Head of state

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Head of state or Chief of State is the generic terms for the individual or collective office that serves as the chief public representative of a monarchic or republican nation-state, federation, commonwealth or any other political state. His or her role generally includes personifying the continuity and legitimacy of the state and exercising the political powers, functions and duties granted the head of state in the country's laws and constitution.

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Charles de Gaulle described the role he envisaged for the French president when he wrote the modern French constitution. He said the head of state should embody "the spirit of the nation" for the nation itself and the world: une certaine idée de la France (a certain idea about France). Today many countries expect their head of state to embody national values in a similar fashion.

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Constitutional models

Different countries have different executive systems but in essence four major, generalizing categories can be distinguished:
  1. the non-executive head of state system, in which the head of state does not hold any executive power and mainly plays a symbolic role on behalf of the state;
  2. the parliamentary system, in which the head of state possesses executive power but the exercise of this power is done on the advice of a cabinet;
  3. the presidential system, in which the head of state is also the head of government and actively exercises executive power; and,
  4. the semi-presidential system, in which the head of state shares exercise of executive power with a head of government.

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Non-executive heads of state

, President of Ireland, is an example of a non-executive head of state.]]

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One form that the head of state role takes can be loosely called the non-executive head of state model. Its holders are excluded completely from the executive: they do not possess even theoretical executive powers or any role, even formal, within the government. Hence their states' governments are not referred to by the traditional parliamentary model head of state styles of "His/Her Majesty's Government" or "His/Her Excellency's Government." Within this general category, variants in terms of powers and functions may exist. The King of Sweden, since the passage of the modern Swedish constitution (the Instrument of Government) in the mid 1970s, no longer has any of the parliamentary system head of state functions that had previously belonged to Swedish kings, but still receives formal cabinet briefings monthly in the royal palace. In contrast, the only contact the Irish president has with the Irish government is through a formal briefing session given by the Taoiseach (prime minister) to the President. However, he or she has no access to documentation and all access to ministers goes through the Department of An Taoiseach (prime minister's office).

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Examples of this category, invariably dating from the twentieth century, include: the President of Ireland, the King of Sweden (since 1975), the President of Germany, the President of Greece, the President of Israel, and the Emperor of Japan (since 1947).

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===Parliamentary system===, one of the world's best known and longest serving heads of state.]]

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In parliamentary systems the head of state may be merely the nominal chief executive officer of the state, possessing executive power (hence the description of the United Kingdom monarch's government as His/Her Majesty's Government; a term indicating that all power belongs to the sovereign and the government acts on Her Majesty's behalf, not parliament's). In reality however, due to a process of constitutional evolution, powers are usually only exercised by direction of a cabinet, presided over by a prime minister, or President of the Government, who is answerable to the legislature. This accountability requires that someone be chosen from parliament who has parliament's support (or, at least, not parliament's opposition - a subtle but important difference). It also gives parliament the right to vote down the government, forcing it either to resign or seek a parliamentary dissolution. Governments are thus said to be responsible (or answerable) to parliament, with the government in turn accepting constitutional responsibility for offering constitutional advice to the head of state.

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In parliamentary constitutional monarchies, the legitimacy of the unelected head of state typically derives from the tacit approval of the people via the elected representatives. Accordingly, at the time of the Glorious Revolution, the English Parliament acted of its own authority to name a new king and queen (joint monarchs Mary II and William III); likewise, Edward VIII's abdication required the passage of a law in the parliament of each of the Commonwealth realms, due to the independence of each country's monarchy in personal union. In monarchies with a written constitution, the position of monarch is a creature of the constitution, and could quite properly be abolished through a democratic procedure of constitutional amendment, although there are often significant procedural hurdles imposed on such a procedure (as in the Constitution of Spain).

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In reality, numerous variants exist to the position of a head of state within a parliamentary system. The older the constitution, the more constitutional leeway tends to exist for a head of state to exercise greater powers over government, as many older parliamentary system constitutions in fact give heads of state powers and functions akin to presidential or semi-presidential systems, in some cases without containing reference to modern democratic principles of accountability to parliament or even to modern governmental offices. For example, the 1848 constitution of the Kingdom of Italy was sufficiently ambiguous and outdated by the 1920s to give King Victor Emmanuel III leeway to appoint Benito Mussolini to power in controversial circumstances. Some Commonwealth parliamentary systems combine a body of written constitutional law, unwritten constitutional precedent, Orders-in-Council, letters patent, etc. that may give a head of state or their representative additional powers in unexpected circumstances (such as the dismissal of Australian prime minister Gough Whitlam by Governor-General Sir John Kerr.)

