Comparison of Australian and Canadian governments

Canada and Australia relations

Australia	Canada

There are a great many similarities between the countries of Canada and Australia. They are both fully-independent former settler colonies of Britain from which they have inherited their political traditions. Both nations are large, relatively isolated, and sparsely inhabited, and both use federal systems of government.

Canada, being the first of the colonies to peacefully gain independence, became a model that was followed by Australia and the other Dominions. Both were also affected by the same events in Britain and around the world: World War I, the creation of the shared monarchy in 1927, the Statute of Westminster in 1931, World War II, and the Cold War had similar effects on both nations.

Differences between the two nations' politics are ascribable to the existence of a French speaking population in Canada, which has no parallel in Australia, and the close proximity of the United States to Canada, which has a powerful influence on Canadian politics.

Federalism

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Unlike the United Kingdom, both Australia and Canada cover huge and sparsely populated territories. This made some sort of federalism a necessity. A previous history of division into separate colonies also created long-standing divisions. In Canada, the British North America Act of 1867 thus created strong provincial governments that are in no practical way subservient to the federal government. The Australian constitution of 1901 divided the new nation into several states with similar constitutionally-enshrined powers. Neither country had a bill of rights at first, although Canada adopted a statutory charter of rights in 1960 and a constitutional charter, the Canadian Charter of Rights and Freedoms, in 1982.

Both nations also have territories; these are areas with smaller populations whose governments have almost all of the responsibilities of state/provincial governments, but are fully under the control of the federal government.

Both have internal territories, but Australia, unlike Canada, has a number of external territories, small islands in the Pacific, Indian and Southern Oceans.

States and provinces

The Crown is represented in Australian states by a Governor, and in Canadian provinces by a Lieutenant-Governor. The appointed head of government, usually the leader of the party that commands a majority in the Legislative Assembly, is called the Premier in both Australia and Canada. In all Australian states except Queensland, the state parliament is bicameral with a lower and upper house. The self-governing territories, like Queensland, are also unicameral. All of the Canadian provinces' parliaments are now unicameral, Quebec being the last province to abolish its upper house in 1968.

The Governors of the Australian states are appointed directly by the Sovereign, on the advice of the Premier of that state. By contrast, the Lieutenant Governor of a Canadian province is appointed by the Governor General of Canada, acting on the advice of the federal Prime Minister; his or her salary is paid by the federal government. By loose convention, the Canadian Prime Minister is expected to consult with the respective provincial Premier prior to selecting a Lieutenant Governor, but he or she is under no obligation to do so. The Canadian Prime Minister could also advise the dismissal of a Lieutenant Governor at any time. These distinctions are significant, as they effectively leave the considerable vice-regal reserve powers over the Canadian provinces in the hands of the federal government. In the early years of Confederation, these powers were used on five occasions to dismiss provincial governments outright, although the last such use of the vice-regal reserve powers was in 1904.

Further information: Monarchy in the Canadian provinces

Under the Constitution of Australia, any residual powers are left to the states, while the Constitution of Canada leaves residual powers in the hands of the federal government. The reason for this discrepancy has its origins in the differing circumstances of Confederation (Canada) and Federation (Australia). In 1867 Canada faced a significant military threat from the United States, and many British and Canadian politicians blamed the concept of states rights for helping to trigger the then-recent American Civil War. Australia in 1901 did not face a similar military threat and its politicians were thus more comfortable in leaving residual powers with the states. Furthermore, rivalry existed between the states of Victoria and New South Wales, and the less populous states feared that a strong central Government would see too much power and influence wielded by Sydney and Melbourne. So the Australian states wanted to be explicitly granted wide powers in their own right.

Yet despite these constitutional differences, or perhaps because of them, the powers of Australian state governments are now far weaker than provincial governments in Canada, which still have considerable powers over both income and sales taxes. Australian state governments receive the vast majority of their income through block grants from the federal government in Canberra, and this lack of financial independence has led to a gradual erosion of state power. This situation has led to a claim that Australia is "over-governed", and some politicians have called for the outright abolition of the states, with powers to be instead divided between national and local (or regional) tiers of government. However, the states retain considerable power and influence and there is no practical likelihood of their abolition. Proposals to abolish the Canadian provinces, although not non-existent, are very unusual.

