Editing Prime minister (section)

==Cross-country comparative details==

===Titles===
[[File:Prime Minister Keir Starmer attends Armistice Day in Paris, France on 11 November 2024 - 25.jpg|thumb|British Prime Minister [[Keir Starmer]] and French Prime Minister [[Michel Barnier]] in Paris, 2024]]
In many cases, though commonly used, "prime minister" is not the official title of the office-holder. In the [[Constitution of Russia|Russian constitution]], the prime minister is titled ''Chairman of the government''. The Irish prime minister is called the {{lang|ga|[[Taoiseach]]}} (which is rendered into English as ''prime minister''), in [[Israel]] the prime minister is ''Rosh HaMemshalah,'' meaning "head of the government", and the Spanish prime minister is the [[Prime Minister of Spain|President of the Government]] ({{lang|es|Presidente del Gobierno}}). The head of government of the [[China|People's Republic of China]] is referred to as the [[Premier of the People's Republic of China|Premier of the State Council]].<ref>{{Cite web |title=laws |url=http://www.npc.gov.cn/zgrdw/englishnpc/Law/2007-12/13/content_1384048.htm |access-date=2025-01-22 |website=www.npc.gov.cn}}</ref>

Other common forms include [[president of the council of ministers]] (for example in Italy, {{lang|it|Presidente del Consiglio dei Ministri}}), President of the Executive Council, or [[Minister-President]]. In the Nordic countries the prime minister is called ''Statsminister'', meaning "Minister of State". In [[federation]]s, the head of government of a [[Federated state|federated entity]] (such as the [[Provinces and territories of Canada|province or territory of Canada]], the [[Provinces of Argentina|province of Argentina]] or the [[States of Brazil| state of Brazil]]) is most commonly known as the [[premier]], [[chief minister]], [[governor]] or [[minister-president]].{{cn|date=August 2023}}

It is convention in the English language to call nearly all national heads of government "prime minister" (or sometimes the equivalent term "premier"), except in cases where the head of state and head of government are one position (usually a presidency), regardless of the correct title of the head of government as applied in his or her respective country. The few exceptions to the rule are Germany and Austria, whose head of government's title is Federal [[Chancellor]]; Monaco, whose head of government is referred to as the Minister of State; and Vatican City, for which the head of government is titled the Secretary of State. A stand-out case is the president of Iran, who is not actually a head of state, but the head of the government of Iran. He is referred to as "president" in both the [[Persian language|Persian]] and English languages.

In non-Commonwealth countries, the prime minister may be entitled to the style of [[Excellency]] like a president. In some Commonwealth countries, prime ministers and former prime ministers are styled [[Honourable]] or [[Right Honourable]] associated with their position (the [[Prime Minister of Australia|prime minister of Australia]] or the [[Prime Minister of Canada|prime minister of Canada]], for example). In the United Kingdom, the prime minister and former prime ministers are also often styled [[Honourable]] or [[Right Honourable]]; however, this is not due to their position as head of government, but a [[Privilege (legal ethics)|privilege]] of being current members of [[His Majesty's Most Honourable Privy Council#Rights and privileges of members|His Majesty's Most Honourable Privy Council]].<ref name=PCpage25>{{cite web |url=http://www.privy-council.org.uk/output/Page25.asp |title=Privy Council Members |publisher=The Privy Council Office |access-date=19 September 2009 |url-status=dead |archive-url=https://web.archive.org/web/20090925163150/http://www.privy-council.org.uk/output/Page25.asp |archive-date=25 September 2009 }}</ref>

In the UK, where devolved government is in place, the leaders of the [[Scottish Government|Scottish]], [[Northern Ireland Executive|Northern Irish]] and [[Welsh Government|Welsh]] Governments are styled [[First Minister]]. Between 1921 and 1972, when Northern Ireland had a [[Parliament of Northern Ireland|majority rule Parliament]], the head of government was the [[Prime Minister of Northern Ireland|prime minister of Northern Ireland]]. In [[Bangladesh]], the prime minister is called ''Prodhān Montrī'', literally meaning "the head of ministers" or "prime minister".  In India, the prime minister is called ''Pradhān Mantrī'', literally meaning "the head of ministers" or "prime minister". In Pakistan, the prime minister is referred to as ''Wazir-e-Azam'', meaning "grand vizier".

===Constitutional basis for the position in different countries===
[[File:Macdonald1872.jpg|right|thumb|upright|[[John A. Macdonald]] (1815–1891), first [[Prime Minister of Canada|Canadian prime minister]]]]
[[File:Sirimavo Bandaranaike, Prime Minister of Ceylon 1960 (cropped).PNG|thumb|upright|[[Sirimavo Bandaranaike]] (1916–2000), former [[Prime Minister of Sri Lanka]] and the [[List of elected and appointed female heads of state and government|first female prime minister]]]]
[[File:Pitt the Younger.jpg|right|thumb|upright|[[Prime Minister of the United Kingdom|British prime minister]] [[William Pitt the Younger|William Pitt]] (1759–1806), the youngest head of government at the age of 24.]]
The position, power and status of prime ministers differ depending on the age of the constitution.

