Like much of the developing world in South Asia, Bangladesh continues to be run, for the most part, within a system of governance derived from the British colonial tradition. The so-called ‘Westminster’ parliamentary system, once considered the benchmark of democracy and political stability, has proven itself to be structurally weak and poorly suited to countries where democratic institutions have never truly taken root, where political accountability is minimal and where power is habitually hyper-centralised. In sharp contrast, the US constitutional framework holds crucial lessons on institutional independence, separation of powers and accountability. No system of governance is flawless, but the American constitutional order provides for stronger safeguards against unchecked concentrations of power and institutional mechanisms that more successfully guarantee executive accountability.
One of the paramount advantages of the American constitutional system is its distinct separation of the executive, legislative and judicial powers. The US President, Congress and Supreme Court constitute separate and independent constitutional organs of government. In a traditional Westminster parliamentary democracy, by contrast, the executive branch is implicitly controlled by a parliamentary majority. The Prime Minister and their cabinet are all elected members of Parliament, which means that a single political force often controls the legislative and administrative agenda. While this helps to make decision-making efficient, it compromises the autonomy of Parliament.
The US system creates a degree of separation between the lawmakers and executive administrators. Members of the US Congress do not typically hold cabinet positions. Most senior executive officials are appointed to their roles and may be subject to Senate confirmation, thereby establishing some level of vetting and accountability. The American culture of constitutional accountability and public scrutiny. Presidential nominees to senior posts, from cabinet members to judges to ambassadors to the chiefs of government agencies, must undergo a public vetting process during which they are tested by congressmen for their credentials, experience, integrity, ethics, and policy views. As a result, public servants recognise their accountability not just to elected politicians but also to constitutional structures and to the American citizenry as a whole.
Several mechanisms make it extremely difficult for any individual to dominate the entire state. Congressional investigative powers, public hearings, judicial review, and independent journalistic coverage all contribute to multiple tiers of accountability throughout the government. Many developing countries, sadly, lack such checks and balances. Ministerial portfolios are all too often distributed based on political loyalty, electoral calculations or internal factional calculations rather than any genuine consideration of technical and professional competence. Ministers are frequently appointed to portfolios without any serious or transparent evaluation of their qualifications and managerial capacity.
When political loyalty is allowed to substitute for expertise, governments are prone to implementation failures, administrative mismanagement, corruption, and long-term planning collapse. Public confidence in the state progressively decays, as bureaucratic dependence and erosion of professional standards grow. The American constitutional order additionally offers greater protections against the development of an authoritarian concentration of power.
US members of Congress may, by and large, probe the behaviour of the President and executive branch, may reject budget requests, may block presidential appointments, and can initiate impeachment procedures against the President or other senior officials. US federal courts retain the ability to review and overturn the actions of the President or the executive branch in cases when they are found to be contrary to the constitution. This creates substantial obstacles to an individual’s seizing all of the power of the state as a private matter. While the country certainly suffers from deep partisan divides, the structure of the American Constitution provides substantial protections against arbitrary rule.
The Westminster system itself is certainly not fundamentally flawed. Many parliamentary democracies, including the more advanced economies of Canada, Australia and New Zealand, provide for remarkably high standards of transparency, accountability and institutional integrity. But the political environment, organisational culture and governance context of such states are very different from those found in much of the developing world, including Bangladesh. The effectiveness of the Westminster model is highly contingent on well-developed democratic norms and robust institutions. As this is not the case in many developing countries, the Westminster system tends to be significantly less effective there.
As a result, many governments based on this system have failed to create meaningful accountability. An overwhelming centralisation of political authority, coupled with the weak organisational capacities of most developing country states, weakens the checks and balances inherent in a parliamentary democracy, making governments susceptible to arbitrary rule. Beyond the question of parliamentary versus presidential governance, a more significant challenge for countries like Bangladesh concerns how they may strengthen the effectiveness of their institutional frameworks.
Much more transparency and public accountability are needed, for example, in the selection and appointment of individuals to public and constitutional bodies, and to government institutions with significant regulatory and administrative responsibilities. As noted previously, the Westminster parliamentary system, in which ministerial appointments are almost exclusively drawn from elected members of Parliament, poses a particular constraint. It automatically excludes non-elected politicians from becoming cabinet members, thereby shutting out potentially crucial professional, technocratic, administrative and scientific expertise in such areas as economics, public health, or technological innovation. Moreover, an elected politician without specific experience or expertise in a policy domain can readily become a minister by virtue of holding a seat in Parliament.
In the contemporary context of nation-building and state-making, the primary criteria for ministerial appointments must move beyond electoral calculations and include, in a meaningful way, such attributes as competence, professional experience, expertise, integrity, and leadership potential. State institutions must be subordinate to constitutionality rather than the dictates of partisan loyalty. The office must be a vehicle for service and accountability, not for political privilege. Ultimately, the fundamental challenge for developing countries does not lie in simply picking a presidential or parliamentary form of government. It lies in the capacity of their constitutional institutions to be independent, strong and effectively accountable.
The systems of governance adopted from colonial times were originally conceived as instruments for colonial domination and administrative management, not as mechanisms for democratic self-governance. Modern states and the demands of democracy require constitutional organs capable of maintaining transparency, securing adherence to the rule of law and limiting the abuse of executive power.
The views expressed in this article are solely those of the author
The writer is a columnist and political analyst
