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1. The president of America is frequently referred to as the world's most powerful

person. However, the federal structure of America has put restraints on the power of thepresident that do not occur in Great Britain, lead by a Prime Minister. The powers of Congress and the Supreme Court are used as a balance to the power a president mightaccrue in his time in office. The Constitution of America ties the president down as towhat he can and cannot do. This codified document can only be changed by theSupreme Court. Such a constraint does not exist in Britain though the input of theEuropean Court on formulating some British legislation is difficult to assess but does notcome into the same league as the power that that the Supreme Court of America has.

The general powers exercised by a British Prime Minister include:

the power to appoint, reshuffle or dismiss cabinet ministers 

the power to create new peers to the House of Lords 

the power to give out honours 

the power to appoint top civil servants, ambassadors, bishops and judges 

the power to determine government business and Cabinet discussions/agendas 

the power to withhold information from the Houses of Parliament if deemed necessary 

the power to use the media via a lobby system 

the power to terminate the life of a government and call a general election 

The Prime Minister clearly has an abundance of powers at his disposal. Sir RichardCrossman wrote that :

(The PM) is now the apex not only of a highly centralised politicalmachine but also of a highly centralised and vastly more powerfuladministrative machine.

The PM's position as leader of the majority party in the House of Commons together with his position as head of government, thus combining legislative and executivepowers, amounts to an "immense accretion of power."

Many of the PM's powers derive from the prerogative powers of the Monarch. Theseextensive powers are wielded independently of Parliament and effectively give everyPM the power of a Head of State. These powers include the right to appoint ministers,to dissolve Parliament and so set the timing for a general election, to be in charge of thearmed forces and the security services, to negotiate treaties and other diplomaticagreements and to summon and chair Cabinet meetings. The proponents of PrimeMinisterial government postulate that the Cabinet is effectively the tool of the PM andthat, in practice, government policy has long ceased to be decided at Cabinet

meetings. PM's use Cabinet Committees (the PM chairs several of these), bilateralmeetings with individual ministers, the No. 10 Policy Unit, the Cabinet Office, ThinkTanks and 'kitchen cabinets' of personal aides and advisers, to shape policy andpresent it to the Cabinet. The Cabinet as a collective body, it has been argued, hasbeen reduced to a clearing house and ratifier of decisions already taken.

Unlike their ministerial colleagues, the PM is not tied up with a particular departmentand is ultimately responsible for co-ordinating government policy across the board. ThePM's potential impact on policy-making is therefore enormous and a pro-active PM like

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Mrs. Thatcher intervened extensively in departments and left her personal imprint on anarray of policies from local government, education to privitisation.

This suggests that the PM can act like a virtual autocrat. However, this is not so asthere are constraints on his power. Though a PM's power in the Cabinet is great, hecannot get himself into a situation whereby he is seen to surround himself with 'nodding

donkeys'. The party he leads will not tolerate this and every five years (maximum) thePM and the party have to present themselves to the country who will vote on their record of government. A PM who is seen to be going against the British tradition of democratic government whereby the party is all-inclusive at Westminster will lose outwhen the party abandons its support for him. Mrs. Thatcher lost the support of both her Cabinet and the Conservative Party when she was seen as being too over-bearing andout of touch. A PM who loses support from his own party is doomed to failure even if hedoes have the power to reward loyalty. The current PM, Tony Blair, leads a party with aParliamentary majority second to none. On paper, it would appear that his power as PMis unassailable. However, all he needs to do to sow the seeds of his own politicaldownfall is to lose the support of those Labour MP's at Westminster. In this sense, theparty have the power not the PM. Tony Blair has yet to have a serious challenge to hisposition as party leader. What happens should this occur?

Many in the current Labour Party are concerned about Tony Blair's apparent desire tomake decisions by himself or with a small non-elected clique thus by-passing both theCabinet and Westminster. A former Cabinet colleague, Mo Mowlam, has made theseaccusations and has also stated her belief that Cabinet meetings are a farce as they areno more than sessions whereby Blair is agreed to. If this is the case, what happenswhen the Labour Party tires of this?

During the current fight against terrorism, President Bush has held frequent meetingswith Cabinet colleagues, and those who air a belief that an American attack on Iraq -without an agreement from the UN Security Council - is fraught with danger, are

seemingly allowed to do so. Colin Powell has been reported as voicing his concernsand the media have reported this accordingly. The President has his views while othersclose to him express theirs. Congress has also had an input with the Senate approvinga $34.4 billion rise in defence spending to assist in the president's campaign againstterrorism. The House of Commons, on the other hand, has frequently complained that itis being side-lined by not having a full debate about the issue. Therefore, the ability andopportunity for politicians to voice opposition to the PM's policies regarding this foreignpolicy issue are very limited. Blair has been accused of developing presidential powers.

However, the powers of the president of America are limited by Article II of theConstitution. There are many things the president can do but there are also many thingsthat he cannot do. The House of Commons at Westminster does not formulate policy; it

discusses proposed legislation and votes on them. Congress, however, has been givenvery real powers by the Constitution, the likes of which are not seen in Great Britain.The Senate can remove the president from office - the president cannot remove aSenator; the Senate ratifies the president's Cabinet; all financial issues have to start inthe House of Representatives and Congress can reject a president's proposed budget.These clearly limit the power of a president.

In Britain, the Chancellor's budget is introduced regardless of what Parliament thinks.With the exception of a party revolt, the party in power cannot remove a PM

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2. Within their domestic systems, the Prime Minister and President are both the

“chief executive”. They are, therefore, the head of policy implementation within

their countries and in this respect have similar roles. In the UK, though, by

constitutional convention, the Prime Minister shares this role with his cabinet as

‘first among equals’. The President does not. As the constitution states, “theexecutive power shall be vested in a President”, not a President and his cabinet.

