, 42: 3 (2003), p. 307.
40
John D. Huber, Rationalizing Parliament. Legislative Institutions and Party Politics
in France, Cambridge, Cambridge University Press, 1996.
41
Xavier Vandendriessche, ‘Le parlement entre déclin et modernité’, Pouvoirs, 99
(2001), p. 66. The character of this device as a genuine opposition instrument is
underlined by the frequency with which the Conseil is invoked by the opposition
parties. Between 1974, when this procedure was introduced, and 2000 no less than
96.2 per cent of all cases initiated by the parliament were triggered by the opposition
parties. See Wolfram Vogel, Demokratie und Verfassung in der V. Republik. Frankreichs Weg
zur Verfassungsstaatlichkeit, Opladen, Leske + Budrich, 2001, pp. 169–75.

tary majority is the president’s right to dissolve the National Assem-

bly (which can be, however, applied only once a year). Secondly, the
president can require that a bill he considers to be unconstitutional
be scrutinized by the Conseil constitutionnel. The president may,
thirdly, refuse to promulgate any bill and may instead send it back
to parliament for further deliberation. By contrast, the emergency
powers (set out in Article 16 of the French Constitution) cannot be
properly considered as ‘normal’ oppositional devices.42 The presi-
dent’s ‘right’ not to sign a government decree, which then has to be
passed as a bill, is widely considered to form part of the institutional
opportunity structure of minority presidents. There is, however, no
written constitutional provision to this effect; President Mitterrand
set a precedent in 1986 which has since been regarded as a consti-
tutional convention.43
There are serious problems with the parliamentary-presidential
model of opposition both during periods of ‘unified government’
and cohabitation. During periods of undivided control of the parlia-
ment, the government and the presidency, many structural features
and problems look pretty similar to those in the British system.44
However, exactly because most components of the institutional op-
portunity structure of the French parliamentary opposition bear
much resemblance to the British model, the basic differences
between the two models stand out sharply in a direct comparison.
There is, first of all, no symbolic up-grading of the largest opposition
party in the French National Assembly by granting it anything similar
to the title of an ‘official Opposition’. Moreover, even one of the most
basic preconditions of the British Westminster model, namely the
42
They were used just once in 1961, and the criticism that followed was apt to
underline their exceptional character. See Maurice Duverger, Le système politique
français. Droit constitutionnel et science politique, 21st edn, Paris, Presses universitaires de
France, 1996, p. 517.
43
David S. Bell, Presidential Power in Fifth Republic France, Oxford, Berg, 2000,
pp. 179–80.
44
This would appear to include not only the powerlessness of the parliamentary
opposition but also the policy-related performances of governments in the Fifth
French Republic. See John T. S. Keeler, ‘Executive Power and Policy-Making Patterns
in France: Gauging the Impact of the Fifth Republic Institutions’, West European
Politics, 16: 4 (1993), pp. 518–44; Arend Lijphart, ‘Reply to Lane and Ersson, French
Politics: The Virtues of Majoritarian Democracy. Majoritarianism and Democratic
Performance in the Fifth Republic’, French Politics, 1: 2 (2003), pp. 225–32.

tradition of considering parliament as the centre of the political

system (which is, admittedly, on the wane even in Britain), has never
been part of the general self-perception of the Fifth French Repub-
lic.45 This rather weak position of the parliamentary opposition, both
in normative and empirical terms, structurally increases the danger
of dissenting minorities resorting to extra-parliamentary forms of
opposition, which have been part and parcel of more recent French
political history.46
Although the opposition function is formally strengthened during
periods of cohabitation, as then both the parliamentary minority and
the president represent the opposition, serious problems persist.
First of all, what is gained in terms of the overall number of actors
representing (potentially) opposing views to the policies and politics
of the government, is likely to be lost by the lack of coherence in par-
liamentary and presidential oppositions. There is scant empirical
evidence from the first three French cohabitations (1986–88, 1993–95
and 1997–2002) suggesting that there has ever been a major effort
to coordinate systematically parliamentary and presidential strategies
of opposition.47 During the first cohabitation – of President Mitterrand
and Prime Minister Chirac – the president remained very much on
the top of the French decision-making pyramid,48 which structurally
limited the chances for any sort of coordinated parliamentary-
presidential opposition. During the second and the third cohabita-
tions, the relationship between the president and his party was
notably strained both for political and personality-related reasons,
which again had a negative effect on developing a joint opposition
strategy. There are, however, also important systemic reasons which
make it rather unlikely that the parliamentary opposition and the
45
There have however been signs of a modest increase in the public reputation
of the French parliament more recently. See Franco Rizzuto, ‘France: Something of a
Rehabilitation’, Parliamentary Affairs, 50: 3 (1997), pp. 373–9.
46
This may, however, not be explained by institutional factors alone. See Alfred
Grosser, ‘Nothing But Opposition’, in Dahl (ed.), Political Oppositions in Western
Democracies, op. cit., pp. 284–302.
47
Peyrefitte, ‘Les trois cohabitations’, op. cit.; Bell, Presidential Power in Fifth Repub-
lic France, op. cit., pp. 175–96; Robert Elgie, ‘La cohabitation de longue durée: studying
the 1997–2002 experience’, Modern and Contemporary France, 10: 3 (2002), pp. 297–311.
48
Apart from this occasion marking a historical precedence, Mitterrand profited
significantly from his huge public popularity and the rather shaky conservative gov-
ernment majority, which did not even unanimously accept Chirac as its leader.