'''Algeria's''' [[Constitution of Algeria|constitution]] (1962) lists the powers, functions and duties of the [[Prime Minister of Algeria|prime minister of Algeria]].

'''Australia's''' [[Constitution of Australia|constitution]] makes no mention of a [[prime minister of Australia]] and the office only exists by convention, based on the British model.

'''Bangladesh's''' [[Constitution of Bangladesh|constitution]] clearly outlines the functions and powers of the [[Prime Minister of Bangladesh|prime minister]], and also details the process of his/her appointment and dismissal.

The '''People's Republic of China''' [[Constitution of the People's Republic of China|constitution]] set a [[Premier of the People's Republic of China|premier]] just one place below the [[National People's Congress]] in China. Premier read as ([[Simplified Chinese characters|Simplified Chinese]]: 总理; [[pinyin]]: Zŏnglĭ) in Chinese.

'''Canada''' has a 'mixed' or hybrid [[Constitution of Canada|constitution]], partly formally codified and partly uncodified. The codified part originally made no reference whatsoever to a prime minister<ref>''[https://laws-lois.justice.gc.ca/eng/Const/page-1.html Constitution Act, 1867]'' (U.K.), 30 & 31 Vict., c. 3. See also “Constitution Act, 1867,” in: Justice Canada, ed., ''A Consolidation of'' The Constitution Acts, 1867 to 1982, Government of Canada Catalogue № [https://laws-lois.justice.gc.ca/PDF/CONST_E.pdf YX1‑1/2012] (Ottawa: 2012), {{ISBN|9780660674582|}}, pp. 1–52.</ref> and still gives no parameters of the office. Instead, their powers, duties, appointment and termination follow uncodified conventions. The ''[[Constitution Act, 1867]]'' only establishes the [[Queen's Privy Council for Canada]], to which all federal ministers (among others) are appointed and with Members{{Efn|Which Members, though, are left to uncodified convention. As appointment to the Privy Council normally lasts for life, ''former'' Cabinet ministers predominate. The convention of [[Responsible Government]], however, requires the Governor General to only act on the advice of the current Cabinet (or its ministers relevant to the issue at hand).|name=|group=note}} of which the Monarch or their Governor General normally performs executive government (as [[King-in-Council|King- or Governor-in-Council]]).<ref>See ''[https://laws-lois.justice.gc.ca/eng/Const/page-1.html Constitution Act, 1867]'' (U.K.), 30 & 31 Vict., c. 3, Part 2 (§ 11 in particular). See also “Constitution Act, 1867,” in: Justice Canada, ed., ''A Consolidation of'' The Constitution Acts, 1867 to 1982, Government of Canada Catalogue № [https://laws-lois.justice.gc.ca/PDF/CONST_E.pdf YX1‑1/2012] (Ottawa: 2012), {{ISBN|9780660674582|}}, pp. 3–4.</ref> The ''[[Constitution Act, 1982]]'', adds passing reference to the "[[Prime Minister of Canada]]" [French: {{Lang|fr|premier ministre du Canada}}] but as detail of [[first ministers conference|conferences]] of federal and provincial [[first minister#Canada|first minister]]s.)<ref>''[https://laws-lois.justice.gc.ca/eng/Const/page-15.html#h-38 Constitution Act, 1982]'', Schedule B to the ''Canada Act 1982'' (U.K.), 1982, c. 11, §§ 35.1, 49. See also “Constitution Act, 1982,” in: Justice Canada, ed., [https://laws-lois.justice.gc.ca/PDF/CONST_E.pdf ''A Consolidation of'' The Constitution Acts, 1867 to 1982], Government of Canada Catalogue № YX1‑1/2012 (Ottawa: 2012), {{ISBN|9780660674582|}}, pp. 53–75 at 63, 68.</ref>

'''Czech Republic's''' [[Constitution of the Czech Republic|constitution]] clearly outlines the functions and powers of the [[Prime Minister of the Czech Republic|prime minister of the Czech Republic]], and also details the process of his/her appointment and dismissal.

'''France's''' [[Constitution of France|constitution]] (1958) lists the powers, functions and duties of the [[Prime Minister of France|prime minister of France]].

'''Germany's''' [[Basic Law of the Federal Republic of Germany|Basic Law]] (1949) lists the powers, functions and duties of the federal [[Chancellor of Germany (Federal Republic)|chancellor]].

'''Greece's''' [[Constitution of Greece|constitution]] (1975) lists the powers, functions and duties of the [[Prime Minister of Greece|prime minister of Greece]].

'''Hungary's''' [[Constitution of Hungary|constitution]] (2012) lists the powers, functions and duties of the [[Prime Minister of Hungary|prime minister of Hungary]].