Even so, the President uses a cabinet, which is narrowly provided for by the US

constitution (article 2, section 2). This, and recent Prime Ministers’ (Tony Blair)

apparent erosion of cabinet power, would suggest that chief executive power is not

restrained any more by cabinet in the UK than in the US. Furthermore, when we

look beyond the executive function of the President and Prime Minister, the Prime

Minister’s domestic powers appear to extend further and further ahead of those of 

the President.

One of the most striking features of US politics is the regulation and

interdependence each branch of government; and the Executive Office is in no way

exempt from this principle. The President makes Supreme Court nominations,

subject to approval by the Senate. The President can sign treaties, subject to

ratification by the Senate. The President is ‘Commander in Chief’ of the armed

forces, whose funding comes from Congress. The president is also chief legislator,

but any legislation must be passed by Congress, and any veto may be overridden

by a determined-enough Congress (as shown by the 2007 override of George Bush’s

water bill veto). Consequently, the President has very little independence, despite

being head of state.

By contrast, the Prime Minister has a great deal of autonomy within UK government,and is subject to far fewer checks than the President. The Royal prerogative powers

give a Prime Minister extensive independence; to declare war, appoint ministers

and civil servants and to call elections, among other things. Powers of patronage

are particularly important, as they provide a carrot for a Prime Minister to dangle

before potentially rebellious MPs. Due to its fairly undemocratic nature, the royal

prerogative power to declare war would be dangerous to use, and this is probably

evidenced by Gordon Brown’s willingness to surrender this power in attempt to

reform the royal prerogatives.

Even so, it is not in the royal prerogative powers that a Prime Minister’s true might

lies. It is in his combined role as a Member of Parliament, chief legislator, and

commander of a whipped and incentivised majority within the House of Commons.

Indeed, if, like James Callaghan, a Prime Minister is not in this incredibly strong

position, he or she will not be Prime Minister for much longer. Therefore any

incumbent Prime Minister must be in a position of incredible legislative strength

compared to the US President. In practice, this means that a Prime Minister can

force through almost any legislation, and therefore control British statute.

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A President has no such ability, at least not consistently. There is no guarantee that

the President’s party will occupy a majority in either House, let alone both Houses of 

Congress, as demonstrated by the current scenario. Even if it did, party discipline

-and partisanship in general- is far weaker in the USA, not least because of the

comparative lack of ‘carrot and stick’ factors to compel legislators to vote on partylines. Although by convention presidential legislative initiatives tend not to be

blocked in Congress, there is no guarantee of this. One must also consider that the

heavy amendment which secure presidential bills undergo may well distort the

original bill considerably, following the influence of committees that are far more

powerful than those in the UK.

3. The comparison of the US President and the British Prime Minister appears from

the onset, to provide some interesting differences since the President holds the

position of Head of State as well as Head of Government. The Prime Minister, it

would appear, has more influence in domestic, able to dominate his part, legislatureand to an extent, executive branch. The US President, on the other hand, appears to

have the position of supremacy in domestic politics, known as the chief legislator

and dominates his executive, though part control is limited. He does not hold the

same position of power in domestic affairs as the Prime Minister, but his position of 

strength appears to be in the realm of foreign and international matters, in which he

faces little challenge from Congress. Much of this prominence is derived from his

status as the ‘Nation’s Leader’ and the unifying force in a dispersed political system.

It would appear that both offices hold different powers, all of which will be taken

into account when deciding which is more powerful. The power, which the holder of 

each office exercises over their respective party in the legislature is of great

significance in determining which office, confers the most power. The British Prime

Minister, as shown by past examples, usually holds substantial power over the party

machine from which their power originates, and position depends on. The absence

of a clear separation of powers in the British system gives the British Prime Minister

the position of, head of the majority party in parliament. Due to such a strong link

between the Prime Minister and his party he can often expect loyalty as a matter of 

course when forwarding legislation. The President can not though, expect such

favorable treatment from his party, as no direct link exists between he and his party

colleagues in Congress, a situation created by the ‘separation of powers’, a primary

intention of the Founding Fathers when writing the Constitution to prevent

executive dominance. The British Prime Minister also has, at his disposal, a powerfulWhip system to maintain party loyalty. British MPs are faced with the threat of 

losing career prospects within government, temporary suspension, the enmity of 

their colleagues, failure to be selected by their constituency party, and the ultimate

sanction of expulsion from the party. Such weapons make the Whips a vital tool to

the Prime Minister in maintaining party loyalty. It may be true that both Senators

and Representatives of the same party as the President face similar threats when

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voting on Presidential legislation, but they also face numerous other pressures

which they take into account when voting, most notably, their own personal

convictions, lobbyist and financial backer’s views, and pressure from constituents

upon whom they rely for reelection. This is particularly true of Representatives who

stand for election every two years and are thus ‘fighting a permanent election

battle’. For such reasons, members of Congress, especially Representatives, areusually more independent when it comes to voting. Despite the success of 

presidents such as FDR in maintaining strong party loyalty in Congress, the example

of Presidents such as Carter show that party loyalty is not often guaranteed or even

expected in the US system. This explains the reliance on ‘logrolling’ by the US

President when attempting to gain support for legislation, rather than the reliance

on party loyalty, which dominates British politics. The example of Reagan, a

Republican, in gaining control over the federal budget through the cultivation of 

good relations with Tip O’Neill, a Democrat House Speaker, showed clearly how the

support of the opposing party is often required to pass legislation within the US

system. It has been noted though that control over party, for both the President and