president, even when representing the same party colours, will actu-
ally pursue closely coordinated strategies of opposition. The high
prestige of the office and the functional requirements of the semi-
presidential system do not allow a minority president to confine his
political self-perception and behaviour to those of an opposition
leader. Whereas the parliamentary opposition may, and usually does,
concentrate their energy on criticizing the government’s political
and policy performance, the president generally has to develop a
much more cooperative approach to dealing with the government.
This task has usually been eased by the great respect with which the
prime minister and other members of the governing elite tend to
treat the president. In fact, as most cohabitation premiers more or
less openly aspired to advance from the position of head of govern-
ment to the presidency, not undermining the powers of the president
often appeared as a well-calculated strategy rather than an exercise
in political self-restraint.
In the eyes of most French political scientists, the core problem
with cohabitation is the increasing amount of ‘opaqueness’ of the
French political system during periods of split party control, which
has been considered to have negative side effects on the system’s
overall legitimacy.49 The (over-)complexity of the semi-presidential
system during periods of cohabitation has also been reflected in the
notable hesitation of leading scholars of French politics to define the
normative and empirical role of the president in the French politi-
cal system.50 Yet, certainly more important, also many French voters
would seem to have voiced their frustration with cohabitation when
they provided Jacques Chirac with the worst ever result of a re-
election-seeking president in the first round of the 2002 presidential
election, and forced then Prime Minister Lionel Jospin and con-
tender for the presidency to drop out of the race.51 The reduction
49
Daniel Bourmaud, ‘Les Ves Républiques. Monarchie, dyarchie, polyarchie:
variations autour du pouvoir sous la Ve République’, Pouvoirs, 99 (2001), p. 16.
50
See Hugues Portelli, ‘Arbitre ou chef de l’opposition?’, Pouvoirs, 91 (1999),
pp. 59–70.
51
The French electoral laws stipulate a run-off election between the two strongest
contenders of the first round. In the first round, held on 21 April 2002, Jospin came
just third, trailing behind right-wing extremist Jean-Marie Le Pen and President
Jacques Chirac. The second round produced an overwhelming victory for President
Chirac. See Jean-Luc Parodi, ‘L’énigme de la cohabitation, ou les effects pervers d’une
pré-sélection annoncée’, Revue française de science politique, 52: 5–6 (2002), pp. 483–504.

of the length of the president’s term from seven to five years, as

adopted in 2001, structurally reduces the likelihood of future periods
of cohabitation, without completely precluding their resurgence.
However, even the future absence of cohabitation would help over-
come only part of the described difficulties of the French model of
political opposition.
UNITED STATES: THE SEPARATION-OF-POWERS MODEL OF

There are particular problems in discussing the phenomenon of

legitimate political opposition in the United States. Political opposi-
tion in the American political system is in fact ‘ubiquitous’, as Nelson
Polsby has stated.52 This is even true if one confines an assessment to
the level of constitutionally provisioned forms of political opposition
that are at the centre of this article. Most observers accustomed to
studying the political process in parliamentary democracies tend to
consider the relationship between Congress and the president in the
American separation-of-powers system as the neat equivalent to the
government/opposition divide in parliamentary systems of govern-
ment. While such a comparison is not completely mistaken, it is at
best a simplistic one, which underestimates the manifold and often
ambivalent dimensions of the relationship between the president
and the legislature. From a strictly constitutional perspective the
president, rather than Congress, would appear to be the ‘natural’
veto actor in the American political system. This is at least what the
constitutional restrictions regarding the president’s right to formally
initiate legislation, and the existence of the presidential veto in par-
ticular, would seem to suggest. However, the history of presidential
leadership, at least since the 1930s, with the institutionalization of
a ‘legislative presidency’ and the emergence of ever more sophisti-
cated forms of presidential public leadership, has significantly
altered the initial constitutional conception of the presidential or
‘separated system’.53 As also the public expectations towards the pres-
52
Nelson Polsby, ‘Political Opposition in the United States’, Government and
Opposition, 32: 4 (1997), p. 511.
53
Charles O. Jones, The Presidency in a Separated System, Washington, DC,
Brookings Institution Press, 1994.

idency have followed this direction, it is now common to consider

Congress as the most important actor of institutionalized political
opposition in the contemporary American political system.54 Still, in
our context both Congress and the presidency – in their roles as
opposition players – shall be looked at briefly.
The president may veto a bill for any reason. A presidential veto,
which has to be applied within ten days from the presentation of a
bill, may be overridden by a two-thirds majority (of members being
present) in both the Senate and the House. No amendments are
allowed to a vetoed bill and all congressional votes on vetoed bills
have to be recorded.55
How have presidents used this veto-power in practice? In contrast
to very early holders of the presidency, all modern presidents have
considered the veto a legitimate weapon in the political confronta-
tion with Congress.56 Another important difference to the early
history of the presidential veto relates to the reactions of Congress.
In contrast to the late nineteenth century, it is now a rare occurrence
that Congress overturns a presidential veto. This holds true even for
periods of ‘divided government’ (i.e., split party control of Congress
and the office of president). Of the 37 vetoes President Clinton
launched between 1995 and 2000 only two were overruled.57
Many recent works on the presidential veto have focused especially
on the conditions under which presidents threaten to use their veto –
a strategic option which has come to be considered as a powerful
resource in its own right. According to a recent statistical survey, pres-
idents are most likely to threaten a veto if a decision is considered
highly relevant by the public, or is part of a chain of decisions that
54
See David R. Mayhew, Congressional Opposition to the American Presidency: an Inau-
gural Lecture Delivered before the University of Oxford on 27 November 2000, Oxford, Oxford
University Press, 2001.
55
A different procedure applies to the so-called ‘pocket veto’ which allows the
president to prevent a bill, passed within ten days of adjournment of a session, from
becoming law by simply not signing it. In contrast to such cases involving the ‘normal’
presidential veto, Congress cannot override a ‘pocket veto’. The bill must be reintro-
duced when Congress comes back into session and passed anew for it to be recon-
sidered.
56
Richard A. Watson, Presidential Vetoes and Public Policy, Lawrence, University Press
of Kansas, 1993.
57
Victoria Allred, ‘Versatility with the Veto’, Congressional Quarterly Weekly Report,
19 January 2001, p. 177.

