Irish vs. British Political Systems: Institutions Compared

Introduction: Two Islands, Two Political Traditions

The United Kingdom and Ireland have both enjoyed geographic separation from the continent of Europe, enabling both to develop unique political cultures and institutions. Ireland has been even more removed from the fray, having never been part of the Roman Empire and having been systematically resistant to the same invasions that affected England throughout much of their respective histories. However, the proximity between Ireland and England — and later the United Kingdom — has caused the two countries to be "intertwined politically, economically, and culturally for over 800 years" (The Republic and Politics of the Republic of Ireland 5). British hegemony has generally meant that Irish identity has been largely oppositional in nature.

Divergent trends have emerged in the political cultures and institutions of the United Kingdom and Ireland, especially with regard to the relative power of the Church. Ireland's political structures, institutions, and cultures have been inevitably influenced by the British system, but the Catholic Church has also penetrated the political sphere in Ireland to a great degree. As a result, the Irish political system exhibits some marked peculiarities that differentiate it from its British counterpart and from its counterparts in Europe as well. The Irish and British systems are generally similar in being modern democracies, but their procedural politics are substantially different, their respective political institutions differ in important ways, and their political cultures also diverge from one another.

Constitutional Foundations and Judicial Review

By the early twentieth century, Ireland had fully adopted most British parliamentary democratic institutions, albeit with important modifications. One such modification has been the evolution of the Irish constitution. The current Irish Constitution (Bunreacht na hÉireann, or the 1937 Constitution of Éire) dates from 1937. By contrast, the United Kingdom has never had a singular document it would call a constitution. Instead of a formal constitution outlining the systems, branches, forms, functions, and limitations of government, Britain relies on its system of common law and on traditions that have long been embedded in its society. While the British system may seem tenuous — even dangerous — its flexibility and pragmatism have proven it effective for nearly a thousand years (O'Neil). The British government and its political culture are not without formal documents, either. Tracing its heritage to groundbreaking texts such as the Magna Carta of 1215 and the Bill of Rights of 1689, the British parliamentary system remains a model of liberal democracy around the world.

Also referred to as the Westminster system, the British form of government had some influence on Irish political culture, procedures, and institutions. The most important procedural differences between the Irish and the British systems include the role of judicial review, the proportional representation–single transferable vote (PR-STV) system, and the use of the public referendum. Like the United States, Ireland embraces a system of judicial review, whereby the independent judiciary may strike down a law passed by the legislature. The United Kingdom has no such policy or procedure for judicial review; in fact, Parliament can effectively pass any law it likes unchallenged, and Parliament holds a much stronger role in government than it does in Ireland.

While the British system might seem to encourage tyranny and abuses of power, its strong and entrenched political culture builds in safeguards against gross injustices. Until recently, the most notable — if ironic — safeguard preventing unconstitutional or unjust legislation from being passed was the House of Lords (O'Neil). Britain has since changed its political system to accommodate some degree of judicial review. As of 2009, the United Kingdom has a Supreme Court, initially populated by members of the House of Lords and thereafter filled by appointment. Its powers are weak, limited, and rarely exercised, unlike those of the Irish court system. The Irish judiciary's power, role, and purpose in government is similar to that of the United States Supreme Court in that it provides a formal check on the legislative and executive branches. Both Ireland and the United Kingdom favor a common-law method of judicial proceedings rather than relying on statute-based law.

Structurally, the Irish and British governments share some elements in common but with key distinctions. The House of Lords is a relic of the past, its members undemocratically selected to represent the aristocracy or the elite, many serving for life. Some members — the Life Peers — are appointed by the Prime Minister. Others are selected on the basis of legal expertise, which is why the House of Lords had traditionally performed the function of judicial review in the absence of a formal Supreme Court. Since the formation of the UK Supreme Court in 2009, however, this judicial review tradition in the House of Lords has been superseded. A large number of members of the House of Lords were seated based on heredity alone.

Legislative Structures: Parliament and the Oireachtas

Ireland has no such tradition, but the Irish senate — the Seanad — offers the closest comparison. Like the House of Lords, the Seanad is not a democratically elected body. Its members are appointed by what can be considered elite or special-interest groups. Although heredity does not factor into Seanad membership as it does in the House of Lords, Seanad members are not directly elected by voters; rather, they are appointed or elected via an electoral college. As with the House of Lords, Seanad positions are divided between different types or methods of appointment. Some are directly elected by Trinity College graduates, underscoring the elitist elements in Irish society (The Republic and Politics of the Republic of Ireland 28). The majority of Seanad appointments come from specific commercial industries or vocational sectors — a tradition absent not just in Britain but in most other liberal democracies.

The appointment of industry representatives to the Seanad is a holdover from Catholic traditions. Known as a "corporatist system," the appointment of industry leaders to political positions affects issues such as trade regulations and labor policies (The Republic and Politics of the Republic of Ireland 21). Reflective of Catholic values, the policy is designed to balance the interests of capitalism with Catholic communitarian values (The Republic and Politics of the Republic of Ireland 21). No Seanad appointments are geographically based, just as no member of the House of Lords is. Unlike members of the House of Lords, however, Irish senators do not serve for life.

Both the British and the Irish legislative systems — Parliament and the Oireachtas, respectively — are bicameral with uneven power distribution between their two chambers. In both cases, the democratically elected house retains far greater political and authoritative power than the appointed house, ensuring democratic accountability. In the United Kingdom, the House of Commons is the primary legislative body; in Ireland it is the Dáil. Members of the House of Commons are known as Members of Parliament (MPs) and are directly elected from geographic constituencies. Members of the Dáil are called Teachta Dála (TDs) and are likewise linked to geographic constituencies.

The House of Commons and the Dáil both feature proportionate representation, but their similarities end there. The methods of electing MPs and TDs are radically different, as are the roles and functions they serve. Ireland employs an "exotic form of voting" known as proportional representation–single transferable vote (PR-STV), whereby voters can choose more than one candidate by listing them in order of preference (The Republic and Politics of the Republic of Ireland 81). The PR-STV system is more complex than the British method, which is referred to as first-past-the-post (FPTP), in which a single candidate wins the entire constituency outright.

Conclusion: Similarities, Differences, and Relative Strengths

Although the political system in Ireland borrows heavily from the Westminster model, it can hardly be called derivative. Many of Ireland's political institutions and procedures are wholly unique, reflecting the fusion of Irish religion, language, culture, and values with the demands of participation in the global market economy. The procedural politics are markedly different in Ireland versus the United Kingdom, especially with regard to voting methods and Ireland's PR-STV system. Irish political institutions have emulated those in England in certain respects — particularly the fused legislative and executive branch and a higher but weaker chamber composed of non-democratically elected officials. Yet Britain's model is majoritarian and Ireland's is not, a contrast that reflects the vastly different political cultures of the two neighboring countries.