British Prime Minister depend much on the varying political climate at that time. In

Britain, the example of the Conservative rebellions over Europe throughout the life

of the Major government which served to decrease the government majority and

eventually render it non-existent, showed how party support could be lost and

extremely weaken a Prime Minister’s power. By contrast, many political observers

have noted the growth of a more cohesive party system, especially after the

‘Contract With America’ produced by the Republican Party in 1994 after a sweeping

victory in the elections for both Houses of Congress. If the Congressional

composition remains as it is after the elections in November and Bush wins the

Presidential election, it will be interesting to see how the relationship between he

and Congress will develop and if such party unity does in fact exist. Undoubtedly,the prime minister appears to hold a considerable advantage in controlling his

party, much more so than the president, who is faced with a disunited party system

and the lack of a working authority with his party colleagues. The power, which

each office holds over the passage of legislation, is of great significance in

determining which office holds the most power as a whole. The British Parliament,

according to McNaughton, may be sovereign but when considered thoroughly, this

is only a theory. “In effect, the sovereignty of Parliament becomes the sovereignty

of the Government” (McNaughton). This view tends to show that the British Prime

Minister, who usually maintains the support of a parliamentary majority, holds a

position of dominance over the passage of legislation. The American system though,due to the ‘Separation of Powers’ between the Executive and legislative branches,

in theory provides a limit to Presidential power over the passage of legislation. The

‘checks and balances’ which exist within this system, according to McNaughton,

both limit and enhance the independence of Congress in dealing with legislation,

with the constitution acting as the guarantee of such a position. The majority, which

the Prime Minister can usually rely on, both because of the election system and the

use of the Whips is in effect a guarantee of legislative success, especially true with

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the current Blair government which holds a massive majority in parliament, so

much so that even legislation which faces much opposition from within can pass

with ease. The passage of the Bill on the privatization of Air Traffic Control in May,

despite a massive revolt, shows clearly how the British Prime Minister can push

through legislation, which has little support. Contradictions though, most notably

from the Major administration, show that other factors also play a significant role inthis, such as the size of the majority, leadership skills and party unity. The President

though, due to the relative lack of party loyalty and the election system, which

often results in ‘split-ticket voting’, cannot hope to have such control. The President

is aware that members of Congress often have their own interests as regards

legislation, and therefore compromise is often the key to Presidential success. The

individual wishes of Congressmen, it would therefore appear, are influential in the

passing of legislation. In Britain, the failure of Private Member’s Bills is common,

with success limited to about five Bills per year. This due to the lack of support

given by the government, those with support are the only ones with a real chance

of success. The parliamentary timetable is dominated by Government Bills, which

find their roots with the Prime Minister, and have a relatively minute chance of 

failure. The British Prime Minister, it would appear has more legislative power than

the President since he has much control over the workings of the standing

committees which consider and amend legislation. The governing party’s majority,

the existence of whipped voting and the application of the guillotine allows the

Prime Minister to effectively control the work of such committees. Only

amendments, which he favors, will be moved to a vote so that the government Bill

usually emerges unaltered. The standing committees of Congress, in stark contrast,

are not under the control of the President and have a much wider range of powers

when considering legislation, and are themselves key policy initiative areas, acting

as an alternative to Executive dominance of the legislative program. Besides,Presidential Bills have to negotiate further hurdles in their passage through

Congress, from the Rules and Majority Policy Committees, which hold great

influence on the likelihood of success for the Bills proposed by the President, as

they determine when they will be debated. It would appear therefore that the only

effective formal power, which the President possesses, is that of veto. This, though

subject to overturn by the 2/3 majority of both Houses, is a very effective power in

legislating. Clinton, for example, used 17 vetoes between 1993 and 97 with great

success, having none overturned. Bush too, had great success in using the veto,

defeated only once from 1988 to 1993. The power of the pocket veto has also

become an effective weapon of the president in controlling legislation, since it cannot be overturned and needs not be explained, and moreover, can be used a

bargaining counter with Congress to ensure success for Presidential legislation. It

would appear that the constitution has limited the power of the President and

strengthened Congressional power, but when looked at more closely, the President

has become known as the ‘Chief Legislator’, according to Johnson, for his extensive

use of the State of the Union address to forward his proposals for legislation and

make it known to Congress, his intentions for the year, and the fact that he passes

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more legislation than Congress. We may also consider the use of Executive Powers

by the President as a further way in which he can bypass Congress, and exert his

law-making powers. The extensive use of such powers in Foreign Affairs have been

a significant element of the Presidency in recent years, as Executive Agreements

have been used instead of Treaties so that Senate’s approval is not required. They

have also been used to send troops abroad, an example being the Grenada andPanama situations of the 1980’s, when the War Powers Resolution of 1973 and the

Constitution were successfully sidestepped. The British Prime Minister cannot

expect to hold so much foreign influence, as the question of foreign policy appears

to spark the interest of Parliament, shown by the quality of debates on foreign

issues. The Prime Minister does not have the ability to use Executive powers in this

area either, and he does not hold the position of Head of State. It would appear

therefore that both the President and Prime Minister have extensive powers in

legislating, both having the most control within their respective systems. The Prime

Minister though, appears to have the most influence over legislation, when

compared to the President, as his dominance over the legislature is much more

secure and faces less opposition. The president though, through his use of 

executive powers, appears to have almost unlimited powers in foreign affairs,

whereas Congress are more concerned with domestic issues. Both offices are faced

with the scrutiny of committees within the legislatures of the respective systems.

