Two systems, two ways to govern: How Westminster and presidential models organise power

When a newly elected legislature meets for the first time, the rituals that follow reveal how a country's democracy truly works.

In some nations, lawmakers gather only after being formally summoned by a monarch or ceremonial president who arrives with centuries-old pageantry to open the parliament. In others, legislators assemble automatically under the constitution, while a powerful president remains outside the chamber.

These contrasting scenes reflect two of the world's most influential systems of governance: the Westminster parliamentary model and the presidential system. 

Each structure of political power differs, especially in the relationship between the executive and the legislature, and those differences shape how governments function and how leaders are held accountable.

The Westminster system

The Westminster system originated in Britain and gradually spread across the Commonwealth. Today, it forms the foundation of governance in countries such as the UK, Canada, Australia, India, and Bangladesh.

The main principle is known as the fusion of powers. The executive branch, i.e., the cabinet, is drawn directly from the legislature.

This creates two distinct leadership roles.

The Head of State, a monarch or ceremonial president, represents the state symbolically and constitutionally. The prime minister, however, serves as the Head of Government and holds the real executive authority.

The Head of State's powers exist largely in a formal sense. They appoint the prime minister after elections, dissolve parliament when necessary and grant the final assent required for legislation to become law. Yet these powers are exercised almost entirely on the advice of the prime minister.

In practice, the Head of State functions as a constitutional referee, ensuring the democratic process continues while remaining politically neutral.

For the first assembly of the Westminster model, its workings are most visible when a newly elected parliament meets for the first time.

Following a general election, the Head of State issues a formal proclamation summoning Members of Parliament (MPs) to assemble on a specified date. Without this summon, the legislature technically does not begin its session.

Once MPs gather in the lower house, such as the House of Commons in the UK, the first order of business is electing the Speaker, the official responsible for presiding over debates and maintaining order.

Traditionally, the process is overseen by the "Father of the House" in British parliament, usually the longest-serving MP. A curious ritual accompanies the election: the newly chosen Speaker is often playfully dragged to the chair by colleagues, a reminder of an earlier era when Speakers sometimes faced execution for delivering parliament's unwelcome messages to monarchs.

After the Speaker takes the chair, MPs must swear an oath of allegiance to the Head of State or make a solemn affirmation before they can participate in parliamentary business.

'Speech from the Throne'

The ceremonial highlight of the opening session is the State Opening of Parliament.

The Head of State arrives at the legislature and delivers what is known as the "Speech from the Throne", or the King's, Queen's, or President's Speech.

Despite the grandeur of the occasion, the speech contains an important constitutional detail: it is not written by the Head of State.

Instead, it is drafted by the prime minister and the cabinet. The speech outlines the government's legislative agenda, listing the policies, budgets and laws the government intends to introduce during the parliamentary session.

Graphics: TBS

Because the government formally governs in the name of the Head of State, the speech includes phrases such as "My Government will introduce legislation…" or "My Ministers will focus on…".

The Head of State reads the speech in a neutral tone, reinforcing their role as a politically impartial figure.

After the ceremony ends, the chamber moves into political debate.

The first major discussion is the Debate on the Address, often called the Motion of Thanks. Lawmakers debate the policies outlined in the speech, and the opposition delivers its first critique of the new government.

The debate concludes with a vote. In Westminster systems, this vote often serves as an early test of confidence in the government.

If the government loses the vote, it signals that the prime minister no longer commands the support of the parliamentary majority. Such a defeat may force the government to resign or call another election.

This mechanism highlights a defining feature of the Westminster model: executive authority depends directly on parliamentary support.

What happens if a ceremonial president acts independently?

The Westminster system relies heavily on constitutional conventions. When those conventions are broken, a constitutional crisis can emerge.

If a ceremonial president refuses to follow the advice of the prime minister and attempts to act independently, parliament and the courts usually intervene.

The most immediate consequence may be impeachment or removal from office. In republics such as India or Bangladesh, the parliament can remove the president for violating constitutional norms.