have been vetoed.58 The overall effects of veto threats in terms of

congressional concessions to the president have long been thought
to be rather modest, especially during periods of divided govern-
ment. More recent empirical research suggests, though, that even
during ‘divided government’ veto threats can often be remarkably
effective in wresting concessions from Congress.59
The dominant public perspective on constitutionalized forms of
political opposition in the American political system has, however,
been on congressional opposition to the presidency, rather than on
manifestations of presidential opposition to Congress. The weapons
of Congress towards the president and his administration are mani-
fold. They include its strong powers in the legislative arena, the
overview function of its powerful committees as well as the Senate’s
important scrutiny function in the field of presidential nomina-
tions.60 Even the impeachment of the president, although constitu-
tionally designed as a judicial instrument, has been judged as ‘a
legitimate expression of political opposition’.61
The separation-of-powers system has long been hailed both for its
safeguards against autocratic and undemocratic leadership and its
capacity for facilitating compromise. There are, however, several
potential problems with this model of political opposition, some
of which have figured prominently in the more recent past of
American politics. The first one is the possibility of ‘divided govern-
ment’. Since 1945 about two-thirds of the total period have seen
various constellations of ‘divided government’. Whereas, in parlia-
58
Rebecca E. Deen and Laura W. Arnold, ‘Veto Threats as a Policy Tool: When to
Threaten?’, Presidential Studies Quarterly, 32: 1 (2002), pp. 30–45.
59
Charles M. Cameron, Presidents and the Politics of Negative Power, Cambridge,
Cambridge University Press, 2000, pp. 178–98.
60
The most up-to-date overview on the various devices mentioned can be found
in Roger H. Davidson and Walter J. Oleszek, Congress and Its Members, 9th edn,
Washington, DC, Congressional Quarterly Press, 2004. More recently, especially, the
senatorial process of scrutiny has come to be considered a matter of concern in
terms of the very significant time costs of the procedure. See on this G. Calvin
Mackenzie (ed.), special issue of The Brookings Review, 19: 2 (2001).
61
Polsby, ‘Political Opposition in the United States’, op. cit., p. 513. As the more
recent experience suggests, there is in fact a very strong political element in the deci-
sion of Congress to impeach the president. In a survey, published at the height of the
impeachment of President Clinton, no less than 78 per cent of American citizens felt
that this impeachment was more about politics than about the investigation of possi-
ble crimes. See National Journal, 20 February 1999, p. 501.

mentary democracies, highly coherent and integrated political parties

are the key representatives of political opposition in the parliamentary
arena and beyond, political parties in separation-of-powers systems
introduce an element of distortion. Rather than invigorating the con-
stitutionally provided model of political opposition, the existence of
political parties (which were not foreseen by the American framers
some 200 years ago) significantly modifies, if not undermines, the
extisting constitutional construction. As Nelson Polsby remarked in
the mid-1990s, ‘it is nearly impossible to identify a clear-cut opposition
because for two-thirds of the period the national government was split
between the two major parties’.62 There can be no doubt that split
party control of the executive and the legislative branches has made
the American system significantly less transparent and even harder to
understand than the framers’ original constitutional construction.
Leading scholars of the advanced democracies, such as Anthony King,
have identified this as a major reason for the extreme amount of dis-
trust among the American public towards their political institutions
and the country’s political elite.63
The negative effects of ‘divided government’ may be – and have
been – compounded by the growing ‘party politicization’ of Con-
gress, to be understood here as an increase in ideological coherence
of the two congressional parties and enhanced ‘party discipline’ at
divisions.64 While the degree of ‘party government’, in terms of sta-
tistically recorded ‘party unity votes’, has slightly declined since its
peak in the mid-1990s, the congressional atmosphere in the very
early twenty-first century has been even more aggressively partisan
than during earlier periods.65 As empirical assessments of the leg-
islative process reveal, the intensified degree of party politicization
has considerably increased the latent gridlock potential of divided
party control of the two governmental branches: Whereas there
have been few legislative sessions experiencing a real stalemate situa-
tion, presidents do oppose significant legislation more often under
62
Polsby, ‘Political Opposition in the United States’, op. cit., pp. 519–20.
63
Anthony King, ‘Distrust of Government: Explaining American Exceptionalism’,
in Susan J. Pharr and Robert D. Putnam (eds), Disaffected Democracies. What’s Troubling
the Trilateral Countries?, Princeton, Princeton University Press, 2000, pp. 91–5.
64
For figures on the development of partisan voting by chamber since the mid-
1950s see Congressional Quarterly Weekly Report, 14 December 2002, pp. 3281–2.
65
See Eric Schickler, ‘Congress’, in Gillian Peele et al. (eds), Developments in
American Politics 4, London, Macmillan, 2002, p. 108.