 The British Prime Minister, in theory, is held to account and scrutinized widely by

the Select Committees of the commons and the in House debates and Question

 Time. Select Committees have the right to ‘persons, papers and records’ and may

commission damning reports which are of great use in scrutinizing the Prime

Minister, a view backed by Adonis, ‘they have enhanced the profile of the House’. In

practice though, Prime Ministers, as shown by Thatcher in particular, can greatly

limit their effectiveness in scrutinizing, by withholding vital evidence and witnesses,as was the case in the 1996 investigation into the ‘Arms to Iran’ affair. Such

committees, according to Norton have numerous other setbacks which limit their

scrutinizing powers, such as time restrictions and the lack of an independent inquiry

into their reports (this is left to the government to act upon). The President faces

much more intense scrutiny from both Standing and Select Committees since they

have a wider remit to evidence due to their extensive finance and freedom of 

information laws, added to this is the apparent lack of government secrecy on a

scale such as that displayed in Britain. The investigations carried out by such bodies

often gain public attention and mass media coverage, prominent examples being

the Watergate Committee of 1974 which had mass following and demonstrated thepower of such committees, by subpoenaing vital evidence which led to the

resignation of Richard Nixon. Due to the direct link between the Prime Minister and

the legislature, it may appear that he would face much more intense scrutiny than

the President, as he has to face the Commons in debates and at Question Time. This

may be true in theory, and has support from Adonis, but in practice debates have

little influence on government policy, usually made to a sparsely attended chamber

and only having real influence when the government is in a small majority, as

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shown during the time of Major when the debate over coal mines in 1992 led to

Major’s back down over shutting them down. Adonis argues that debates on

international issues are of great value as they force the Prime Minister to defend his

actions and help in the area of sound policy making, a recent example being the

debate on Kosovo and the subsequent decision to send in British troops. Question

 Time too has come under attack for its ritualistic nature and often, ‘rowdy’ nature inwhich it becomes a mere point scoring match, a situation which appears to have

continued despite Blair’s reforms in 1997. Such politics has led to, according to

many analysts, the apathy towards politics felt by many in Britain today. It would

appear that the President is more extensively scrutinized than the Prime Minister,

and thus his power is greatly limited in order to provide accountable government for

the United States. The lesser degree of government secrecy and the ‘separation of 

powers’ provide, it would appear, a more adequate form of scrutiny. The power of 

each office can also be measured by the degree of control they exercise over their

cabinet and executive. In theory, the British Prime Minister is merely regarded as

the ‘first among equals’ within the cabinet, and is usually expected to meet with

cabinet, which is a formal unit. The President though, is not obliged to meet with his

cabinet or consult them on policy, as cabinet is not a formal unit contained within

the constitution. There is no doctrine of collective decision making, and the

President holds the power of supreme decision maker when consulting cabinet and

may ignore the views of his cabinet, a policy favored by Presidents such as Kennedy

and Bush, who formalized meetings and paid little attention to the views of their

cabinets. In Britain there exists the doctrine of collective decision making, which is

supposed to help in stable government and collective decision making, but has

been manipulated by many prime Ministers to silence dissent as those who refuse

to do so are forced into resignation. The American President may, if he so wishes,

use alternative sources of information apart from his cabinet, namely EXOP or theIndependent Executive Agencies, which are contained within the Bureaucracy. This,

it would appear, gives the President a vital alternative source which can only help

increase his power as it provides vital information and analysis. The British Prime

Minister, according to Dunleavy, has also taken on such a policy, pre-cooking policy

and using alternative sources of information when deciding policy. Thatcher, in

particular, greatly increased her power within the executive by increasing the power

of the Prime Minister’s Office and successfully using the Cabinet Secretariat as a

further means of centralizing power. Blair too, as he streamlined the two, has

followed up on such a policy to adapt both executive branches to his advantage, to

keep his cabinet in check, and to use it successfully in media relations. Dunleavyand Rhodes claim that the power within the British executive though, cannot be said

to be merely central to the Prime Minister as it is more complex than it appears,

rather that power within the British executive is spread in different places at

different times, depending on the political landscape. It would seem therefore, that

the president has more control over his executive than the prime minister, as

McNaughton points out, since he can easily centralize power around himself 

whereas the prime Minister must refer to his cabinet. The comparison of the US

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President and the British Prime Minister appears from the onset, to provide some

interesting differences since the President holds the position of Head of State as

well as Head of Government. The Prime Minister, by comparison, is merely Head of 

Government, but as we have seen from the above, is able to exert considerable

influence to merit a comparison with the President. The Prime Minister, it would

appear, has more influence in domestic politics and is able to successfully dominatethe legislature due to a lack of ‘separation’ between the executive and legislature,

avoid the intense scrutiny of Parliament, and keep a firm grip over his party which

the president cannot. The US President, on the other hand, appears to have the

position of supremacy in domestic politics, although not to the degree of the Prime

Minister, but his position of strength appears to be in the realm of foreign and

international matters, in which he faces little challenge from Congress. Much of this

prominence is derived from his status as the ‘Nation’s Leader’ and the unifying

force in a dispersed political system. It is therefore difficult to assess which office is

more powerful, but it would appear that the President is more powerful in foreign

affairs and the Prime Minister, more dominant in domestic politics. However, the

Prime Minister must also maintain the support of the legislature, whereas the

president can govern without support here

4. Political instinct alone seems to dictate to many that the American president – ‘the

world’s most powerful man’ – is the most powerful politician in any of the world’sdemocratic nations. He is at the head of the world’s most modern military force and theworld’s largest economy. What the president says is reported around the world andworld share markets can fall or rise on any public statement by him. But is he thewestern world’s most powerful politician?