Many areas of responsibility that are jointly exercised by federal and state governments in Australia, such as education, are the sole responsibility of provincial governments in Canada. Australian states do have some powers that that the Canadian provinces do not - most notably, each Australian state enacts and amends its own criminal code while Canada has a uniform Criminal Code under federal jurisdiction.

Canadian Fathers of Confederation such as Sir John A. Macdonald did not intend to have provinces that were nearly as powerful as they have become. Strong provincial governments would only become entrenched when Britain's Judicial Committee of the Privy Council ruled jurisdictional disputes consistently in favour of the provinces starting in the 1870s. Another complicating factor in Canada is that the government of Quebec has gained control over immigration and other matters, which are not the responsibility of provinces in the rest of Canada. The existence of a powerful independence movement in Quebec has also been cited as a reason why the provinces in Canada have gained and maintained more jurisdiction than they were intended to have at Confederation.

Parliament

The Canadian Parliament Buildings on Parlement Hill in Ottawa.

Parliament House in Carberra.

The executive is all but identical with the British heritage of cabinet government kept intact, with the Prime Minister being the leader of the largest party in the Australian House of Representatives or Canadian House of Commons. In both countries, MPs represent single member constituencies, known as divisions in Australia and ridings in Canada.

Unlike Canada, which uses the first past the post voting system, Australia uses instant runoff voting (known in Australia as preferential voting) for almost all lower house elections and proportional representation for almost all upper house elections.

Australia has also introduced compulsory voting, something Canada has not done. There is no pressure to introduce such a measure in Canada, although poor electoral turnouts in the past two elections are beginning to make Canadians seriously consider some sort of electoral reform (while no major party wants mandatory voting, the New Democratic Party's platform indicates that they wish to lower the voting age to 16, something that reduced voter apathy in Brazil).

Canada and Australia both have strong multiparty systems with many parties represented in their legislatures as opposed to two (as in the United States). At the federal level, however, Canada's House of Commons tends to be more diverse than the Senate, while in Australia the reverse situation applies. This reflects the different means by which Members of Parliament are selected.

While both Canada and Australia have bicameral parliamentary systems, the composition of the upper house or Senate differs in each country. The Australian Senate is elected by single transferable vote, while the Canadian Senate is appointed by the Governor-General under the advice of Prime Minister. In Australia, each state has equal representation in the Senate, while in Canada, Senate seats are distributed between the regions of the country, not provinces. The Australian Senate also has great power to block money bills, unlike the weaker Canadian Senate, which it used in 1975, resulting in the constitutional crisis.

Since the 1990s, all Canadian parties elected to parliament with the exception of the Liberals have been pushing for some kind of reform of the Senate. Many politicians in the western provinces, such as Preston Manning of the (now defunct) Reform Party have advocated an Australian style, or 'Triple-E Senate– elected, equally representative of all regions, and effective, while others, such as the NDP and the Bloc Québécois call for outright abolition. Efforts for an elected Senate with term limits are currently underway by the governing Conservative Party. In a recent address to the Australian Parliament, in which he praised the country's elected Senate Prime Minister Stephen Harper stated that "Canadians understand that our Senate, as it stands today, must either change or– like the old upper houses of our provinces– vanish.". By contrast, while former Labor Prime Minister Paul Keating described the Senate as an 'unrepresentative swill', proposals for reform have focused on its ability to block legislation rather than its existence or composition.

Judiciary

The nations share a very similar judicial system based on British common law (except for civil matters in Quebec, where a French-style civil code applies). The highest courts of both nations are now domestic, with Canada doing away with appeals to the Judicial Committee of the Privy Council in 1949 and Australia doing the same in 1986.

However, the use by the Canadian federal courts of the Canadian Charter of Rights and Freedoms has begun to impact Canadian society in such matters as same-sex marriages and abortion. Australia has not enshrined similar rights and freedoms.