‘divided government’, and much more important legislation fails

to pass under split party government.66 Secondly, the combination of
‘divided government’ and party government has the potential effect
of significantly weakening the position of ‘minority presidents’ in the
decision-making arena.67 This became very clear during the first term
of the Clinton presidency, especially if an assessment is being made on
the basis of statistical scores measuring the presidential success rate in
the legislative arena.68 While Clinton achieved an outstanding score of
86.4 per cent support in roll calls in 1993 and 1994, his success rate
dropped sharply to just over 36 per cent the following year after
Congress had been taken over by a huge and aggressively acting
Republican majority. However, the almost identically high scores that
President George W. Bush secured under the conditions of ‘unified
government’ during the first half of 2001 and ‘divided government’ in
2002 (87 and 87.8 per cent respectively) may be seen as a reminder
that the patterns of party control mark just one key factor among many
others that shape the legislative process – even though the actual
legislative accomplishments of the Bush White House were less
impressive than the administration’s statistical record suggests.69
66
George C. Edwards III et al., ‘The Legislative Impact of Divided Government’,
American Journal of Political Science, 41: 2 (1997), pp. 545–63. As more recent research
has found, it also matters in terms of legislative outcomes as to whether just one or
both legislative chambers are being controlled by what may be described from the
president’s view as the ‘opposition party’. See Sarah A. Binder, ‘The Dynamics
of Legislative Gridlock, 1947–96’, American Political Science Review, 93: 3 (1999),
pp. 519–33.
67
Richard Fleisher and Jon R. Bond, ‘The President in a More Partisan
Legislative Arena’, Political Research Quarterly, 49: 4 (1996), pp. 729–48; Douglas
W. Jaenicke, ‘Congressional Partisanship and Presidential Success: The Case of the
Clinton and Bush Presidencies’, Politics, 18: 3 (1998), pp. 141–9.
68
Respective figures are annually calculated and published by Congressional Quar-
terly Weekly Report. It should be noted, however, that scores measure only the propor-
tion of bills which the president supported publicly; they do not account specifically
for the proportion of legislative measures being actually initiated by the president.
The statistical approach to assessing presidential performance in the legislative arena
also does not distinguish between the relevance of individual measures passed by
Congress.
69
Many of the legislative measures that Bush supported explicitly in public were
among those that had been initiated by Congress rather than by himself. Moreover,
the number of floor votes on which Bush took a clear position was very small, espe-
cially in 2002. See John Cochran, ‘Bush Readies Strategies for Legislative Success in
2003’, Congressional Quarterly Weekly Report, 14 December 2002, pp. 3235–58.

This weakening of the presidency in the legislative arena – which

has characterized much of the past decades of American political
history,70 but marks at the same time a more general possibility in
separation-of-powers systems – has, however, far-reaching conse-
quences. To the extent one considers the legislative branch as the
single most important opposition actor, one may only conclude that,
during times of ‘divided government’, the opposition finds itself in
a considerably stronger position than the president. While this would
have delighted some factions at the Philadelphia Convention, such
a constellation holds the danger of significantly widening the struc-
tural gap between public expectations towards the president and
what presidents may actually achieve.71 This, again, must be consid-
ered a major source of democratic discontent with the overall per-
formance of the separated system.
SWITZERLAND: THE DIRECT DEMOCRATIC MODEL OF

Whereas each of the five opposition models discussed in this article

is unique, many would still consider Switzerland a special case. With
most of the typical manifestations of political opposition being
absent, there is a widely shared belief even among leading scholars
of the advanced democracies that there is no such thing as opposi-
tion in the Swiss political system. While it is easy to show that this
position is untenable, the Swiss direct democratic model of opposi-
tion has in fact managed to transform the bulk of social conflicts,
which otherwise would become ‘loud’ opposition, into an integrated
or ‘built-in’ form of opposition.
Direct democratic instruments – which have to date rarely been
identified as genuine devices of political opposition – are at the very
centre of the Swiss political system, which combines individual
aspects of parliamentary and presidential government into a highly
70
As the dean of modern presidential studies has argued, the weakness of the con-
temporary presidency is by no means confined to the legislative arena. See Richard
E. Neustadt, ‘The Weakening White House’, British Journal of Political Science, 31: 1
(2001), pp. 1–11.
71
Richard W. Waterman et al., ‘The Expectations Gap Thesis: Public Attitudes
toward an Incumbent President’, Journal of Politics, 61: 4 (1999), pp. 944–66.

