Germany is a democratic and social federal Nation with 16 states[ CITATION An10 \l 2057 ]. The government of Germany is structured in three independent arms (Executive, Legislature and Judiciary). The 16 states (Länder) are each governed by a parliamentary system (Land government). Members of the state legislature are elected directly by popular vote. A minister president appointed by the largest party or coalition of parties leads the Land government and appoints the state cabinet. The state governments are fairly independent from the federal government with the federal government playing more legislative roles and the state government mainly playing administrative role.
The executive power in the government of Germany is vested on the president and the Chancellor. As the head of state the president is largely ceremonial with limited responsibilities including representing the state in foreign affairs, signing of legislation into law, appointment of military officials, judges and senior civil servants and granting pardons. However all the presidential powers are exercised in consultation with the chancellor who heads the government. The president also proposes the chancellor candidate to the Bundestag; dissolves the Bundestag in case the government loses a motion of no confidence and declares the state of emergency. The Federal Convention which consists of representatives of the land is convened once every five years to elect the president by secret ballot. The chancellor on the other hand is elected by the Bundestag after the national elections which are held once every four years. The chancellor recommends the ministers for formal appointment by the president and is responsible for all government policies. The Bundestag cannot oust the chancellor by a simple vote of no confidence but can only do so by a constructive vote of no-confidence which requires that the Bundestag simultaneously agrees on a successor in order to remove the Chancellor[ CITATION An10 \l 1033 ].
Like in the UK and France the Germany’s parliament is bicameral with the Bundestag (lower house/ Federal Diet) and the Bundesrat (upper house/Federal council) as the legislative houses. Before becoming laws most laws must be approved by the two houses and the executive. When the two houses fail to agree on legislation the Joint Conference Committee resolves the stalemate. The Bundestag comprises of 672 members elected by the public. Unlike in the French National Assembly and the British House of Commons, the standing committees perform most of the legislative work of the Bundestag. The Bundestag elects the chancellor and provides checks on the executive. Conversely the Bundesrat comprises of 69 representatives of the state government appointed by their respective state governments. The number of members representing a state depends on the population of the state[ CITATION An10 \l 1033 ].
The Judiciary in Germany is independent with the lower level courts being under the Länder (only the courts of appeal are at the federal level). The judicial system is governed by principles of the Roman law which is different from the Anglo-Saxon law that guides the UK justice system. The judiciary is divided into the ordinary courts, specialized courts and the federal constitutional court. The three courts at the federal levels are the Federal Court of Justice (final appellate court for local court), the Federal Patents Court (deals with industrial property rights) and the Federal Constitutional Court (highest judicial body).
The electoral system in Germany mainly involves the election of Bundestag deputies (federal level), senate members (Landtag representatives) at the state (Land) level and council representatives at the district and local level. Hardly are executive officials elected by popular election except mayors in some municipalities. The elections of different officials are usually staggered. There are 328 electoral districts from which half the Bundestag members are elected. A unique element of the German electoral system is the 5% clause which requires a party to have at least 5% of the national vote or 3 constituency seats in order to be represented at the Bundestag. Germany also doesn’t hold by-election instead if the Bundestag seat falls vacant the next party candidate becomes the representative.
Like the German government, the French government is a social democracy with three arms. France is not a federal state but a unitary state though it is subdivided into regions, departments and communes for administrative purpose. The national government doesn’t interfere in matters of these sub units[ CITATION Rog11 \l 1033 ].
The executive power is shared between the president and the prime minister who is appointed by the president. Unlike in the German government, in France the president is head of the government and appoints all the ministers. The president is elected by popular vote after obtaining at least 50% votes at the first or second round voting. Unlike in Germany the Government may be removed by a simple censure motion. The president has the power to appoint and dismiss senior civil servants, constitutional office holders and military senior military officials. The executive is checked by the parliament and various independent agencies[ CITATION Rog11 \l 1033 ].
Like in Germany the France legislature is made up of two houses: the National Assembly (lower house) and the senate (upper) with the lower house being pre-eminent. The National Assembly is the main legislative body with 577 deputies elected at the local balloting every five years. The National assembly can oust the government by passing a censure motion. The senate has 346 members appointed by about 145,000 locally elected officials (Electoral College). The Senate serve for six years and has very limited legislative powers. Though, like in Germany, there is a joint commission which harmonizes the any law that the two houses disagree on, the National Assembly has the final say.
