Why there is no such thing as the ‘Westminster model’

meg_russell_2000x2500.jpgRuxandra.Serban.crop.jpgPractitioners and academics in comparative politics frequently refer to a set of ‘Westminster model’ countries which are similar in some way. But in a new article, summarised here, Meg Russell and Ruxandra Serban show that definitions of the ‘Westminster model’ tend to be muddled, or even absent, and that its meaning is far from clear. Insofar as defined political attributes are linked to the ‘model’, key countries associated with it now lack many of those attributes. The term has hence become increasingly outdated, leading the authors to suggest that it should now be dropped.

The term ‘Westminster model’ appears frequently both in the academic and practitioner literature, and will be familiar to many specialists in comparative politics, public administration and law. But what precisely does it mean, and is there consistency in its application? Our new newly-published paper in the journal Government and Opposition, ‘The Muddle of the ‘Westminster Model’: A Concept Stretched beyond Repair’, addresses this question – based on analysis of the term in the academic literature over the last 20 years. It demonstrates that the use of the term has become extremely confused, leading us to suggest that it should be retired from academic and practitioner discourse.

Authors have often deployed the term ‘Westminster model’ as shorthand for the UK system of government which Bagehot outlined in the 1860s. Bagehot never used the term himself, but it appeared a century later in a classic text by De Smith on ‘Westminster’s export models’. Hence it therefore does not simply describe the British system, but other systems which were modelled upon it. Comparative texts for example often suggest that there is a group of ‘Westminster model countries’, ‘Westminster democracies’ or members of a ‘Westminster family’. The term received a more recent boost when used in the widely-cited comparative texts by Arend Lijphart (1984, 1999, 2012), which classify countries based on whether they have characteristics of ‘majoritarian’ or ‘consensus’ democracy. Lijphart used the term ‘Westminster model’ interchangeably with ‘majoritarian democracy’, and cited Britain as ‘both the original and the best-known example of this model’. Yet – at Lijphart’s own admission – his ideal type did not precisely apply in any country. For example, he associated unicameralism with majoritarian democracy, while Britain has a bicameral parliament.

The term hence has a long history, and since it was first adopted much in the world has changed. Our own casual observation suggested that scholars did not use the term consistently, to the extent that it might now provide more confusion than illumination. We thus set out to explore this systematically. Our study was inspired by the recommendation of another well-known comparative scholar, Giovanni Sartori, who strongly advocated clarity in political science concepts. In a classic 1970 article, Sartori introduced the notions of conceptual ‘travelling’ (across time and space), and conceptual ‘stretching’ (to enable a concept to remain relevant to increasingly disparate cases). The Westminster model certainly seems to have travelled, and its meaning also looks likely to have stretched. Sartori highlighted the relationship between the ‘extension’ of a term (to different cases), and its ‘intension’, defined as the ‘collection of properties which determine the things to which the [term] applies’. But widening a term’s extension may put the clarity of its meaning under strain.

In later work, Sartori proposed the rigorous testing of concepts and particularly the ‘reconstruction’ of those whose meaning may have become unclear. He suggested ‘reconstructing a concept from its literature’, by seeking out published definitions, exploring their characteristics, and seeing what could be learned from organising them systematically. Our study followed this suggestion. 

We used bibliographic databases to identify texts which used the term ‘Westminster model’ or various synonyms (‘Westminster system’, ‘Westminster democracy’ or ‘Westminster parliamentary democracy’) for the period 1999–2017. We also searched university reading lists for broad-based courses in comparative politics to identify core textbooks – which these database searches may have missed. Once irrelevant texts were excluded, this left 239 items in total, which were coded and analysed systematically.

Our first question was the extent to which the term ‘Westminster model’ (or synonyms) is in fact explicitly defined by the texts that use it. The result of this initial analysis was striking. Among the 239 texts, 71 (30%) used the term without defining it at all. These even included some texts which cited the term in their titles. Often the only clue to what the term might mean was the countries that the text went on to analyse (as further discussed below). We concluded that the phrase ‘Westminster model’ is often used in comparative works to imply presence of a well-defined sampling strategy, or that results are broadly generalisable when based on only a single country case, without any overt rationale for such a judgement being provided. Often the meaning of the term is simply taken as understood.

Table 1: Extent and type of definitions used in texts referring to the Westminster model

Type of definition Total
N %
No definition 71 30%
Implicit  90 38%
Partial definition 40 17%
Full definition 38 16%
TOTAL 239 100%

Beyond those texts omitting a definition, some included an ‘implicit’ definition. That is they lacked an explicit statement of meaning but nonetheless associated the term with certain attributes. Others provided a ‘partial’ definition, explicitly linking the term’s meaning to specified attributes, which might be few or with no indication of whether they comprised a complete list. Only 38 articles (16%) provided what we considered a ‘full’ definition — i.e. an explicit statement of meaning which was also explicitly complete. Many of these simply reproduced the list of 10 attributes associated with ‘majoritarian democracy’ by Lijphart.