'''India's''' [[Constitution of India|constitution]] (1950) lists the powers, functions and duties of the [[Prime Minister of India|prime minister of India]]. In India, prime ministerial candidates must be a member of parliament, i.e. of either the Lok Sabha (Lower House) or Rajya Sabha (Upper House). No parliamentary vote takes place on who forms a government.

'''Ireland's''' [[Constitution of Ireland|constitution]] (1937), provides for the office of [[Taoiseach]] in detail, listing powers, functions and duties.

'''Italy's''' [[Constitution of Italy|constitution]] (1948) lists the powers, functions and duties of the [[president of the Council of Ministers]].

'''Japan's''' [[Constitution of Japan|constitution]] (1946) lists the powers, functions and duties of the [[Prime Minister of Japan|prime minister of Japan]].

The '''Republic of Korea's''' [[Constitution of South Korea|constitution]] (1987) sections 86–87 list the powers, functions and duties of the [[Prime Minister of South Korea|prime minister of the Republic of Korea]].

'''Malta's''' [[Constitution of Malta|constitution]] (1964) lists the powers, functions and duties of the [[Prime Minister of Malta|prime minister of Malta]].

'''Malaysia's''' [[Constitution of Malaysia|constitution]] (1957) lists the powers, functions and duties of the [[Prime Minister of Malaysia|prime minister of Malaysia]].

'''Norway's''' [[Constitution of Norway|constitution]] (1814) lists the powers, functions and duties of the [[Prime Minister of Norway|prime minister of Norway]]

'''Pakistan's''' [[Constitution of Pakistan|constitution]] (1973) lists the powers, functions and duties of the [[Prime Minister of Pakistan|prime minister of Pakistan]].

'''Poland's''' [[Constitution of Poland|constitution]] (1918) lists the powers, functions and duties of the [[Prime Minister of Poland|prime minister of Poland]].

'''Spain's''' [[Spanish Constitution of 1978|constitution]] (1978) regulates the appointment, dismissal, powers, functions and duties of the [[Prime Minister of Spain|President of the Government]].

'''Sri Lanka's''' [[Constitution of Sri Lanka|constitution]] (1978) lists the powers, functions and duties of the [[Prime Minister of Sri Lanka|prime minister of Sri Lanka]].

'''Thailand's''' [[Constitution of Thailand|constitution]] (1932) lists the powers, functions and duties of the [[Prime Minister of Thailand|prime minister of Thailand]].

'''Taiwan's''' [[Constitution of the Republic of China|constitution]] (1946) lists the powers, functions and duties of the [[president of the Executive Yuan]].

The '''United Kingdom's''' [[Constitution of the United Kingdom|constitution]], being [[uncodified constitution|uncodified]] and largely unwritten, makes no mention of a [[Prime Minister of the United Kingdom|prime minister]]. Though it had ''[[de facto]]'' existed for centuries, its first mention in official state documents did not occur until the first decade of the twentieth century. Accordingly, it is often said "not to exist"; indeed there are several instances of parliament declaring this to be the case. The prime minister sits in the cabinet solely by virtue of occupying another office, either [[First Lord of the Treasury]] (office in commission) or more rarely [[Chancellor of the Exchequer]] (the last of whom was [[Arthur Balfour|Balfour]] in 1905).

:In such systems unwritten (and unenforceable) constitutional conventions often outline the order in which people are asked to form a government. If the prime minister resigns after a general election, the monarch usually asks the leader of the opposition to form a government. Where however a resignation occurs during a parliament session (unless the government has itself collapsed) the monarch will ask another member of the government to form a government. While previously the monarch had some leeway in whom to ask, all British political parties now elect their leaders (until 1965 the [[Conservative Party (UK)|Conservative]]s chose their leader by informal consultation). The last time the monarch had a choice over the appointment occurred in 1963 when the [[Alec Douglas-Home|Earl of Home]] was asked to become prime minister ahead of [[Rab Butler]].
During the period between the time it is clear that the incumbent government has been defeated at a general election, and the actual swearing-in of the new prime minister by the monarch, governor-general, or president, that person is referred to as the "prime minister-elect" or "prime minister-designate". Neither term is strictly correct from a constitutional point of view, but they have wide acceptance. In a situation in which a ruling party elects or appoints a new leader, the incoming leader will usually be referred as "prime minister-in-waiting". An example or this situation was in 2016 in the United Kingdom when [[Theresa May]] was elected leader of the [[Conservative Party (UK)|Conservative Party]] while [[David Cameron]] was still prime minister.

'''Russia's''' [[Constitution of Russia|constitution]] (1993) lists the powers, functions and duties of the [[prime minister of Russia]].

'''Ukraine's''' [[Constitution of Ukraine|constitution]] (1996) lists the powers, functions and duties of the [[Prime Minister of Ukraine|prime minister of Ukraine]].