The government may also challenge the president's actions in the Supreme Court, which typically rules in favour of the prime minister because the elected government carries the democratic mandate.

Some presidents use a delay tactic known as a "pocket veto", simply refusing to sign a bill immediately. While a president may send legislation back to parliament once for reconsideration, if parliament passes it again, the president is generally constitutionally obliged to sign it.

Only in rare circumstances, known as reserve powers, can a Head of State act independently. These powers may be used if a prime minister refuses to resign after losing parliamentary confidence or attempts an unconstitutional action that threatens democracy.

Even then, such interventions remain rare.

The presidential system

In contrast, countries such as the United States, Brazil and South Korea operate under a presidential system based on the principle of separation of powers.

In this model, the executive and legislature are elected independently and operate as separate branches of government.

The president holds a much more powerful position because they serve simultaneously as Head of State and Head of Government. They lead the executive branch, appoint cabinet members and direct government policy.

Unlike a prime minister in a parliamentary system, the president is not a member of the legislature, and cabinet ministers usually cannot hold legislative seats.

Because of this separation, the first meeting or the first assembly of a newly elected legislature looks very different.

The president's speech is not written by the president himself. Instead, it is drafted by the prime minister and the cabinet. The speech outlines the government's legislative agenda, listing the policies, budgets and laws the government intends to introduce during the parliamentary session.

Lawmakers do not need a summons from the president. Instead, they convene automatically on a constitutionally specified date.

Once assembled, they organise the chamber themselves by electing leaders such as the Speaker or Senate president. The executive branch plays no role in this process.

The legislature and executive, therefore, begin their terms independently of each other.

The president's speech and veto power

Presidential systems also feature major addresses to the legislature, such as the State of the Union in the United States.

Unlike the Westminster throne speech, this address is written by the president and their advisers and reflects the president's own political agenda.

The president does not summon lawmakers. Instead, the legislature invites the president as a guest to speak in its chamber.

Crucially, there is no vote of confidence tied to the speech. Even if the legislature rejects the president's proposals, the president remains in office for a fixed constitutional term.

Presidents also possess a powerful legislative tool: the veto. If the legislature passes a bill the president disagrees with, they can refuse to sign it. Lawmakers must then gather a supermajority, often two-thirds, to override the veto.

Bangladesh's parliamentary model

Bangladesh operates under a Westminster-style parliamentary system, though adapted to a republic with a written constitution. Its national legislature, the Jatiya Sangsad, is a unicameral parliament.

The president serves as ceremonial Head of State, while the prime minister exercises executive authority as Head of Government.

After a general election, the constitution requires the president to summon parliament within 30 days of the official publication of the results.

Bangladesh also differs slightly from the British tradition. Newly elected MPs usually take their oath before the first formal sitting, often administered by the Speaker of the outgoing parliament or the Chief Election Commissioner.

During the first session, MPs elect a Speaker and Deputy Speaker, after which the president delivers the President's Address, outlining the government's legislative priorities.

This address, like the throne speech in other Westminster systems, is written by the prime minister and cabinet. It is followed by a Motion of Thanks, which triggers a multi-day debate and a vote.

These procedures are unfolding at a significant moment in the country's politics.

Following the July 2024 uprising that removed Sheikh Hasina from power and the interim administration led by Muhammad Yunus, Bangladesh held its 13th general election on 12 February 2026.

Newly elected MPs were sworn in on 17 February 2026, with the oath administered by Chief Election Commissioner AMM Nasir Uddin due to the transitional circumstances. On the same day, BNP Chairman Tarique Rahman took the oath as prime minister.

President Mohammed Shahabuddin subsequently summoned the new parliament.

The first sitting of the 13th Jatiya Sangsad took place on 12 March 2026, when lawmakers elected their Speaker and debated the BNP-led government's agenda for the post-interim political era, facing an opposition led by Jamaat-e-Islami.