Pour appartenir à l’Union européenne, un régime démocratique appuyé par des institutions solides est un critère strict. Ce n’est cependant pas parce que des pays ont des institutions qui font les lois qui doivent refléter la volonté des citoyens que ces institutions sont similaires. C’est ce qu’illustrent la France et le Royaume-Uni quand on les compare.
Like France, the United Kingdom has a parliament composed of two distinct chambers. It can make, modify or suppress laws. It can also change the government. These two chambers are not equal: the House of Commons has the final say against the House of Lords when it comes to passing laws. The Commons is composed of directly elected members of Parliament who determine the government together, whereas the Lords don’t have that power.
So France and the UK seem to have the same model of parliamentary power: the House of Commons looks like the French National Assembly. There are however clear differences: first, the members of the Commons choose the secretaries and can be in the Cabinet whereas the French “députés” cannot; it is up to the French President to choose his Prime Minister and then he chooses the other ministers with the advice of his PM. A two-third majority is required in the French National Assembly to overthrow the government but the president can dissolve the National Assembly once in his term.
Whereas France has a presidential regime, the UK has a parliamentary regime: the House of Commons is the heart of politcal power; it has crushing power, contrary to the Assembly which has to deal with the Senate, the President and the French “Conseil Constitutionnel” when it passes laws. The Queen has in theory the power to nominate the Prime Minister and to prevent laws from passing (Royal Assent) but no sovereign has made such a decision since 1707.
So saying that France and the United Kingdom have a similar parliamentary power is a mistake, not to mention the difference between the House of Lords and the Senate. It would be more relevant to compare the French parliament to the US Congress. More similarities would probably be found…