specific collegial form of constitutional government.72 There is a long

list of different direct democratic devices in Switzerland, in fact one
of the most extensive ones to be found in the western world.73 Not
all of these devices can, however, be equally considered as genuine
opposition instruments. The key instrument of direct democratic
opposition in Switzerland can be seen in the optional referendum.
Introduced as early as 1874, it enables the Swiss citizens to prevent
any bill passed by parliament from becoming law. To initiate a ref-
erendum, 50,000 signatures or the support of eight cantons (states),
to be collected within 90 days, are required. A bill will only be
enforced if it secures the support of a majority of the citizens taking
part in the vote.
Historically, referendums were the institutional driving force
behind the gradual co-optation of the major opposition parties into
a dramatically oversized coalition government, which has become as
much a hallmark of Swiss democracy as the direct democratic instru-
ments themselves. Groups that had the proven capacity to thwart the
government’s aims by mobilizing public opposition against a pro-
jected measure were invited to join the Federal Council (the Swiss
federal executive).74 Since 1959 the same four parties have controlled
the executive, and in fact not even the number of seats held by each
party in the Federal Council, has ever changed since.75 The parlia-
mentary basis of these governments has exceeded 80 per cent of the
parliamentary seats in the National Council (Switzerland’s first leg-
islative chamber), and has been even larger in the upper chamber.
72
Whereas the indirect election of the federal executive (consisting of seven
members) by both chambers of the Swiss parliament, and its right to formally initiate
federal legislation are reminiscient of the parliamentary form of government, the
fixed term of the executive and its inability to dissolve the legislature have more in
common with the basic features of presidential government.
73
For an overview see Wolf Linder, ‘Direkte Demokratie’, in Ulrich Klöti et al.
(eds), Handbuch der Schweizer Politik, Zürich, Verlag Neue Zürcher Zeitung, 1999,
pp. 109–30.
74
Historically, the Liberals were the only governing party. In 1891 the Catholic
branch of the then conservative opposition was co-opted into the government; the
Swiss People’s Party followed in 1929. The Social Democrats, finally, joined the
government for the first time in 1943.
75
Leonhard Neidhart, Die politische Schweiz. Fundamente und Institutionen, Zürich,
Verlag Neue Züricher Zeitung, 2002, pp. 343–51. Since 1959, with the exception of
the Swiss People’s Party which has held just one seat, all other governing parties have
controlled two seats in the federal executive.

The formal integration of potential veto-players that has marked

the Swiss government-building process has been accompanied by
more informal efforts to collude as many potential opposition forces
as possible into an ad hoc coalition to carry a given measure. It is a
well-established practice not only among the numerous smaller Swiss
opposition parties, but also and even more so among the governing
parties, to use the referendum threat as a strategic device to achieve
their policy goals. In a survey carried out in the early 1990s, 63 per
cent of all responding members of the governing parties in the Swiss
federal parliament declared that they would resort to the referen-
dum threat if a bill they opposed was about to be passed. Among the
Social Democrats even 100 per cent admitted to have this inclina-
tion.76 Thus, negotiations are usually carried on as long as a viable
compromise is reached. Almost only when these often lengthy nego-
tiations fail, are optional referendums likely to be launched. This is
why some observers have maintained that, in terms of policy, the
most successful referendums are those that are not called at all.77
The correlation between the size of a parliamentary majority sup-
porting a given bill and the likelihood that a referendum will be
launched is quite strong. If parliamentary support for a given bill
exceeds a two-thirds majority, the probability that a referendum
will be launched drops to below 50 per cent.78 Interestingly, as
Alexander Trechsel and Pascal Sciarini found, there has been virtu-
ally no correlation between the size of a parliamentary majority
supporting a given bill and the result of a referendum, though.
According to the authors, there is a ‘consistency deficit’ at the level
of the political elites. After a referendum has been called, the
painstakingly negotiated elite compromise usually falls apart – a
process to be facilitated by the lengthy two-tier process of launching
a referendum.79 In the run-up to a referendum the battle lines
between the four governing parties and the many minor opposition
76
Kris W. Kobach, The Referendum: Direct Democracy in Switzerland, Aldershot,
Dartmouth, 1993, p. 161.
77
Yannis Papadopoulos, ‘How Does Direct Democracy Matter? The Impact of
Referendum Votes on Politics and Policy-Making’, in Jan-Erik Lane (ed.), The Swiss
Labyrinth. Institutions, Outcomes and Redesign, London, Cass, 2001, p. 49.
78
Alexander H. Trechsel and Pascal Sciarini, ‘Direct Democracy in Switzerland:
Do Elites Matter?’, European Journal of Political Research, 33: 1 (1998), p. 110.
79
Ibid., p. 118.

parties usually get blurred. As statistical analysis confirms,

commonly agreed recommendations of all the governing parties
as to how to vote in a referendum mark an exception rather than
the rule.80
While the virtual absence of much aggressive, or even violent,
opposition and a respectable record of public policies mark, in fact,
significant achievements, the direct democratic opposition model
has its price. There are not just the exceptionally high time-costs of
the Swiss style of public policy-making. Despite the manifold devices
encouraging the citizens to articulate dissent, the system does not
offer the voters a chance to hold individual actors responsible. More
specifically, voters cannot dismiss the whole programme of the gov-
ernment and oust the latter from office. As the more recent experi-
ence with Swiss democracy suggests, even major electoral upheavals,
such as in 1999, do not necessarily lead to changes in the partisan
composition of the government. In the 1999 parliamentary election,
the conservative-populist Swiss People’s Party managed to turn itself
from the smallest governing party into the strongest party in the
National Council by increasing its share of the vote by 7.6 percent-
age points (the largest gain from one election to another of any Swiss
party in 70 years).81 Nonetheless, not only the partisan composition
of the government, but also the distribution of the seven seats in the
federal executive among the four governing parties remained com-
pletely unchanged.
No less importantly, many scholars contend that – in stark con-
trast to the official constitutional doctrine – it is neither the citizens
nor the political parties but the major interest groups that stand out
as the single most powerful and influential group of actors govern-
ing the Swiss referendum democracy. In fact, the process that many
studies of the actual functioning of referendums in the democratic
process describe looks very much like an exemplification of the
classic theories in political economy from Anthony Downs to Mancur
80
Ludger Helms, Politische Opposition. Theorie und Praxis in westlichen Regierungssys-
temen, Opladen, Leske + Budrich, 2002, p. 175.
81
The background of this spectacular election result, and the lengthy arguments
in the aftermath of the election, was provided by the highly aggressive and disturbingly
right-wing populist campaign propaganda of the People’s Party. See Wolf Linder and
Georg Lutz, ‘The Parliamentary Elections in Switzerland, October 1999’, Electoral
Studies, 21: 1 (2002), pp. 128–34.

