the estimates, prepares a lengthy report, and finally after three or four months- writes out the text of a great loi de finance, or finance bill, incorporating the revised proposals. Then follows the discussion on the floor of the Chamber, first on the bill as a whole, and afterwards on the several articles considered one by one. There is entire freedom of debate; under certain minor restrictions, members may propose amendments, and the Chamber may make any number or kind of changes. While before the legislature, the budget consequently gets beyond the control of the government in a degree quite impossible in the English system, at all events prior to the adoption by the House of Commons of the new rule of 1919. Furthermore, there is no restraint analogous to the important English rule that no expenditures shall be authorized that are not asked by the executive.1 The changes made by Parliament are, indeed, more likely to augment the ministerial estimates of expenditure than to diminish them. As each article is disposed of, a vote on it is taken, and at the end the law is voted upon as a whole. As a rule, the budget is before the Chamber from three to four months after it is received from the committee. Upon its final passage there, the project goes back to the finance minister, who forthwith submits it to the Senate. By this time only a few weeks may remain before the law must take effect, so that consideration by the upper chamber is likely to be hurried. Precisely the same procedure as in the lower chamber is followed, however, and important changes are often introduced. When disagreements arise, the budget goes back and forth between the houses, and conference committees labor to reach an understanding. Only those points that are in dispute are reconsidered; and eventually a full agreement is arrived at. The completed law is published in full in the Journal Officiel; and, after being proclaimed by the president, it goes into operation on the first day of the new year. There is no question that the chambers have the power to reject a budget outright. They have never seriously threatened to do so, however, save on one occasion, i.e., at the time of the Seize Mai crisis in 1877.2

1 See p. 187.

See p. 445, note 3. The best account of French budget procedure and fiscal legislation, with much comparison with English, American, and other systems, is R. Stourm, Le budget, trans. by T. Plazinski as The Budget (New York, 1917). For brief accounts, not wholly up to date, see Bodley, France, II, 225-233, and Esmein, Eléments de droit constitutionnel (4th ed.), 833-857. The accounts of national revenue and expenditure are audited by a Cour des Comtes (Court of Accounts), which reports every year to the president and the Chamber of Deputies. Its members are appointed by the president for life. Its work resembles that of the office of Auditor General in Great Britain.

Control over the Government: the Parliamentary System.— The third main function of Parliament is the enforcement of the principle of ministerial responsibility, which at the least means a general watchfulness over the conduct of the executive and administrative officers, and, carried out literally and completely, as it is in France, means the ceaseless supervision of and interference in the routine of administrative work. The nature and effects of this control can best be made clear by some consideration of the workings of the French cabinet, or parliamentary, system.1 Ostensibly, France has a parliamentary system of government copied from, and substantially like, that of Great Britain. There is a politically irresponsible titulary of the executive power. The actual, working executive consists of the ministers. The ministers are responsible, collectively in general matters and individually in particular ones, to the chambers mainly to the Chamber of Deputies. When defeated on any important proposition, they resign as a body. The right of dissolution as a means of terminating conflicts between the executive and legislative departments is duly provided for.

In practice, parliamentary government in France means, however, something very different from what it means across the Channel. It presents an appearance such that some observers have been led to apply to it the designation "parliamentary anarchy," its outstanding characteristics being the instability of ministries, the frequency of ministerial crises, and the recurring conflicts between the chambers and the Government. From the middle of the nineteenth century to the outbreak of the Great War in 1914 England had but twelve prime ministers; France had as many between 1900 and 1914. From 1873 to 1914 England had but eleven different ministries; France had fifty. Between 1875 and 1900 only four years passed in the latter country without at least one change of ministry. Only four of the fifty ministries between 1873 and 1914 held power for a longer period than two years, and most of them were in office only a few months, the average tenure for the whole period being, indeed, less than eight months. It is of the essence of parliamentary government that the tenure of the ruling ministry shall be determined entirely by the continuance of good relations with the popular chamber. No ministry, even in England, has any

1 The term "cabinet system" is most commonly used in England, the term "parliamentary system" in France.

2 J. W. Garner, "Cabinet Government in France," in Amer. Polit. Sci. Rev., Aug., 1914, pp. 368-369.

definite assurance as to its lifetime. The statistics cited show, however, that in the latter country a ministry has a reasonable expectation of several years in which to carry out its policies. In France, a ministry can be morally certain that it will not last long. Following custom, it begins by issuing a "declaration " setting forth an extensive program of reforms; but it knows in its heart that it will never survive to fulfill any large part of its promises. The work of government tends to become a wearisome succession of starts and stops; great measures hang in the balance for years; politicians of mediocre ability - men who in England would not be considered fit for ministerial posts troop through the great offices in rapid succession.

Causes of Ministerial Instability. The reasons why the parliamentary system works so much less smoothly than in England are not difficult to discover. There is, of course, the underlying fact that whereas the system is in the one country a product of long evolution and adaptation, in the other it is an importation, imperfectly understood by those who a century ago brought it in, and never wholly suited to its new environment. Of more specific reasons for the failure of the system to work as in England, the most important is undoubtedly the condition of political parties. Beyond the Channel, while even before 1914 minor political groups had sprung up to complicate the situation, the political life of the nation has been largely confined to two great parties, each of which has had sufficient strength, if raised to power, to support a homogeneous and sympathetic ministry. In France, on the contrary, there is a multiplicity of parties, and no one of them ever finds itself in a position to operate the government alone. The election of 1910 sent to the Chamber of Deputies representatives of not fewer than nine distinct political groups. No ministry can be made up with any hope of being able to command a working majority in the Chamber unless it represents in its membership a coalition of several parties. A government so constituted, however, is almost certain to be vacillating and short-lived. It is unable to please all of the groups and interests upon which it depends; it dares displease none; it commonly ends by displeasing all.

