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行政機関において、政府の長は、主権国家、連邦国家、自治地域、属領、自治植民地、またはその他の政府における最高位または2番目に高い地位にある官僚であり、多くの場合、行政部門を率いる大臣や長官のグループである内閣を統括する。
外交においては、「政府首脳」は「国家元首」と区別される。[ 1 ] [ 2 ] [ 3 ] [ 4 ]
大統領、首相、総理大臣といった政府首脳の権限、およびその地位と他の国家機関との関係（例えば、国家元首と立法府との関係）は、主権国家によって大きく異なり、主に選択、獲得、あるいは長年にわたって発展してきた特定の政府制度に依存する。
立憲君主制を含むほとんどの議会制国家では、政府の長は事実上の政治的指導者であり、少なくとも議会の一方の議院に対して責任を負う。国家元首への正式な報告関係はしばしば存在するが、国家元首は通常、政府長から憲法上の助言を受けたり、憲法の特定の規定に基づいている場合など、限られた場合に最高行政官の役割を果たす名目上の存在として行動する。[ 5 ]
大統領制共和国や絶対君主制では、国家元首は通常、政府の長も兼任する。[ 6 ]しかし、その指導者と政府の関係は、その国の憲法（またはその他の基本法）によって、権力分立から独裁制まで大きく異なる可能性がある。理論的には、儀礼的な国家元首が別個の大統領制が存在することはあり得るが、実際にはそのような制度は存在しない。イスラエルは1990年代にそのような制度の導入を検討したが、立法過程において、直接選挙で選出された首相が議会の信任を維持する必要があるという要件が導入された。
In semi-presidential systems, the head of government may answer to both the head of state and the legislature with the specifics provided by each country's constitution.[7] A modern example is the present French government, which originated as the French Fifth Republic in 1958. In France, the president, the head of state, appoints the prime minister, who is the head of government. However, the president must choose someone who can act effectively as an executive, but who also enjoys the support of France's legislature, the National Assembly, to be able to pass legislation.
In some cases, the head of state may represent one political party but the majority in the National Assembly is of a different party. Given that the majority party has greater control over state funding and primary legislation, the president is in effect forced to choose a prime minister from the opposition party to ensure an effective, functioning legislature. In this case, known as cohabitation, the prime minister, along with the cabinet, controls domestic policy, with the president's influence largely restricted to foreign affairs.
In communist states, the general secretary of the Communist Party is the supreme leader, serving as de facto head of state and government. In China, the de jure head of government is the Premier. The Chinese president is legally a ceremonial office, but the general secretary of the Chinese Communist Party (top leader in a one-party system) has always held this office since 1993 except for the months of transition.[8][9]
In directorial systems, the executive responsibilities of the head of government are spread among a group of people. A prominent example is the Swiss Federal Council, where each member of the council heads a department and also votes on proposals relating to all departments.
The most common title for a head of government is Prime Minister. This is used as a formal title in many states, but may also be an informal generic term to refer to whichever office is considered the principal minister under an otherwise styled head of state, as minister—Latin for servants or subordinates—is a common title for members of a government (but many other titles are in use, e.g. chancellor and secretary of state). Formally the head of state can also be the head of government as well (ex officio or by ad hoc cumulation, such as a ruling monarch exercising all powers himself) but otherwise has formal precedence over the head of government and other ministers, whether he is their actual political superior (ruling monarch, executive president) or rather theoretical or ceremonial in character (constitutional monarch, non-executive president). Various constitutions use different titles, and even the same title can have various multiple meanings, depending on the constitutional order and political system of the state in question.
In addition to prime minister, titles used for the democratic model, where there is an elected legislative body checking the head of government, include the following. Some of these titles relate to governments below the national level (e.g. states or provinces).
In a broader sense, a head of government can be used loosely when referring to various comparable positions under a dominant head of state (especially is the case of ancient or feudal eras, so the term "head of government", in this case, could be considered a contradiction in terms). In this case, the prime minister serves at the pleasure of the monarch and holds no more power than the monarch allows. Some such titles are diwan, mahamantri, pradhan, wasir or vizier.