Olson.82 Given the requirement to present at least 50,000 signatures

within 90 days after the parliamentary decision on a given bill, and
the dominant logic of collective action in the liberal democracies, it
has proved more than likely that well-organized, financially powerful
and highly specialized interest groups manage to use the referendum
option to their advantage.
LESSONS FROM THE ADVANCED DEMOCRACIES
Each opposition model discussed in this article has its own charac-
ter, and its own strengths and weaknesses. Moreover, as should have
become clear also, there are numerous social, political and cultural
variables that have a strong impact on the actual working of the
respective constitutional devices. Constitution-makers around the
world are well advised to take duly into account the specific condi-
tions prevailing in a given country at a given point in time. This is
not to say, however, that the study of different forms of institutional
solutions to a fundamental problem of liberal democracy, such as the
institutionalization of political opposition, is just of academic or the-
oretical value. The comparative study of different models of political
opposition has to offer some insights that may be linked to the
history of constitution-making as well as to the literature on the pros
and cons of different basic models of constitutional democracy.
The history of constitution-making suggests that there are some
forms of constitutional democracy that, for all their undisputable
accomplishments, are less suitable to serve as a model to be adopted
or imitated elsewhere than others. The Swiss referendum democracy
is arguably the most prominent case among those established
western democracies that have proved too specific to serve as a model
to be followed abroad.83 Even secondary features of the Swiss model,
82
See for instance Wolf Linder, Swiss Democracy. Possible Solutions to Conflict in Multi-
cultural Societies, 2nd edn, London, Macmillan, 1998, pp. 126–8; Aymo Brunetti and
Thomas Straubhaar, ‘Direkte Demokratie – “bessere” Demokratie? Was lehrt uns das
Schweizer Beispiel?’, Zeitschrift für Politikwissenschaft, 6: 1 (1996), pp. 14–17.
83
Robert A. Dahl, ‘Thinking About Democratic Constitutions: Conclusions From
Democratic Experience’, in Robert A. Dahl, Toward Democracy: A Journey. Reflections,
1940–1997, vol. 1, Berkeley Institute of Governmental Studies Press, University of
California, Berkeley, 1997, p. 505.

such as the idea of a truly collegial executive, have hardly ever been
copied successfully outside Switzerland. The direct democratic com-
ponent of the Swiss model, in its full-scale dimension, has proved
even harder, rather than easier, to imitate.
This would seem to narrow the feasible options to the two basic
models of constitutional democracy, parliamentary and presidential
democracy (including the specific form of parliamentary democracy
that many have described as semi-presidential democracy). This is
in fact the area on which much of the more recent debate about
constitutional solutions to problems of democracy has centred, and
which is too well-known to require a detailed review here. We may
thus draw from what can be seen as the dominant judgement about
the two most basic forms of constitutional democracy.
If it is correct to maintain that, ceteris paribus, parliamentary
democracies have a better overall record of achievements than pres-
idential democracies, especially in recently democratized countries,84
it seems fair to suggest that also the opposition function is best per-
formed under the conditions of parliamentary government. For
several reasons, the ‘classic’ British model of political opposition can,
however, hardly be considered to represent the ‘natural’ blueprint
for the new democracies. Both the dramatically increased implica-
tions of many legislative key decisions in the twenty-first century,85
and the growing demands of many citizens concerning the demo-
cratic quality of the political decision-making process, let the tradi-
tional British model appear as being somewhat out of touch with the
democratic ideals of the new century. The problem-solving and
consensus-building capacities of the British model have come under
serious challenge more recently even in Britain itself. While the
84
See for instance Alfred Stepan and Cindy Skach, ‘Constitutional Frameworks
and Democratic Consolidation: Parliamentarism versus Presidentialism’, World Politics,
46: 1 (1993), pp. 1–22; Juan J. Linz and Arturo Valenzuela (eds), The Failure of
Presidential Democracy. Comparative Perspectives, Baltimore and London, Johns Hopkins
University Press, 1994; Dahl, ‘Thinking About Democratic Constitutions’, op. cit.,
pp. 496–9.
85
This is both due to the enlarged complexity of many issues and the consider-
ably increased ‘longevity’ of outcomes of many legislative decisions, especially in such
areas as environmental or energy policy, or the reform of the social security systems.
See Dietrich Herzog, ‘Der Funktionswandel des Parlaments in der sozialstaatlichen
Demokratie’, in Dietrich Herzog et al. (eds), Parlament und Gesellschaft. Eine Funktions-
analyse der repräsentativen Demokratie, Opladen, Westdeutscher Verlag, 1993, pp. 13–52.