In America, the president is the best known of many politicians. This alone gives him a

great deal of authority as many people within their own states cannot name their ownrepresentatives in the House, Senate or governor. The simple fact, that the presidenthas the title of president gives him enormous authority and power in that he is the mainfigurehead within the whole of the massive American political structure. To take on thepresident is seen as almost taking on America and all that the nation stands for. WhenClinton moved towards the impeachment process during the Lewinsky scandal, he waspaying the price for what he had done as a person not as a politician who happened tobe president. Even so, the fact that the Senate failed to go all the way down the road toimpeachment was probably because they did not want to see the title of presidentsullied in such a manner. The same is probably true of Nixon during the Watergatecrisis. Here was a man who was allowed to resign rather than face the ignominy of 

impeachment and possibly a full trial in the full glare of the public at both domestic andinternational level. Protecting the name of the president and all he stands for does givethe post-holder a great deal of authority and, in this sense, power.

The British Prime Minister does have the same international standing as the president.In the crisis involving Iraq, the driving force behind any move against the leadership inBaghdad has been the American president, G W Bush, while Tony Blair, the BritishPrime Minister, has been referred to as clinging onto the coat tails of Bush. Britainsimply does not have the international standing to overtly influence policies – her 

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military is weak compared to America and though a member of G7, our economicstanding in the world is dwarfed by America’s. Such a position does not allow the PrimeMinister to drive an international agenda whereas the US president can. In this sense,the power of the US president abroad is far greater than that of the British PrimeMinister.

In domestic politics that same power is more open to question. The president can selecthis own cabinet with which he can work, but it has to be ratified by the Senate. Whilstthis is usually a formality – as the Senate would usually want to be seen as giving a newpresident a sound start to his four years – it does in theory mean that the presidentmight have to work with people he did not initially select for his cabinet. The PrimeMinister has no such restrictions. He selects all those people he wants for his cabinetand can remove them if they fail to make the grade. He does not have to consultanybody over this though he might discuss it with an inner circle of very closecolleagues. Least of all does the Prime Minister have to have his cabinet agreed to bethe House of Commons or Lords.

The president is not head of his party. Bush may be a Republican but he does not head

the party. Though to many people he does ‘hold’ this title, the chairman and committeemembers of the Republican Party Central Committee hold great sway in the actual partyitself and the 50 Republican Parties at state level also do a great deal to defend their political independence coming together in a needed act of loyalty every four years atelection time. The British Prime Minister is not only prime minister, he is also a servingMember of Parliament and head of his party. As such, he commands huge respectwithin that party and does a great deal to drive the policies of that party in power. With alarge parliamentary majority, it is almost certain that prime ministerial policies willbecome actual policy and law. If things go wrong, then the Prime Minister will be heldresponsible but if they succeed he will get the spoils of this.

It is more difficult for the president to drive domestic policy in America. He announces

his platform at his national convention but is not bound by it. Whilst this may give himmore freedom to adapt his stated policies throughout his term in office, he cannotguarantee getting them through Congress. As an example, in Britain the main annualbudget speech in made in the early Spring. This is publicly stated in the House of Commons by the Chancellor, though with the support of his Prime Minister, and it isthen enacted. The only problem in recent years was when Nigel Lawson’s speech wasinterrupted by outraged Opposition politicians and there were short breaks in thedelivery of that budget. But the budget still went through as all do. In America, thepresident prepares his budget for Congress to scrutinise. But it is Congress thatessentially has the final say in that it can reject the president’s budget proposals. Inreality, much is done behind closed doors to ensure that a very public bill – America’sbudget for that year – goes through with little apparent public rancour. However, thepotential is there for embarrassment for the president.

The political set-up in both countries also gives the Prime Minister the edge over thepresident. If the Prime Minister has a sound parliamentary majority (or a record largeone as Tony Blair does have), it is very probable that the policies that he wants willbecome law. A simple Parliamentary vote on this almost certainly means that the PrimeMinister will have his way. With the House of Lords currently under review and its power likely to be severely clipped, it falls to the European Union to deem certain British laws

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valid or not. In fact, in recent years the European Union has done little if anything toimpact on important British legislation. It has intervened on issues that involve a fewsuch as the sentencing of the Jamie Bulger murderers. But with the fear of encroachingfederalism seemingly strong throughout Europe, it seems highly unlikely that theEuropean Courts would involve itself in wholesale British domestic policies that havecome from a democratically elected government. If this remains true, and the currentgovernment maintains its current huge parliamentary majority, the Prime Minister will beable to push through reform after reform (though the result of a referendum on the Euromight prove an interesting issue for him).

The president does not have such domestic power. He is hamstrung by the powersgiven to others by the Constitution. This document is very clear about the powers hehas. But it is also very clear about the powers given to Congress and to the SupremeCourt. In recent years, the Supreme Court has been more involved in assessing statesrights rather than presidential powers and in the aftermath of September 11th 2001, GW Bush has seemingly been able to do anything by flying the patriot’s flag. However,the Constitution and its makers, do state the powers of Congress first in Article 1 andthen the powers of the president in Article 2. Was this their way of putting an individualin his place after the experience of one man’s power in Britain during the independencecrisis? Again, compromise appears to ensure that most presidential recommendationsget through Congress as this approach alone ensures that the system is notembarrassed in the nation’s eyes. However, the president still has the power of vetoover Congressional legislation by the simple fact that he must sign all legislation beforeit becomes law. The use of the pocket veto does extend the president’s authority at adomestic level but its overuse might lead to cries of one man ridding rough over one of the main bastions of America’s democracy – Congress. Also, if both sides – presidentand Congress – are satisfied that they have both had an input into proposed legislation,why would a veto be needed?

