Distinction Between the Indian, American and British Models of Government
Indian Polity › Systems of Government · Topic 12.3
India differs from Britain in being a republic with a limited Parliament, no shadow cabinet and no legal responsibility of ministers, and from the USA in having a parliamentary system, a stronger Centre, central residuary powers, single citizenship and integrated courts.
5 min read · UPSC Prelims · Polity · Systems of Government
At a Glance
- What it is A comparison of the Indian system with the American and British models
- India and Britain Both parliamentary, but India is a republic with limited parliamentary powers
- India and USA India has a parliamentary and a quasi-federal system; the USA has a presidential federal system
- Federal base Canadian model rather than American
- Exam link UPSC Prelims, Polity: Systems of Government
Where Does It Fit?
This is the third topic of the category on Systems of Government. The Indian parliamentary system is largely based on the British system, but it never became a replica. The federal system is based on the Canadian model, and many of its features contrast with the American model.
India and Britain
| Point | India | Britain |
|---|---|---|
| Head of State | Elected President in a republic | Hereditary King or Queen in a monarchy |
| Sovereignty | Parliament is not supreme; limited by a written Constitution, federal system, judicial review and Fundamental Rights | Sovereignty of Parliament |
| Prime Minister | Member of either House of Parliament | Member of the House of Commons |
| Ministers | A non-member can be a minister for a maximum of six months | Usually members of Parliament alone |
| Legal responsibility of ministers | No such system; ministers do not countersign the Head of State’s acts | System of legal responsibility exists |
| Shadow cabinet | No such institution | Formed by the opposition to balance the ruling cabinet |
Three Prime Ministers, Indira Gandhi in 1966, Deve Gowda in 1996 and Manmohan Singh in 2004, were members of the Rajya Sabha when appointed.
Why India Chose the Parliamentary Model
A plea was made in the Constituent Assembly for the US presidential system; K.T. Shah favoured it. But the framers preferred the British parliamentary system because they were familiar with it from British rule, because Dr Ambedkar noted that a democratic executive must satisfy stability and responsibility, and the American system gives more stability but less responsibility while the British system gives more responsibility but less stability. The Draft Constitution therefore preferred more responsibility to more stability. K.M. Munshi argued that constitutional traditions had already become parliamentary and there was no reason to buy a novel experience. The Swaran Singh Committee later opined that the parliamentary system had done well and need not be replaced by the presidential system.
Parliamentary and Presidential Systems: India and the USA
| Point | India (parliamentary) | USA (presidential) |
|---|---|---|
| Executive | Dual executive: President and council of ministers | Single executive: the President is head of State and government |
| Responsibility | Collective responsibility to the Lok Sabha | President and secretaries are not responsible to Congress |
| Tenure | Government depends on majority support | President elected by electoral college for fixed four years; removed only by impeachment |
| Membership | Double membership of ministers | Secretaries are not members of Congress |
| Dissolution | President can dissolve Lok Sabha on PM’s advice | President cannot dissolve the House of Representatives |
| Separation of powers | Fusion of powers | Doctrine of separation of powers is the basis |
| Advisers | Council of ministers from Parliament | Cabinet or Kitchen Cabinet of non-elected departmental secretaries |
Federal Features: India and the USA
| Point | India | USA |
|---|---|---|
| Residuary powers | Centre | States |
| State territory | Parliament can change by simple majority; destructible states | Indestructible Union of indestructible states |
| Constitution of states | Single Constitution | States can frame their own |
| Citizenship | Single citizenship | Dual citizenship |
| Courts | Integrated judicial system | Double system of federal and state courts |
| Representation in upper house | Rajya Sabha by population, 1 to 31 seats | Senate with two members from each state, 100 in all |
| Initiating an amendment | Only Parliament | States can also propose |
| Public services | All-India Services in addition | Separate federal and state services |
| Audit | CAG audits Union and states | Comptroller-General has no role with state accounts |
| Head of the state | Governor appointed by the President | Elected head in the states |
| Reservation of state bills | Governor may reserve bills; President has absolute veto | No such provision |
The USA is the first and oldest federation, formed in 1787 following the American Revolution, and now comprises 50 states, originally 13. The Canadian federation, formed in 1867, comprised 10 provinces, originally 4. India takes from Canada the strong Centre, the term Union, formation by disintegration, the appointed head of the state and the residuary powers with the Centre.
Why Is This Topic Important?
- Comparison format Tabular comparisons are regular question types
- Source of features Links to the sources of the Constitution
- Revision Condenses 12.1 and 12.2
What Came Next?
The next topic covers the quasi-federal nature of the Indian Constitution.
Key People and Terms
- Sovereignty of Parliament British doctrine
- Shadow cabinet Opposition’s alternative ministers
- Kitchen Cabinet Presidential advisers in the USA
- Electoral college Elects the US President
- Dual citizenship National plus state citizenship
Exam Corner
Points to Remember
- India has a republic; Britain a monarchy.
- India: no shadow cabinet, no ministerial legal responsibility.
- USA: residuary powers with states.
- USA: dual citizenship and double system of courts.
Do Not Confuse With
- Sovereignty of Parliament and parliamentary government The first is British; India has the second without it
- Indian PM and British PM Indian PM may be in either House
- Residuary powers in India and USA Centre versus states
Memory Hook
Britain gave the cabinet, Canada the Centre, America the rights and review.
Mains Angle
Questions on this topic usually ask for differences. Use these points to add depth.
- Borrowing with adaptation India did not copy any single model
- Limited Parliament Written Constitution and judicial review
- Federal tilt Strong Centre unlike USA
- Single citizenship Unity over dual loyalty
A Question You May Face
An original practice question, not a past paper question.
“Compare the Indian parliamentary and federal systems with those of Britain and the USA.”
How to Answer
- Introduction Sources and adaptation.
- India and Britain Differences.
- India and USA Differences.
- Conclusion Indian uniqueness.
GS Relevance
Frequently Asked Questions
How does the Indian parliamentary system differ from the British?
India has a republic with an elected President, while Britain has a hereditary monarch. Parliament is not sovereign in India because of the written Constitution, federalism, judicial review and Fundamental Rights, and India has no shadow cabinet or legal responsibility of ministers.
Can the Indian Prime Minister be a member of the Rajya Sabha?
Yes. In India the Prime Minister may be a member of either House of Parliament, whereas in Britain the Prime Minister must be a member of the House of Commons. Indira Gandhi, Deve Gowda and Manmohan Singh were Rajya Sabha members.
How is the Indian executive different from the American?
India has a dual executive, with the President as nominal head and the Prime Minister as real head, accountable to the Lok Sabha. The USA has a single executive in which the President is both head of State and government and is not responsible to Congress.
Who holds residuary powers in India and the USA?
In India the residuary powers are vested in the Centre. In the USA they are vested in the states. This difference reflects the strong Centre in India, modelled on the Canadian federation, versus the state-centred American federation.
What is dual citizenship and does India have it?
Dual citizenship means both national and state citizenship, as in the USA and Australia. India has only single citizenship, so all citizens enjoy the same rights wherever they were born or reside, which strengthens national unity.
PYQ Practice — Statement Analysis
1 India has a shadow cabinet like Britain.
Not in India.
2 Residuary powers vest in the states in the USA.
In India with the Centre.
3 The Indian Prime Minister must be a member of the Lok Sabha.
Either House.
4 The US President can dissolve the House of Representatives.
He cannot.
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