A second cause of ministerial instability is Parliament's insistence upon the exercise of a close and continuous control over the ministers, not only in the shaping of policy, but in matters

1 There is no ministerial declaration, corresponding to the Speech from the Throne in England, at the opening of a parliamentary session. But a new ministry, whenever it comes in, offers a statement of principle and policy.

of administrative detail. In England, as has been pointed out, the cabinet leads and dominates in both legislation and administration. Parliament holds it to a general responsibility, but in practice allows it free scope, especially on the side of administration.1 The French parliament is content to play no such passive, trustful rôle. It displays a regrettable eagerness to dictate appointments and promotions, issue orders, and meddle generally in matters that do not properly concern it. "Not content with depriving the chief of state of his constitutional prerogatives and reducing him to the position of a figurehead, the French chambers insist upon throwing the ministers out upon trivial questions, and this notwithstanding the constitutional prescription that they shall be responsible only for their general policies." 2

The position occupied by French ministries is made the more precarious by the device of interpellation. As in the English parliament, every member of the two chambers has the right to put to a minister, in the presence of the chamber, a question designed to elicit information, providing the minister assents. Normally, the question is asked, a reply is given, the author of the question makes a rejoinder if he wishes (though no one else may do so), and the incident passes without debate; at all events, there is no vote. French usage permits, however, another practice, whose consequences extend much farther. This is interpellation. An interpellation is, similarly, a demand for information made by a member or group of members upon a minister. But in this case the consent of the minister is not asked, the demand is reduced to writing, the chamber fixes the day when it shall be put, and debate follows, with motions, serving to bring under challenge the general policy of the ministry, or at all events an act or policy of an individual minister. Frequently information is sought only as a pretext, the real object being to put the Government on the defensive and to maneuver it into a position where it can be defeated and compelled to resign. In short, the interpellation is, as has been stated, a challenge. It becomes the subject of a general debate, and it almost invariably leads to a vote of an "order of the day," which in its simplest form is a vote on the question whether the chamber, "approving the declarations of the Government," shall pass to the considera

1 Willoughby, Government of Modern States, 237-241; Esmein, Éléments de droit constitutionnel (4th ed.), 884-887.

2 Garner, loc. cit., 366.

Not more than one month distant unless the question relates to foreign affairs.

tion of other subjects that have been made the order for the day.' If this vote is affirmative, the ministry has weathered the storm, and nothing happens. But if it is negative, it is tantamount to an expression of want of confidence, and ordinarily there is nothing for the ministers to do save resign. As may be surmised, interpellation is a practice which readily lends itself to abuse, and ministries are often overthrown on mere technicalities or other matters inherently unimportant. The chambers have full power to restrict, or even to abolish, the system by amending their rules. But the right of interpellation is regarded by French authorities as an indispensable means of enforcing ministerial responsibility, and there is reluctance to place limitations upon it. Interpellation, as employed in France, is unknown in England. The statements of a minister in the House of Commons, made in answer to an interrogation, are allowed to become the subject of debate and the occasion of a vote only on request of forty members; and such requests are rarely made.2

A final cause of French ministerial instability is the practical ineffectiveness of the constitutional provision for parliamentary dissolutions. The power to dissolve the Chamber of Deputies is formally vested in the president, and would normally be exercised by the ruling cabinet. It is subject, however, to a restriction which has no parallel in England: a dissolution can take place only with the consent of the upper chamber. Furthermore, the dissolution which was carried out in 1877 was so unwise, if not actually unconstitutional, as to bring the practice into lasting disfavor. The consequence is that there has not been a dissolution since that date, and the power is for practical purposes obsolete. The effect of this is obvious. In England, when disagreement arises between the cabinet and Parliament the ministers may resign; but, on the other hand, they may dissolve Parliament, order a general election, win a parliamentary majority, and

1 For the numerous shades of praise or blame that an order of the day may be made to express see Lowell, Governments and Parties, I, 120-121.

See p. 180. Garner, loc. cit., 360-362; Lowell, Governments and Parties, I, 119-126; Esmein, Eléments de droit constitutionnel (4th ed.), 858-860; Dupriez, Les ministres, II, 439-445

For the circumstances see Bodley, France, I, 286-289, and for a fuller account, Hanotaux, Contemporary France, III, Chap. ix, IV, Chap. i. President MacMahon, himself a monarchist, arbitrarily dismissed the republican premier, Jules Simon, named the monarchist Duc de Broglie as his successor, and finding the Chamber of Deputies hostile, obtained the consent of the monarchist Senate to a dissolution. In the ensuing national elections the reactionary government systematically employed the methods used by Napoleon III to obtain a legislative majority. The new Chamber was, however, republican, and the formation of a republican cabinet by Dufaure brought the Seize Mai crisis to an end.