The input both president and Prime Minister have in the judiciary is about equal. Withinthe Supreme Court, the president can only appoint a Supreme Court judge if a sittingone has retired or has died. His appointed successor must then be ratified by theSenate, and this has not always happened in the past as Ronald Reagan found. ThePrime Minister can influence the appointed of senior figures in the judiciary as heappoints the Lord Chancellor who then has great power in selecting circuit judges etc.

In foreign policy, the president exerts far greater power than the Prime Minister. Britainsimply does not have the status that America does at an international level. It seemshard to believe that Colin Powell as Secretary of State, would have received the sametreatment in Israel as Britain’s then Foreign Secretary, Robin Cook, did when hereceived a less than polite welcome on a visit to that country. Only America has thenecessary power and influence to gather together the necessary support in the UnitedNations for her foreign policy.

However, in domestic issues, the Prime Minister has the advantages in that he as anindividual can push through domestic legislation as he is not only Prime Minister butalso party leader. The constitutional restraints that are on the president simply do notexist in Britain. The president can veto a bill from Congress but an overuse of this willdevalue not only his position but also that of the political structure in America. In Britain,the only thing that can stop a bill becoming law under the current political set-up, is if the

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Queen refused to give the Royal Assent to a bill that had gone all through thedemocratic procedures of Parliament. Such an incident is inconceivable. If the PrimeMinister has a large parliamentary majority, then he has very extensive powers at adomestic level with probably far fewer restrictions placed on him than a president.

5. The President of the United States of America is the head of state and head of government

of the United States. The president leads the executive branch of the federal government and isthe commander-in-chief of the United States Armed Forces.

Article II of the U.S. Constitution vests the executive power of the United States in the presidentand charges him with the execution of federal law, alongside the responsibility of appointingfederal executive, diplomatic, regulatory, and judicial officers, and concluding treaties withforeign powers, with the advice and consent of the Senate. The president is further empowered togrant federal pardons and reprieves, and to convene and adjourn either or both houses of Congress under extraordinary circumstances.[5] Since the founding of the United States, the power of the president and the federal government have grown substantially[6]  and each modern president, despite possessing no formal legislative powers beyond signing or vetoing congressionally passed bills, is largely responsible for dictating the legislative agenda of his party and the foreign and domestic policy of the United States.[7] The president is frequentlydescribed as the most powerful person in the world. [8][9][10][11][12][13]

The president is indirectly elected by the people through the Electoral College to a four-year term, and is one of only two nationally elected federal officers, the other being the Vice President of the United States.[14] The Twenty-second Amendment, adopted in 1951, prohibits anyone fromever being elected to the presidency for a third full term. It also prohibits a person from beingelected to the presidency more than once if that person previously had served as president, or acting president, for more than two years of another person's term as president. In all, 43individuals have served 55 four-year terms.[15] On January 20, 2009, Barack Obama  became the44th and current president.

Powers and duties

Article I legislative role

Obama signing legislation at the Resolute desk.

The first power the U.S. Constitution confers upon the president is the legislative power of the presidential veto. The Presentment Clause requires any bill passed by Congress to be presentedto the president before it can become law. Once the legislation has been presented, the presidenthas three options:

1. Sign the legislation; the bill then becomes law.

2. Veto the legislation and return it to Congress, expressing any objections; thebill does not become law, unless each house of Congress votes to overridethe veto by a two-thirds vote.

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3. Take no action. In this instance, the president neither signs nor vetoes thelegislation. After 10 days, not counting Sundays, two possible outcomesemerge:

○ If Congress is still convened, the bill becomes law.

○ If Congress has adjourned, thus preventing the return of the

legislation, the bill does not become law. This latter outcome is knownas the pocket veto.

In 1996, Congress attempted to enhance the president's veto power with the Line Item Veto Act.The legislation empowered the president to sign any spending bill into law while simultaneouslystriking certain spending items within the bill, particularly any new spending, any amount of discretionary spending, or any new limited tax benefit. Once a president had stricken the item,Congress could pass that particular item again. If the president then vetoed the new legislation,Congress could override the veto by its ordinary means, a two-thirds vote in both houses. InClinton v. City of New York , 524 U.S. 417 (1998), the U.S. Supreme Court ruled such alegislative alteration of the veto power to be unconstitutional.

Article II executive powers

War and foreign affairs powers

Perhaps the most important of all presidential powers is command of the United States armedforces as commander-in-chief . While the power to declare war is constitutionally vested inCongress, the president commands and directs the military and is responsible for planningmilitary strategy. The framers of the Constitution took care to limit the president's powersregarding the military; Alexander Hamilton explains this in Federalist No. 69:

 The President is to be commander-in-chief of the army and navy of the United

States. ... It would amount to nothing more than the supreme command and

direction of the military and naval forces ... while that [the power] of the British king

extends to the DECLARING of war and to the RAISING and REGULATING of fleets and

armies, all [of] which ... would appertain to the legislature.[18] [Emphasis in the

original.]

Congress, pursuant to the War Powers Resolution, must authorize any troop deployments longer than 60 days, although that process relies on triggering mechanisms that have never beenemployed, rendering it ineffectual.[19] Additionally, Congress provides a check to presidential

military power through its control over military spending and regulation.Along with the armed forces, the president also directs U.S. foreign policy. Through theDepartment of State and the Department of Defense, the president is responsible for the protection of Americans abroad and of foreign nationals in the United States. The presidentdecides whether to recognize new nations and new governments, and negotiates treaties withother nations, which become binding on the United States when approved by two-thirds vote of the Senate.