However, just because the head of state is the de jure dominant position does not mean that he/she will not always be the de facto political leader. A skilled head of government like 19th-century German statesman Otto von Bismarck, Minister President of Prussia and later Chancellor of Germany under Emperor/KingWilhelm I, serves as an example showing that possession of formal powers does not equal political influence. Alternatively, a de jure powerful head of state may have their power be de facto constrained by unwritten conventions, such as the monarch of the United Kingdom or the president of Austria.
In some cases, the head of state is a figurehead whilst the head of the government leads the ruling party. In some cases a head of government may even pass on the title in hereditary fashion. Such titles include the following:
In some models the head of state and head of government are one and the same. These include:
An alternative formula is a single chief political body (e.g., presidium) which collectively leads the government and provides (e.g. by turns) the ceremonial Head of state. The only state in which this system is currently employed is Switzerland but other countries such as Uruguayhave employed it in the past. This system is described as the directorial system.
See Head of state for further explanation of these cases.
In parliamentary systems, government functions along the following lines:
All of these requirements directly impact the head of government's role. Consequently, they often play a 'day to day' role in parliament, answering questions and defending the government on the 'floor of the House', while in semi-presidential systems they may not be required to play as much of a role in the functioning of parliament.
In many countries, the head of government is commissioned by the head of state to form a government, on the basis of the strength of party support in the lower house; in some other states, the head of government is directly elected by parliament. Many parliamentary systems require ministers to serve in parliament, while others ban ministers from sitting in parliament (they must resign on becoming ministers).
Heads of government are typically removed from power in a parliamentary system by
Constitutions differ in the range and scope of powers granted to the head of government. Some older constitutions – for example, Australia's 1900 text, and Belgium's 1830 text – do not mention their prime ministerial offices at all, the offices became a de facto political reality without a formal constitutional status. Some constitutions make a Prime Minister primus inter pares (first among equals) and that remains the practical reality for the Prime Minister of Belgium and the Prime Minister of Finland. Other states however, make their head of government a central and dominant figure within the cabinet system; Ireland's Taoiseach, for example, alone can decide when to seek a parliamentary dissolution, in contrast to other countries where this is a cabinet decision, with the Prime Minister just one member voting on the suggestion. In Israel, while the Government is nominally a collegiate body with a primus inter pares role for the Prime Minister, the Israeli Prime Minister is the dominant figure in the executive branch in practice.[10] The Prime Minister of Sweden, under the 1974 Instrument of Government, is a constitutional office with all key executive powers either directly at his or her disposal or indirectly through the collegial Government, whose members are all appointed and dismissed at the Prime Minister's sole discretion.
Under the unwritten British constitution, the prime minister's role has evolved, based often on the individual's personal appeal and strength of character, as contrasted between, for example, Winston Churchill as against Clement Attlee, Margaret Thatcher as against John Major. It is alleged that the increased personalisation of leadership in a number of states has led to heads of government becoming themselves "semi-presidential" figures, due in part to media coverage of politics that focuses on the leader and his or her mandate, rather than on parliament; and to the increasing centralisation of power in the hands of the head of government. Such allegations have been made against three former British Prime ministers: Margaret Thatcher, Tony Blair, and Boris Johnson. They were also made against Italian prime ministers Silvio Berlusconi and Matteo Renzi, Canadian prime minister Pierre Trudeau and Federal Chancellor of West Germany (later all of Germany), Helmut Kohl, when in power.
The head of government is often provided with an official residence, often in the same fashion as heads of state often are. The name of the residence is often used as a metonym or alternative title for 'the government' when the office is politically the highest, e.g. in the UK "Downing Street announced today…"
Well-known official residences of heads of government include:
Similarly, heads of government of federal entities below the level of the sovereign state (often without an actual head of state, at least under international law) may also be given an official residence, sometimes used as an opportunity to display aspirations of statehood:
Usually, the residence of the heads of government is not as prestigious and grand as that of the head of state, even if the head of state only performs ceremonial duties. Even the formal representative of the head of state, such as a governor-general, may well be housed in a grander, palace-type residence. However, this is not the case when both positions are combined into one:
In China, the political job that matters most is the general secretary of the Communist Party. The party controls the military and domestic security forces, and sets the policies that the government carries out. China's presidency lacks the authority of the American and French presidencies.
Mr. Xi's most important title is general secretary, the most powerful position in the Communist Party. In China's one-party system, this ranking gives him virtually unchecked authority over the government.