Federal , seat of the
Chamber of Deputies and the
Federal Senate Some countries, such as
Argentina,
Australia,
Austria,
Belgium,
Bosnia and Herzegovina,
Brazil,
Canada,
Germany,
India,
Malaysia,
Mexico,
Nepal,
Nigeria,
Pakistan,
Russia,
Switzerland, and the
United States, link their bicameral systems to their
federal political structure. In the United States, Australia, Mexico, Brazil, and Nepal for example, each state or province is given the same number of seats in one of the houses of the legislature, despite variance between the populations of the states or provinces.
Australia , which contains a
House of Representatives and a
Senate The bicameral
Parliament of Australia consists of two Houses: the
lower house is called the
House of Representatives and the
upper house is named the
Senate. As of 31 August 2017, the lower house has 151 members, each elected from single-member constituencies, known as
electoral divisions (commonly referred to as "electorates" or "seats") using full-preference
instant-runoff voting. This tends to lead to the chamber being dominated by two major groups, the
Liberal/
National Coalition and the
Labor Party. The government of the day must achieve the confidence of this House to gain and hold power. The upper house, the Senate, is also popularly elected, under the
single transferable vote system of
proportional representation. There are a total of 76 senators: 12 senators are elected from each of the 6
Australian states (regardless of population) and 2 from each of the 2 autonomous internal territories (the
Australian Capital Territory and the
Northern Territory). This makes the total number 76, i.e. 6×12 + 2×2. In many respects, Australia is a unique hybrid with influences from the
United States Constitution, as well as from the traditions and conventions of the
Westminster system and some indigenous features. Australia is exceptional in this sense because the government faces a fully elected upper house, the
Senate, which must be willing to pass all its legislation. Although only the lower house, the House of Representatives, can hold a no-confidence vote against the government, in practice the support of the Senate is also necessary in order to govern. The Senate maintains the ability similar to that held by the British House of Lords, prior to the enactment of the
Parliament Act 1911, to block supply against the government of the day. A government that is unable to obtain supply can be dismissed by the
governor-general: however, this is generally considered a last resort and is a highly controversial decision to take, given the conflict between the traditional concept of confidence as derived from the lower house and the ability of the Senate to block supply (see
1975 Australian constitutional crisis). Many political scientists have held that the
Australian system of government was consciously devised as a blend or hybrid of the Westminster and the
United States systems of government, especially since the Australian Senate is a powerful upper house like the U.S. Senate; this notion is expressed in the nickname "the Washminster mutation". Unlike upper houses in most
Westminster parliamentary systems, the Australian Senate is vested with significant power, including the capacity to block legislation initiated by the government in the House of Representatives. This block can however be overridden in a
joint sitting after a
double dissolution election, at which the House of Representatives has the dominant numbers. As a result of proportional representation, the chamber features a multitude of parties vying for power. The governing party in the lower house rarely has a majority in the Senate, and so generally needs to negotiate with other parties and independents to get legislation passed. This variant of bicameralism has also been further explored by Tarunabh Khaitan, who coined the phrase "Moderated Parliamentarism" to describe a parliamentary system with several distinctive features: mixed bicameralism, moderated (but distinct) electoral systems for each chamber, weighted multipartisanship, asynchronous electoral schedules, and deadlock resolution through conference committees.
Canada , which contains a
House of Commons and a
Senate Canada's elected lower house, the
House of Commons, comprises Members of Parliament (MPs) from single-member "ridings" based mainly on population (updated every 10 years using Census data). The Commons is democratically elected every four years (constitutionally up to five years). In contrast, in
Canada's upper house, Senators are appointed to serve until age 75 by the
Governor General on the
advice of the
Prime Minister through an
Independent Advisory Board as of 2016. The government (i.e. executive) is responsible to and must maintain the confidence of the elected House of Commons. Although the two chambers formally have many of the same powers, this accountability clearly makes the Commons dominant—determining which party is in power, approving its proposed budget, and (largely) the laws enacted. The Senate primarily acts as a chamber of revision: it rarely rejects bills passed by the Commons but does regularly amend them; such amendments respect each bill's purpose, so they are usually acceptable to the Commons. The Senate's power to investigate issues of concern to Canada can raise their profile (sometimes sharply) on voters' political agendas.
Others In German, Indian, and Pakistani systems, the upper houses (the
Bundesrat, the
Rajya Sabha, and the
Senate respectively) are even more closely linked with the federal system, being appointed or elected directly by the governments or legislatures of each
German or
Indian state, or
Pakistani province. This was also the case in the United States before the
Seventeenth Amendment was adopted. Because of this coupling to the
executive branch, German legal doctrine does not treat the
Bundesrat as the second chamber of a bicameral system formally. Rather, it sees the
Bundesrat and the
Bundestag as independent constitutional bodies. Only the directly elected
Bundestag is considered the parliament. In the German
Bundesrat, the various
Länder have between three and six votes; thus, while the less populated states have a lower weight, they still have a stronger voting power than would be the case in a system based proportionately on population, as the
most populous Land currently has about 27 times the population of the
least populous. The Indian upper house does not have the states represented equally, but on the basis of their population. There is also bicameralism in countries that are not federations, but have upper houses with representation on a territorial basis. For example, in South Africa, the
National Council of Provinces (and before 1997, the
Senate) has its members chosen by each
province's legislature. In Spain, the
Senate functions as a
de facto territorially based upper house, and there has been some pressure from the
Autonomous Communities to reform it into a strictly territorial chamber. The
European Union maintains a somewhat close to bicameral legislative system consisting of the
European Parliament, which is elected in elections on the basis of universal suffrage, and the
Council of the European Union, which consists of one representative for each government of member countries, who are competent for a relevant field of legislation. Though the European Union has a highly unusual character in terms of legislature, one could say that the closest point of equivalency lies within bicameral legislatures. The European Union is considered neither a country nor a state, but it enjoys the power to address national Governments in many areas.