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Although not constitutionally provided, presidents also sometimes employ "executiveagreements" in foreign relations. These agreements frequently regard administrative policychoices germane to executive power; for example, the extent to which either country presents anarmed presence in a given area, how each country will enforce copyright treaties, or how eachcountry will process foreign mail. However, the 20th century witnessed a vast expansion of theuse of executive agreements, and critics have challenged the extent of that use as supplanting thetreaty process and removing constitutionally prescribed checks and balances over the executivein foreign relations. Supporters counter that the agreements offer a pragmatic solution when theneed for swift, secret, and/or concerted action arises.

 Administrative powers

The president is the chief executive of the United States, putting him at the head of the executive branch of the government, whose responsibility is to "take care that the laws be faithfullyexecuted." The executive branch has over four million employees, including members of themilitary.[20]

Presidents make numerous executive branch appointments: an incoming president may make up

to 6,000 before he takes office and 8,000 more during his term. Ambassadors, members of theCabinet, and other federal officers, are all appointed by a president with the "advice and consent"of a majority of the Senate. Appointments made while the Senate is in recess are temporary andexpire at the end of the next session of the Senate.

The power of a president to fire executive officials has long been a contentious political issue.Generally, a president may remove purely executive officials at his discretion.[21] However,Congress can curtail and constrain a president's authority to fire commissioners of independentregulatory agencies and certain inferior executive officers by statute.[22]

The president possesses the ability to direct much of the executive branch through executiveorders. To the extent the orders are grounded in federal statute or executive power granted in theU.S. Constitution, these orders have the force of law. Thus, executive orders are reviewable by

federal courts or can be rendered null through legislative changes to statute.

 Juridical powers

The president also has the power to nominate federal judges, including members of the UnitedStates courts of appeals and the Supreme Court of the United States. However, these nominationsdo require Senate confirmation. Securing Senate approval can provide a major obstacle for  presidents who wish to orient the federal judiciary toward a particular ideological stance. Whennominating judges to U.S. district courts, presidents often respect the long-standing tradition of Senatorial courtesy. Presidents may also grant pardons and reprieves, as is often done just beforethe end of a presidential term.

Historically, two doctrines concerning executive power have developed that enable the president

to exercise executive power with a degree of autonomy. The first is executive privilege, whichallows the president to withhold from disclosure any communications made directly to the president in the performance of executive duties. George Washington first claimed privilegewhen Congress requested to see Chief Justice John Jay's notes from an unpopular treatynegotiation with Great Britain. While not enshrined in the Constitution, or any other law,Washington's action created the precedent for the privilege. When Richard Nixon tried to useexecutive privilege as a reason for not turning over subpoenaed evidence to Congress during theWatergate scandal, the Supreme Court ruled in United States v. Nixon, 418 U.S. 683 (1974), that

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executive privilege did not apply in cases where a president was attempting to avoid criminal prosecution. When President Bill Clinton attempted to use executive privilege regarding theLewinsky scandal, the Supreme Court ruled in Clinton v. Jones, 520 U.S. 681 (1997), that the privilege also could not be used in civil suits. These cases established the legal precedent thatexecutive privilege is valid, although the exact extent of the privilege has yet to be clearlydefined. Additionally, federal courts have allowed this privilege to radiate outward and protectother executive branch employees, but have weakened that protection for those executive branchcommunications that do not involve the president. [23]

President George W. Bush delivering the 2007 State of the Union Address, with Vice

President Cheney and Speaker of the House Pelosi behind him.

The state secrets privilege allows the president and the executive branch to withhold informationor documents from discovery in legal proceedings if such release would harm national security.Precedent for the privilege arose early in the 19th century when Thomas Jefferson refused torelease military documents in the treason trial of Aaron Burr  and again in 1876 in Totten v. United States, when the Supreme Court dismissed a case brought by a former Union spy.[24]

However, the privilege was not formally recognized by the U.S. Supreme Court until United States v. Reynolds (1953) where it was held to be a common law evidentiary privilege.[25] Beforethe September 11 attacks, use of the privilege had been rare, but increasing in frequency. [26] Since2001, the government has asserted the privilege in more cases and at earlier stages of thelitigation, thus in some instances causing dismissal of the suits before reaching the merits of theclaims, as in the Ninth Circuit's ruling in Mohamed v. Jeppesen Dataplan.[25][27][28] Critics of the privilege claim its use has become a tool for the government to cover up illegal or embarrassinggovernment actions.[29][30]

Legislative facilitator 

Representing the executive branch of government, the president cannot simultaneously hold aseat in Congress. Therefore, the president cannot directly introduce legislative proposals for consideration in Congress. The president, however, can take an indirect role in shapinglegislation, especially if the president's political party has a majority in one or both houses of Congress. For example, the president or other officials of the executive branch may draftlegislation and then ask senators or representatives to introduce these drafts into Congress. The president can further influence the legislative branch through constitutionally mandated, periodicreports to Congress. These reports may be either written or oral, but today are given as the Stateof the Union address, which often outlines the president's legislative proposals for the coming

year.According to Article II, Section 3, Clause 2 of the Constitution, the president may convene either or both houses of Congress. If both houses cannot agree on a date of adjournment, the presidentmay appoint a date for Congress to adjourn.