The Judiciary is independent and unlike in any other country is divided into the administrative and judicial stream. The latter deals with criminal and civil cases and comprises of inferior courts, intermediate appellate courts and the Supreme Court. The administrative courts on the other hand deal with cases against government agencies or offices and comprises of administrative courts, appellate administrative courts and the council of state. A unique element of the French judiciary is the constitutional council which rules on constitutionality of parliamentary acts referred to it by the National president, the senate or the National assembly president. In addition France also has audit courts at the national and regional levels that audit government finances[ CITATION Rog11 \l 1033 ].
Like in Germany the elections in France are staggered but also involve the election of the president which is not the case in Germany. The French electoral system encourages as many parties as possible and if a presidential candidate gets over 50% of the votes he or she becomes the president otherwise the two top candidates face each other in a second round. The public also elect the members of the National assembly but on a different day from the day the president is elected[ CITATION Rog11 \l 1033 ].
2.0 United Kingdom
Unlike both Germany and France the UK is a constitutional monarchy with the queen as the head of state and the prime minister as the head of government. The UK has a devolved government encompassing Britain, Wales, Scotland and Northern Ireland. Each of these regions is semi-autonomous with its own executive, legislature and judiciary[ CITATION Dir10 \l 1033 ].
The executive power in the UK is vested on the Queen who delegates the power to the prime minister, cabinet ministers and the Northern Ireland executive and the assembly governments of Wales and Scotland. The Queen hardly participates in government directly but wields enormous powers including power to appoint and dismiss the government, declare war and can even bypass the parliament’s consent. The prime minister, who is the head of government and a member of the house of common from the major party, is appointed by the Queen. The prime minister appoints the ministers. Unlike in Germany and Like in France the government can be ousted by the parliament by a censure motion or a vote of no confidence. The Queen also appoints the first minister as the executive leader in Wales, Scotland and Northern Ireland. These executive leaders are proposed to the Queen by their respective parliaments and they appoint ministers.
Like in France and German the legislative powers in the UK are vested on two houses the House of Commons and House of Lords. The UK legislature is also devolved to the Scottish parliament, and Wales and Northern Ireland Assemblies. Members of the House of Commons (members of parliament) are elected to represent 650 constituencies. The House of Common is the major legislative body. The House of Lords is largely hereditary comprising the Lords Spiritual and Lords Temporal. The former Lords represent the established England churches and the latter are appointed and some inherit the position. The House of Lords review legislations from the House of Commons and propose amendments. The UK , like France and unlike German, is a unitary state[ CITATION Dir10 \l 1033 ].
The Judiciary in the UK is complicated by the fact that the UK is an amalgam of previously independent countries, thus the UK has three different legal systems; the Northern Ireland law, the English Law and the Scots law. The Supreme Court is the highest Court in the UK. The House of Lords also has judicial functions as the highest court for criminal and civil cases. The judiciary comprises of ordinary courts, the High courts, appellate court and the Supreme Court.
Unlike the German and France electoral system, the UK uses various electoral systems due to the semi-autonomy of England, Wales, Northern Ireland and Scotland. The general elections of MPs and election of some local authorities in England and Wales are carried out through the first-past-the-post system. In this system the person with the simple majority wins the election. The bloc vote system is as used in some England and Wales Local authority elections. In deed these are just two of the about six electoral systems applied in the various UK regions. Unlike in France and Like in Germany the UK electorates do not elect the executive officials.
The basic government Structures of Germany, France and the UK are only similar in the fact that they have three branches, bicameral parliament and two centres of executive authority. While Germany is a federal state the UK and France are unitary states with the UK having a constitutional monarchy. The Judiciary is fairly similar in the three countries but the France Judiciary has two very distinct branches and the UK Judiciary mingles with the legislature through the House of Lords which forms the highest Court in criminal and civil matters. The electoral systems in the three countries differ significantly with the UK using about six distinct electoral systems.
An. Germany-Government and Politics. 20 February 2010. 1 May 2011
Direct.gov. Overview of the UK system of government. 23 Febuary 2010. 2 May 2011
Stevenson, Roger. "French Politics - The Electoral System." French Accent 10 February 2011: 16.