Aristocratic and post-aristocratic In a few countries, bicameralism involves the juxtaposition of democratic and aristocratic elements.
House of Lords of the United Kingdom The best known example is the British
House of Lords, which includes a number of
hereditary peers. The House of Lords is a vestige of the aristocratic system that once predominated in British politics, while the other house, the
House of Commons, is entirely elected. Over the years, some have proposed reforms to the House of Lords, some of which have been at least partly successful. The
House of Lords Act 1999 limited the number of hereditary peers (as opposed to
life peers, appointed by the
Monarch on the advice of the
Prime Minister) to 92, down from around 700. Of these 92, one is the
Earl Marshal, a hereditary office always held by the
Duke of Norfolk, one is the
Lord Great Chamberlain, a hereditary office held by turns, currently by
Baron Carrington, and the other 90 are
elected by all sitting peers. Hereditary peers elected by the House to sit as representative peers sit for life; when a representative peer dies, there is a by-election to fill the vacancy. The power of the House of Lords to block legislation is curtailed by the
Parliament Acts 1911 and 1949. Peers can introduce bills except Money Bills, and all legislation must be passed by both
Lords Spiritual and
Houses of Parliament. If not passed within two sessions, the
House of Commons can override the Lords' delay by invoking the
Parliament Act. Certain legislation, however, must be approved by both Houses without being forced by the Commons under the
Parliament Act. These include any bill that would extend the time length of a Parliament, private bills, bills sent to the House of Lords less than one month before the end of a session, and bills that originated in the House of Lords. Life Peers are appointed either by recommendation of the Appointment Commission (the independent body that vets non-partisan peers, typically from academia, business or culture) or by Dissolution Honours, which take place at the end of every Parliamentary term when leaving MPs may be offered a seat to keep their institutional memory. It is traditional to offer a peerage to every outgoing Speaker of the House of Commons. Further reform of the Lords has been proposed; however, no proposed reforms have been able to achieve public consensus or government support. Members of the House of Lords all have an aristocratic title, or are from the
Clergy. 26 Archbishops and Bishops of the
Church of England sit as
Lords Spiritual (the
Archbishop of Canterbury,
Archbishop of York, the
Bishop of London, the
Bishop of Durham, the
Bishop of Winchester and the next 21 longest-serving Bishops). It is usual that retiring Archbishops, and certain other Bishops, are appointed to the
Crossbenches and given a life peerage. Until 2009, 12
Lords of Appeal in Ordinary sat in the House as the highest court in the land; they subsequently became justices of the newly created
Supreme Court of the United Kingdom. As of 16 February 2021, 803 people sit in the House of Lords, with 92 Hereditary Peers, 26 Lords Spiritual and 685 Life Peers. Membership is not fixed and decreases only on the death, retirement or resignation of a peer.
Japan's former House of Peers Another example of aristocratic bicameralism was the Japanese
House of Peers, abolished after
World War II and replaced with the present
House of Councillors.
Unitary states Many
unitary states like
Italy,
France, the
Netherlands, the
Philippines, the
Czech Republic, the
Republic of Ireland and
Romania have bicameral systems. In countries such as these, the upper house generally focuses on scrutinizing and possibly vetoing the decisions of the lower house.
Italian Parliament On the other hand, in
Italy the
Parliament consists of two chambers that have the same role and power: the
Senate (Senate of the Republic, commonly considered the
upper house) and the
Chamber of Deputies (considered the
lower house). The main difference among the two chambers is the way the two chambers are composed: the deputies, in fact, are elected on a nationwide basis, whilst the members of the Senate are elected on a regional basis: this may lead to different majorities among the two chambers because, for example, a party may be the first nationally but second or third in some regions. Considering that in the Italian Republic the Government needs to win confidence votes in both the chambers, it may happen that a Government has a strong majority (usually) in the Chamber of Deputies and a weak one (or no majority at all) in the Senate. This has led sometimes to legislative deadlocks, and has caused instability in the Italian Government.
Indirectly elected Upper Houses (France, Ireland, Netherlands) In some of these countries, the upper house is indirectly elected. Members of France's
Senate and Ireland's
Seanad Éireann are chosen by
electoral colleges. In Ireland, it consists of members of the lower house, local councillors, the
Taoiseach, and graduates of selected universities, while the Netherlands'
Senate is chosen by members of provincial assemblies (who, in turn, are directly elected).
Semi-bicameral (Hong Kong, Northern Ireland; earlier in Norway, the Netherlands) In
Hong Kong, members of the unicameral
Legislative Council returned from the democratically elected geographical constituencies and partially democratic
functional constituencies are required to vote separately since 1998 on motions, bills or amendments to government bills not introduced by the government. The passage of these motions, bills or amendments to government motions or bills requires double majority in both groups simultaneously. (Before 2004, when elections to the Legislative Council from the
Election Committee was abolished, members returned through the Election Committee vote with members returned from geographical constituencies.) The double majority requirement does not apply to motions, bills and amendments introduced by the
government. Another similar situation are
cross-community votes in
Northern Ireland when the
petition of concern procedure is invoked.
Norway had a kind of
semi-bicameral legislature with two chambers, or departments, within the same elected body, the
Storting. These were called the Lagting and the Odelsting, and were abolished after the general election of 2009. According to
Morten Søberg, there was a related system in the 1798 constitution of the
Batavian Republic. ==Examples of bicameralism in subnational entities==