Ceremonial roles

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President Woodrow Wilson throwing out the ceremonial first ball on Opening Day,

1916

As head of state, the president can fulfill traditions established by previous presidents. WilliamHoward Taft started the tradition of throwing out the ceremonial first pitch in 1910 at GriffithStadium, Washington, D.C., on the Washington Senators' Opening Day. Every president sinceTaft, except for Jimmy Carter, threw out at least one ceremonial first ball or pitch for OpeningDay, the All-Star Game, or the World Series, usually with much fanfare.[31]

Other presidential traditions are associated with American holidays. Rutherford B. Hayes beganin 1878 the first White House egg rolling for local children.[32] Beginning in 1947 during theHarry S. Truman administration, every Thanksgiving the president is presented with a livedomestic turkey during the annual national thanksgiving turkey presentation held at the WhiteHouse. Since 1989 when the custom of "pardoning" the turkey was formalized by RonaldReagan, the turkey has been taken to a farm where it will live out the rest of its natural life.[33]

Presidential traditions also involve the president's role as head of government. Many outgoing presidents since James Buchanan traditionally give advice to their successor during the presidential transition.[34] Ronald Reagan and his successors have also left a private message onthe desk of the Oval Office on Inauguration Day for the incoming president.[35]

During a state visit by a foreign head of state, the president typically hosts a State ArrivalCeremony held on the South Lawn, a custom begun by John F. Kennedy in 1961.[36] This isfollowed by a state dinner given by the president which is held in the State Dining Room later inthe evening.[37]

6. British: Powers and constraints

When commissioned by the Sovereign, a potential Prime Minister's first requisite is to "form aGovernment" – create a cabinet of ministry that has the support of the House of Commons, of which they are expected to be a member. The Prime Minister then formally kisses the hands of his Sovereign, whose royal prerogative is thereafter exercised solely on the advice of the PrimeMinister and Her Majesty's Government ("HMG"). The Prime Minister has weekly audienceswith the Sovereign, whose functions are constitutionally limited "to advise, to be consulted, andto warn"; the extent of the Sovereign's ability to influence the nature of the Prime Ministerialadvice is unknown, but presumably varies depending upon the personal relationship between theSovereign and the Prime Minister of the day.

The Prime Minister will appoint all other cabinet members (who then become active PrivyCounsellors) and ministers, although consulting senior ministers on their junior ministers,

without any Parliamentary or other control or process over these powers. At any time, he mayobtain the appointment, dismissal or nominal resignation of any other minister; he may resign,either purely personally or with his whole government. The Prime Minister generally co-ordinates the policies and activities of the Cabinet and Government departments, acting as themain public "face" of Her Majesty's Government.

Although the Commander-in-Chief  of the British Armed Forces is legally the Sovereign, under constitutional practice the Prime Minister, with the Secretary of State for Defence whom he mayappoint or dismiss, holds power over the deployment and disposition of British forces, and the

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declaration of war. The Prime Minister can authorise, but not directly order, the use of Britain'snuclear weapons and the Prime Minister is hence a Commander-in-Chief in all but name.

The Prime Minister makes all the most senior Crown appointments, and most others are made byMinisters over whom he has the power of appointment and dismissal. Privy Counsellors,Ambassadors and High Commissioners, senior civil servants, senior military officers, members

of important committees and commissions, and other officials are selected, and in most casesmay be removed, by the Prime Minister. He also formally advises the Sovereign on theappointment of Archbishops and Bishops of the Church of England, but his discretion is limited by the existence of the Crown Nominations Commission. The appointment of senior judges,while constitutionally still on the advice of the Prime Minister, is now made on the basis of recommendations from independent bodies.

Peerages, knighthoods, and other honours are bestowed by the Sovereign only on the advice of the Prime Minister. The only important British honours over which the Prime Minister does nothave control are the Orders of the Garter , Thistle, and Merit; the Royal Victorian Order ; and theVenerable Order of Saint John, which are all within the "personal gift" of the Sovereign.

The Prime Minister appoints Ministers known as the "Whips", who use his patronage to

negotiate for the support of MPs and to discipline dissenters of the government parliamentary party. Party discipline is strong since electors generally vote for parties rather than individuals.Members of Parliament may be expelled from their party for failing to support the Governmenton important issues, and although this will not mean they must resign as MPs, it will usuallymake re-election difficult. Members of Parliament who hold ministerial office or political privileges can expect removal for failing to support the Prime Minister. Restraints imposed bythe Commons grow weaker when the Government's party enjoys a large majority in that House,or in the electorate. In general, however, the Prime Minister and their colleagues may secure theCommons' support for almost any bill by internal party negotiations with little regard toopposition MPs.

However, even a government with a healthy majority can on occasion find itself unable to pass

legislation. For example, on 31 January 2006, Tony Blair's Government was defeated over certain aspects of proposals to outlaw religious hatred, and, on 9 November 2005, was defeatedover plans which would have allowed police to detain terror suspects for up to 90 days withoutcharge. On other occasions, the Government alters its proposals in order to avoid defeat in theCommons, as Tony Blair's Government did in February 2006 over education reforms.[73]

Formerly, a Prime Minister whose government lost a Commons vote would be regarded asfatally weakened, and his whole government would resign, usually precipitating a generalelection. In modern practice, when the Government party has an absolute majority in the House,only the express vote "that this House has no confidence in Her Majesty's Government" is treatedas having this effect; dissentients on a minor issue within the majority party are unlikely to forcean election with the probable loss of their seats and salaries, and any future in the party.

Likewise, a Prime Minister is no longer just "first amongst equals" in HM Government; althoughtheoretically his Cabinet might still outvote him, in practice he progressively entrenches his position by retaining only personal supporters in the Cabinet. In periodical reshuffles, the PrimeMinister can sideline and simply drop from Cabinet the Members who have fallen out of favour:they remain Privy Counsellors, but the Prime Minister decides which of them are summoned tomeetings. The Prime Minister is responsible for producing and enforcing the Ministerial Code.