idea of ‘parliamentary sovereignty’ largely persists in British consti-

tutional theory,86 there are strong signs that in constitutional prac-
tice key decisions with far-reaching implications can no longer be
made exclusively on the basis of simple majority decisions of a rep-
resentative legislative assembly. The devolution project of the late
1990s was rightly considered by the Blair government to require
a series of (sub-national) referendums to produce the necessary
amount of democratic legitimacy. Moreover, the devolution legisla-
tion was accompanied by other reforms, for example the introduc-
tion of direct election for the mayor of London, which were also
designed to strengthen the plebiscitary factor within the repre-
sentative system. It would seem reasonable to suggest that other key
issues – such as Britain’s joining or not-joining the euro, and the
future of the electoral system for Westminster – will also be decided
by giving the voters a direct say. Whereas the traditionally ‘super-
representative’ character of the Westminster model could be altered
fairly easily, there are other, more serious problems. The British
model takes for granted the existence of a very strong basic con-
sensus about the ‘rules of the game’, and a very high degree of
toleration of simple majority decisions. This specific combination of
values has been largely absent in most other established liberal
democracies; it is certainly in short supply in most new democracies.87
If the focus is specifically on the needs of a recently democratized
polity, a more promising variant of the parliament-centred opposi-
tion model may be seen in the German model with its strong veto
and co-governing devices of the opposition parties in parliament. In
Germany itself this model has proved to be rather flexible and com-
patible with different party systems and strategies of opposition
parties. Moreover, whereas the room for manoeuvre of German
86
As a ‘realistic’ perspective reveals, however, the constitutional doctrine of ‘par-
liamentary sovereignty’ has been gradually undermined for many decades with more
recent chapters of this process focusing on the growing role of the mass media and
the changing nature of a ‘Europeanized’ system of ‘judicial review’. See Peter Riddell,
Parliament under Blair, London, Politico’s Publishing, 2000, pp. 160–3, 227–32; Gillian
Peele, ‘The Law and the Constitution’, in Patrick Dunleavy et al. (eds), Developments
in British Politics 6, London, Macmillan, 2000, pp. 78–80.
87
See for instance Larry Diamond, Developing Democracy. Toward Consolidation,
Baltimore and London, Johns Hopkins University Press, 1999, pp. 161–217; Detlef
Pollack et al. (eds), Political Culture in Post-Communist Europe. Attitudes in New Democra-
cies, Aldershot, Ashgate, 2003.

governments has been seriously constrained at times, institutional

safeguards have helped to keep government instability at bay. The
key device to be mentioned here is the ‘constructive’ vote of no
confidence,88 which marks a crucial component of the institutional
opportunity structure of the parliamentary opposition – though one
whose primary effect has been protecting governments from ‘nega-
tive’ ad hoc oppositions in parliament. The stabilizing effects of the
constructive vote of no confidence may prove even more beneficial
in countries with a more fragmented party system than the German
one.
From a broader historical perspective on German history, the
model established after 1945 may also be considered a positive
impact on the emergence of a democratic political culture marked
by a reasonable appreciation of tolerance, compromise and concili-
ation.89 As a more recent study confirms, even the tremendous chal-
lenges in the wake of German unification have not fundamentally
undermined the remarkable integrative capacities of the German
parliament-centred power-sharing model. Even serious public dissent
and democratic discontent continue to manifest themselves in elec-
toral support for the ‘loyal’ opposition parties in parliament.90
Moreover, some problems of political opposition in Germany may
hardly be blamed on the basic institutional parameters, i.e., they
could possibly be avoided in a different social, political or cultural
setting. For instance, the low degree of transparency of the demo-
cratic decision-making process in Germany has not been exclusively
the result of the basic institutional parameters of government/
opposition relations. Some of the most fundamental violations of
the responsible party government principle in recent years were
caused by the strategically motivated unwillingness of some parties
to name their respective coalition preferences on entering the
88
Article 67 of the German Basic Law stipulates that a chancellor (and his
government) can only be voted out of office if a majority of the members of the
Bundestag simultaneously elects a successor.
89
David P. Conradt, ‘Changing German Political Culture’, in Gabriel A. Almond
and Sidney Verba (eds), The Civic Culture Revisited, Boston, Little, Brown, 1980, pp.
212–72.
90
Richard I. Hofferbert and Hans-Dieter Klingemann, ‘Democracy and its
Discontents in Post-Wall Germany’, International Political Science Review, 22: 4 (2001),
pp. 363–78.