Monarchy

Elizabeth II is the head of state of both Australia and Canada, though her positions as Queen of Canada and Queen of Australia are legally separate; Elizabeth II cannot be advised on national affairs by anyone other than her ministers in the appropriate country, and when acting internally or abroad on the advice of said ministers, she does so as Queen of Canada or Queen of Australia, not as Queen of the United Kingdom. Both nations have a Governor-General who acts as a vice-regal representative. In 1931, King George V appointed the first Australian as Governor-General; Canada did not have a Canadian Governor General until 1953.

Canada discontinued the awarding of British honours to its citizens, establishing the Order of Canada in 1967, earlier than Australia, which introduced its own Order of Australia in 1975, and did not end the awarding of British honours until 1993. The Canadian monarch and Australian monarch, respectively, is sovereign of all Canadian and Australian national honours.

Polls in both countries over previous decades have shown shifts in the popularity of the monarchy, although to date, only Australia has held a national referendum on moving to a republican form of government, in 1999. Although some Canadian politicians, such as John Manley (described as "Canada's Paul Keating" have expressed support for ending the monarchy, it is not the policy of any of the three main federal parties.

Owing to the federal nature of both countries' constitutions, any constitutional change regarding the monarchy would require the consent of each country's states or provinces. In Australia, such a change requires both a majority of those voting throughout the country, and separate majorities in a majority of the states. In Canada changes to the monarchy require the assent of every province's legislature, unlike the usual amending forumla which requires the approval of only seven out of ten provinces representing at least 50% of the population.

Further information: Debate on the monarchy in Canada and Republicanism in Australia

Aboriginal peoples

Both Canada and Australia were inhabited long before European colonizers arrived. The First Nations and Inuit of Canada and the Aborigines of Australia were both devastated by European disease and other factors. In both areas, the Europeans went on to cruelly mistreat the native inhabitants.

The main difference between the experience of the two countries in this area centres around the concept of native title. In Canada, practically the whole country was acquire by British and later Canadian authorities from native peoples via treaties. The Crown recognized the prior claims of the indigenous peoples to the lands, and negotiated with them on that basis. Numerous treaties were signed that guaranteed that "registered Indians" would have Indian Reserves set aside for them, the freedom to hunt and fish on Crown Lands, and assistance payments to compensate for the loss of the land. First Nations decimated by smallpox or starving because of the dissapearence of the plains bison had little choice but to accept the glaringly unequal treaties, but have since benefited from the protections that the treaties contained, and made defence of their "treaty rights" the cornerstone of Native politics.

But contrast Australia was settled under the policy of terra nullius, or empty land. Indigenous Australians were not considered to have any title to Australia, and until recently had no treaty rights or reserved lands.

Conditions have improved, but in both countries the natives tend to be poorer and have shorter life expectancies than the national average. Australian treatment of Aborigines in the past was generally more systematically cruel than in Canada and life expectancy in Canada for aboriginal peoples is higher than in Australia.

In recent years Canada has accomplished a great deal in recognising land rights and the poverty gap between aboriginal Canadians and the rest of the population. Australia under the Bob Hawke and Paul Keating governments during the 1980s and early 1990s showed similar signs of reform. But more recently, Australia has somewhat reversed this trend. The government has abolished the self-governing panel ran by Aboriginals (ATSIC) citing corruption, not improving the quality of life for Australian Aboriginals, and empathises a desire that Aboriginal communities should be self-sufficient and maintain social standards on an individual basis. The Howard government also reversed some Native Title decisions, greatly reducing the impact of the scheme.

Many isolated Aboriginal communities in both Canada and Australia are characterised by near complete unemployment, multigenerational welfare dependence, domestic and social violence, drug and alcohol abuse including petrol sniffing or methamphetamine use, high crime rates and depression.

In 2007 Australian Prime Minister Kevin Rudd has issued formal symbolic apology to the Stolen Generations, children of mixed ancestry taken from their home comunities and raised in government bording schools. In 2008 Steven Harper, Prime Minster of Canada, apologized for the federal government's role in running Residential Schools which were desinged to sytematically destroy native languages and cultures and assimilate First Nations people into white society.