Our next question, regarding the ‘intension’ of the term, explored which attributes authors associated with it, and the extent to which these were consistent. Obviously, this second part of the analysis applied only to the 168 texts which included a definition (either explicit or implicit). Here we found a wide variety of attributes associated with the ‘model’. Overall, the commonest (appearing in 28% of definitions) was possession of a first-past-the-post electoral system. In some cases, the ‘Westminster model’ was treated as virtually synonymous with this feature, as when one author stated that in Britain ‘the current method of election [is] by first-past-the-post in single-member constituencies (the Westminster model)’, and that this ‘Westminster Model is used in 62 countries’. Such an electoral system is closely linked to other features which were frequently cited in our texts – such as a two-party system and single-party majority governments.

The feature which might be expected to be most central in definitions of a ‘Westminster model’ is parliamentarism – i.e. the government being dependent on parliamentary confidence. Among the ‘implicit’ definitions (which on average cited just 1.9 attributes, compared to the 3 for ‘partial’ definitions and 5.1 for ‘full’ definitions), this was indeed the commonest attribute cited – albeit still only appearing in 26% of texts. Again, for some authors the ‘Westminster model’ was presented as synonymous with parliamentarism – as when one article suggested that Malaysia was ‘a Westminster democracy – which is also known as parliamentary democracy’. Given the centrality of parliamentarism to the UK system, and to many other countries associated with the ‘Westminster model’ it was perhaps surprising that this attribute didn’t feature more frequently. But this may be for a combination of reasons: first, that many authors assume that such an association is obvious, and second, that Lijphart rejected rigid boundaries between parliamentarism and presidentialism, and explicitly excluded parliamentarism from his definition.

Among texts including a ‘full’ definition, the commonest attribute (cited by 55%) was parliamentary sovereignty, and its corollary of an unwritten constitution. Meanwhile for public administration scholars the Westminster model was associated (or even synonymous) with a neutral civil service, while for other authors the term was associated with centralisation and the absence of federalism. Perhaps unsurprisingly, given Lijphart’s interventions, some texts associated the Westminster model with unicameralism and others with bicameralism.

Our third question related to the ‘extension’ of the term – i.e. the countries in which the ‘Westminster model’ is thought to apply. Here there was a very clear concentration, with the commonest countries being the UK (196 texts), Canada (77), Australia and New Zealand (both 67). Smaller numbers referred to India (13) Trinidad and Tobago (12), Jamaica (11), Guyana and Barbados (both 10) and Ireland (9), with 35 countries cited in total. Clearly all of those named here, having formally been under British rule, could be seen as having a Westminster ‘heritage’. But it is far more questionable what they have in common today. Returning to the attributes above, all of these countries are parliamentary democracies (but so are many others not associated with the model). Yet Australia, New Zealand, Guyana and Ireland do not use the first-past-the-post electoral system, only the UK wholly lacks a written constitution, and Canada, Australia and India have federal systems. New Zealand moved from bicameralism to unicameralism in 1952, causing Lijphart to note in his 1984 text that ‘[i]n nearly all respects, democracy in New Zealand is … a better example of the Westminster model, than British democracy’. However the country subsequently adopted a proportional electoral system in 1993 and this reference was removed from Lijphart’s later editions. As other authors have noted, the countries associated with the ‘Westminster model’ have, in short, become increasingly diverse. Our article explores whether they even meet the relatively weak requirements of a ‘family resemblance’ concept, and concludes that they do not.

Further examples and exposition can be found in our article. But we have shown, in summary, that the term ‘Westminster model’ is frequently used with little or no definition, is associated with numerous attributes, given varying weight by different authors, with no overwhelming central focus, and is associated with numerous countries, key exemplars of which display few of the clear attributes most commonly discussed. Lijphart’s work made the term synonymous, for many scholars, with an ideal-type majoritarianism. This in a sense injected new life, and a new precision, into an ageing and distinctly cloudy term. But ultimately it compounded the confusion, because Lijphart’s ideal type did not apply in any existing country, while some countries previously strongly associated with the ‘model’ did not share the attributes that he proposed. 

Language in political science and politics changes, and terms regularly fall out of use when they become outdated. The strongest argument for common bonds between ‘Westminster model’ countries is now one based on heritage, and hence possibly on culture. Yet continued use of the term to describe these countries, whose systems now radically differ, risks trapping them in a colonial past. Some scholars may want to compare systems with a shared British heritage, but they should make this attribute explicit, and justify why it matters. Meanwhile, we suggest, it is time for the ‘Westminster model’ to be retired.

This blog is a summary of the analysis and conclusions contained in ‘The Muddle of the ‘Westminster Model’: A Concept Stretched beyond Repair’, published in Government and Opposition

To mark the 25th anniversary of the Constitution Unit we have launched a special fundraising initiative, encouraging supporters to make donations incorporating the figures 2 and 5. If you value our work, and would like to contribute to its future continuation, please consider making a one-off or regular donation. Contributions are essential to supporting our public-facing work. Find out more on our donations page

About the authors

Professor Meg Russell is Director of the Constitution Unit. Her books include The Contemporary House of Lords (Oxford University Press, 2013) and Legislation at Westminster (Oxford University Press, 2017). She is currently a Senior Fellow with the UK in a Changing Europe, working on ‘Brexit, Parliament and the Constitution’.

Dr Ruxandra Serban is an LSE Fellow in Qualitative Methodology at the London School of Economics and Political Science.