election campaign.91 This was – wrongly – expected to expand their

post-electoral ‘coalition-building’ resources. What it actually did was
to reduce significantly the voters’ chance to choose between two
alternatives.
However, even the basic constitutional arrangements of the
German model are far from perfect – especially in terms of their pos-
sible qualities as a general model for institutionalizing the opposi-
tion principle in other parts of the world. The complete absence of
any direct democratic elements at the national level, which charac-
terizes the German model, is rather unlikely to find much favour
among the bulk of other countries. Therefore a careful modification
of the strictly parliament-centred model by introducing some direct
democratic elements would appear a promising way to follow. In a
highly power-sharing parliamentary system, such as the German one,
the introduction of direct democratic devices can, however, easily
lead to ‘over-equipping’ the opposition parties with strong veto-
powers.92 There is the serious danger of legislative gridlock that, due
to the different character of the political parties in parliamentary
democracies, would be significantly more difficult to overcome than
in presidential systems.93
The international political debate about the pros and cons of direct
democracy is still marked by an exceptionally high degree of deeply
passionate support for or opposition to the direct democratic option,
which has rarely proved helpful in assessing the structural and func-
tional character of different direct democratic devices. Whereas
most kinds of popular initiatives, offering citizens a chance to partici-
pate in the political agenda setting process, do not interfere with the
basic logic of parliamentary government, the same cannot be said
about the systemic effects of referendums. In particular, optional
referendums, such as those that have been used in Switzerland for a
very long time, seem extremely difficult to reconcile with the idea of
91
This was true for the SPD in the 1998 election campaign as much as it was for
the FDP in 2002.
92
That is why many of those scholars of German politics who have argued in favour
of an introduction of some direct democratic devices at the federal level, suggest a
careful reconsideration of the powers of the Bundesrat. See Helms, Politische Opposi-
tion, op. cit., pp. 190–1.
93
For a comparative assessment of ‘divided government’ scenarios under differ-
ent constitutional conditions see Robert Elgie (ed.), Divided Government in Compara-
tive Perspective, Oxford, Oxford University Press, 2001.

responsible party government and majority rule in parliamentary

democracies. Among the various forms of referendums that have been
used in the advanced democracies over the past decades,94 the Italian
variant of an abrogative referendum – by which only existing laws may
be abolished – would appear to recommend itself as a particularly valu-
able device of direct democratic opposition, especially in the broader
context of a parliamentary democracy. In the more recent past of
Italian democratic history, the abrogative referendum (more specifi-
cally the electoral referendums of the early 1990s) has even earned a
special place by paving the way for the birth of what many have called
the ‘Second Italian Republic’.95
CONCLUSION
In this paper different key models of institutionalizing political oppo-

sition have been distinguished and discussed in light of the more
recent constitutional practice of selected countries. Given the sur-
prisingly scant attention that the ‘constitutional engineering’ litera-
ture has devoted to the various ways of institutionalizing political
opposition, the primary aim of this study has been to highlight some
of the possible lessons to be drawn by constitution-makers in post-
authoritarian regimes. To be sure, there is a limit to the positive effects
of any kind of institutional or constitutional arrangements on the
actual working of democratic regimes. While abrogative referendums
in Italy eventually worked as a catalyst for regime change in the 1990s,
they were unable to prevent the emergence and persistence of parti-
tocrazia during earlier decades. Still, seeking institutional solutions to
problems of democracy would appear to remain the most promising
path to follow. The common credo of most of the manifold variants of
‘new institutionalism’, that institutions do not only define the basic
parameters of political action but also have a long-term impact on the
actors’ goals and preferences,96 is apt to deepen this conviction.
94
For a detailed overview see David Butler and Austin Ranney (eds), Referendums
around the World. The Growing Use of Direct Democracy, London, Macmillan, 1994.
95
Pier Vincenzo Uleri, ‘Italy: Referendums and Initiatives from the Origins to the
Crisis of a Democratic Regime’, in Michael Gallagher and Pier Vincenzo Uleri (eds),
The Referendum Experience in Europe, London, Macmillan, 1996, pp. 106–25.
96
See B. Guy Peters, Institutional Theory in Political Science. The ‘New Institutionalisms’,
London, Pinter, 1999.

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Ludger Helms

Five Ways of Institutionalizing Political

IT HAS LONG BEEN ACKNOWLEDGED BY DEMOCRATIC THEORY THAT

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literature. The huge majority of works has tended to look

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rather than on the structural features, actual workings and systemic

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acknowledged to date in the international literature on contempo-

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different countries have different normative preferences, which are

UNITED KINGDOM: PARLIAMENT-CENTRED OPPOSITION WITH

No other institutional model of political opposition has acquired a

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understood to be the largest opposition party in the House of

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Yet how has this venerable model functioned in constitutional

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very democratic legitimacy. Most obviously, extended terms of one

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conflict in countries with a less tolerant and democratically mature

GERMANY: PARLIAMENT-CENTRED OPPOSITION WITH

The constitutional arrangements to be found in Germany may be

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chamber’.24 The Bundesrat basically represents the state govern-

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increases the willingness of governments to seriously consider the

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FRANCE: THE PARLIAMENTARY-PRESIDENTIAL MODEL OF

The peculiar character of the parliamentary-presidential model of

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system, France has actually experienced recurrent manifestations of

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the American separation-of-powers system to be discussed in the

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tary majority is the president’s right to dissolve the National Assem-

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tradition of considering parliament as the centre of the political

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of the length of the president’s term from seven to five years, as

UNITED STATES: THE SEPARATION-OF-POWERS MODEL OF

There are particular problems in discussing the phenomenon of

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idency have followed this direction, it is now common to consider

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have been vetoed.58 The overall effects of veto threats in terms of

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mentary democracies, highly coherent and integrated political parties

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‘divided government’, and much more important legislation fails

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This weakening of the presidency in the legislative arena – which

SWITZERLAND: THE DIRECT DEMOCRATIC MODEL OF

Whereas each of the five opposition models discussed in this article

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specific collegial form of constitutional government.72 There is a long

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The formal integration of potential veto-players that has marked

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parties usually get blurred. As statistical analysis confirms,

© Government and Opposition Ltd 2004