India, the United Kingdom, and Canada share a common institutional framework
rooted in the Westminster parliamentary system. With India and Canada being
former British colonies, their systems of governance have evolved in parallel
with, yet distinct from, that of the United Kingdom.
This paper examines the
electoral systems and democratic mechanisms of these countries, with a specific
focus on anti-defection laws, the debate around One Nation, One Election in
India, and the political maturity demonstrated through recent elections and
coalition formations. While all three countries are parliamentary democracies,
they differ significantly in constitutional enforcement, political culture, and
democratic resilience.
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Constitutional Frameworks and Electoral Systems
India's electoral and parliamentary systems are governed by a detailed written Constitution. Key provisions include:
- Article 324: Establishes the Election Commission of India (ECI).
- Article 83 and 172: Provide for the duration of Parliament and State Assemblies.
- Tenth Schedule: Anti-Defection Law introduced by the 52nd Constitutional Amendment Act, 1985.
- India uses the First Past the Post (FPTP) system. However, it faces challenges like defections and political coercion.
- The UK operates without a written constitution and uses FPTP. There is no anti-defection law; party discipline is maintained through conventions.
- Canada has a partly written constitution and uses FPTP. It does not have anti-defection laws but benefits from a political culture that discourages defections.
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Anti-Defection Laws and Political Switching
India's Tenth Schedule allows disqualification if a legislator voluntarily gives up party membership or disobeys the party whip.
Important Cases:
- Kihoto Hollohan v. Zachillhu (1992): Upheld Tenth Schedule; Speaker's decision subject to judicial review.
- Ravi S. Naik v. Union of India (1994): Defined 'voluntarily giving up membership'.
Despite the law, defections (e.g., Karnataka 2019, MP 2020, Maharashtra 2022) continue. India also witnessed a period of significant instability between 1996 and 1999 at the Centre, where short-lived governments were formed. The 11th Lok Sabha (1996) saw the fall of the BJP government after just 13 days, followed by the United Front governments under Deve Gowda and I.K. Gujral, which also could not complete their full terms. Eventually, fresh elections were held in 1998 and 1999, highlighting the challenges posed by coalition politics and the absence of strong anti-defection enforcement mechanisms.
In contrast, the UK and Canada permit floor-crossing but maintain stability through political norms and public accountability.
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One Nation, One Election – Feasibility and Federalism
India's proposal for simultaneous national and state elections argues for cost and administrative efficiency. However:
- Articles 172 & 174: Allow variable terms and dissolutions.
- Concerns include overshadowing regional issues and logistical barriers.
The UK and Canada do not implement synchronized elections; staggered elections preserve regional accountability.
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Political Maturity and Recent Elections
- India (2024): High turnout but marred by misuse of agencies and media bias.
- UK (2024): Labour's victory was smooth; no major allegations of manipulation.
- Canada (2025): Hung parliament resolved maturely; no horse-trading, reflecting democratic depth.
Conclusion
India, the UK, and Canada follow Westminster systems but differ greatly in
democratic practice. India's legalistic approach contrasts with the mature
political cultures of the UK and Canada. India can draw lessons in institutional
strengthening and political ethics to evolve into a more resilient democracy.
References:
- The Constitution of India – Articles 83, 172, 174, 324, and Tenth Schedule
- Kihoto Hollohan v. Zachillhu, AIR 1993 SC 412
- Ravi S. Naik v. Union of India, AIR 1994 SC 1558
- Election Commission of India reports (2024) – www.eci.gov.in
- UK Electoral Commission – General Election Results 2024 – www.electoralcommission.org.uk
- Parliament of Canada – Election Results 2025 – www.parl.ca
- Pratap Bhanu Mehta, 'The Crisis of Indian Democracy', Indian Express, 2024 – www.indianexpress.com
- Suhas Palshikar, 'Anti-Defection and the Hollowing of Democracy', EPW, 2022 – www.epw.in
- The Hindu, 'One Nation One Election: Debating its Merits', 2023 – www.thehindu.com
- Washington Post, 'Canada's Liberals Win 2025 Snap Polls', April 2025 – www.washingtonpost.com
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