Immigration

Both Australia and Canada are nations built by immigrants, and they are both among the nations that receive the most immigrants per year. Attitudes differ substantially, however. Australia, like much of Europe, has seen an anti-immigration party, the One Nation Party, briefly gain broad support in some areas– something which has never happened in Canada. While One Nation's power quickly dissipated, its immigration policies were broadly copied by the federal Liberal-National Coalition which assisted its hold on power. However, the province of Quebec has strong opposition to immigrations. All 3 principal political parties have plans to assimilate and integrate immigrants in order to preserve the culture of Quebec. This is in completely opposition to the multiculturalism idea present in Canada. Furthermore, it is backed by 77% of the population of Quebec.

Welfare state

Australia and Canada both tend to fall somewhere in the middle between the United States and Europe in terms of how extensive a welfare state they have. Australia has a somewhat greater involvement of the private sector with the privatization of many government enterprises, and increasing emphasis on private education and health care systems with Australia having a two-tier healthcare system.

Canada, on the other hand, has a single-tier or single payer health care system, where almost all basic health costs are covered by the government without any private involvement or user fees (except through taxation). In fact, Canada is the only industrialized democracy in the world that flatly prohibits private health insurance for essential medical care.

War and peace

Neither Canada nor Australia have been to war on their own; rather, they have fought under the leadership of first Britain and then the United States and United Nations. The two nations are the most-commonly-cited examples of middle powers– states that try to pursue their interests through multilateralism and collective security because they are not large enough to act unilaterally.

Canada was founded in part because of threats of American invasion. The War of 1812, where Britain successfully defended its territories against American aggression, and was successful in burning Detroit and Washington, was a strong uniting force in Canada and sparked the creation of an independent federal state.

Both Australia and Canada were immediately and enthusiastically called to the defence of Britain in World War I. While Australia suffered larger per capita casualties, the armies from the two dominions were acknowledged as the best of the British army, and both nations won prestige and greater independence in the war in Europe. Both Australia and Canada emerged divided from the war because of similar crises concerning conscription, which in Australia set Anglo-Saxon Protestants against Catholics of Irish stock, and in Canada French-Canadians against English Canadians.

The Second World War was similar in regard to both nations again springing to the defence of Britain. Unlike Australia, Canada's political fabric was divided by the war– again for similar reasons in the Conscription Crisis of 1944. Conscription was not a major issue in Australia as the country was directly attacked by Japanese bombers. Although a Japanese invasion of North America was feared by many, Australia faced what was perceived to be a far more dire threat from the Japanese Empire. While Quebec emerged from the troubles as a more distinct entity from the rest of Canada, the government handled this crisis in an astute fashion, cooling off tensions in months and years instead of generations.

The beginning of the Cold War saw both sides align with the United States: Canada being a founding member of the North Atlantic Treaty Organization, and Australia signing the ANZUS treaty. Both nations sent troops to the Korean War on the UN side.

From that point on, however, the pattern seems to have diverged as Australia joined the United States in Vietnam and in the 2003 Invasion of Iraq—two conflicts Canada stayed away from. Much of this can be accredited to differing strategic dilemmas and to which governments were in power at the time the conflicts began. If the Conservatives had been in power in Canada in 2003, that nation may have joined the war in Iraq. If the Australian Labor Party had been in office, that country may very well have not gone to war, although this remains inconclusive considering the involvement of the British centre-left party and comments made by former Labor leader Kim Beazley.

External links

• "Canada and Australia" at the Canadian Encyclopedia
• "Study: Canada and Australia: A comparison of economic performance" at Statistics Canada
• 2004 Speech by Australian writer David Malouf, part of the LaFontaine-Baldwin Lecture on Canadian politics, discussing identity politics in Canada and Australia

See also

• Politics of Australia
• Politics of Canada
• Politics of Canada and the United States compared
• Politics of Australia and New Zealand compared