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Other examples of heads of state in parliamentary systems using greater powers than usual, due either to ambiguous constitutions or unprecedented national emergencies, include the decision by King Léopold III of the Belgians to surrender on behalf of his state to the invading German army in 1940, against the will of his government. Judging that his responsibility to the nation by virtue of his coronation oath required him to act, he believed that his government's decision to fight rather than surrender was mistaken and would damage Belgium. (Leopold's decision proved highly controversial. After World War II, Belgium voted on whether to allow him back on the throne. It did so, but because of the ongoing controversy he ultimately abdicated.)

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Presidential system

, the first president of the United States, set the precedent for an executive head of state in republican governments.]]Note: "presidential" in this context does not automatically imply a president but any head of state – elected, hereditary, or dictatorial – who presides. It is sometimes called the "imperial model," without regard for the monarchic title emperor, rather referring to the luster.

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Some constitutions or fundamental laws provide for a head of state who is not just in theory but in practice chief executive, operating separately from, and independent from, the legislature. This system is sometimes known as a "presidential system" because the government is answerable solely and exclusively to a presiding, acting head of state, and is selected by and on occasion dismissed by the head of state without reference to the legislature. It is notable that some presidential systems, while not providing for collective executive answerability to the legislature, may require legislative approval for individuals prior to their assumption of cabinet office and empower the legislature to remove a president from office (for example, in the United States of America). In this case the debate centres on the suitability of the individual for office, not a judgement on them when appointed, and does not involve the power to reject or approve proposed cabinet members en bloc, so it is not answerability in the sense understood in a parliamentary system.

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Some presidential systems may also include a prime minister, but, as with the other ministers, they are responsible to the president, not the legislature. In many such instances the office is of minimal political importance, sometimes even held by some administrative technocrat rather than a politician. A prime minister in a presidential system lacks the constitutional and political dominance of a prime minister in a parliamentary system and is often seen as simply a politically junior figure who may run the mechanics of government while allowing the president to set the broad national agenda.

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Presidential systems are a notable feature of constitutions in the Americas, including those of the United States, Brazil, and Mexico. Most presidents in such countries are selected by democratic means (popular direct or indirect election); however, like all other systems, the presidential model also encompasses people who become head of state by other means, notably through military dictatorship or coup d'état, as seen in South American, Middle Eastern, and other presidential regimes. Some of the characteristics of a presidential system (i.e., a strong dominant political figure with an executive answerable to them, not the legislature) can also be found among absolute monarchies, parliamentary monarchies, and Communist regimes, but in most cases of dictatorship apply their stated constitutional models in name only and not in political theory or practise.

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In the 1870s in the United States, in the aftermath of the impeachment of President Andrew Johnson and his near-removal from office, it was speculated that the United States, too, would move from a presidential system to a semi-presidential or even parliamentary one, with the Speaker of the House of Representatives becoming the real center of government as a quasi-prime minister. This did not happen and the presidency, having been damaged by three late nineteenth century assassinations (Lincoln, Garfield, and McKinley) and one impeachment (Johnson), reasserted its political dominance by the early twentieth century through such figures as Theodore Roosevelt and Woodrow Wilson.

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Semi-presidential systems

was responsible for establishing the semi-presidential system of France.]]Semi-presidential systems combine features of presidential and parliamentary systems, notably a requirement that the government be answerable to both the president and the legislature. The constitution of the Fifth French Republic provides for a prime minister who is chosen by the president, but who nevertheless must be able to gain support in the National Assembly. Should a president be of one side of the political spectrum and the opposition be in control of the legislature, the president is usually obliged to select someone from the opposition to become prime minister, a process known as Cohabitation. President François Mitterrand, a Socialist, for example, was forced to cohabit with the neo-Gaullist (right wing) Jacques Chirac, who became his prime minister from 1986 to 1988. In the French system, in the event of cohabitation, the president is often allowed to set the policy agenda in foreign affairs and the prime minister runs the domestic agenda.

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Other countries evolve into something akin to a semi-presidential system or indeed a full presidential system. Weimar Germany, for example, in its constitution provided for a popularly elected president with theoretically dominant executive powers that were intended to be exercised only in emergencies, and a cabinet appointed by him from the Reichstag, which was expected, in normal circumstances, to be answerable to the Reichstag. Initially, the President was merely a symbolic figure with the Reichstag dominant; however, persistent political instability, in which governments often lasted only a few months, led to a change in the power structure of the republic, with the president's emergency powers called increasingly into use to prop up governments challenged by critical or even hostile Reichstag votes. By 1932, power had shifted to such an extent that the German President, Paul von Hindenburg, was able to dismiss a chancellor and select his own person for the job, even though the outgoing chancellor possessed the confidence of the Reichstag while the new chancellor did not. Subsequently President von Hindenburg used his power to appoint Adolf Hitler as Chancellor without consulting the Reichstag.

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Single-party states

Since real political power belongs to the head of the sole legal party (often a communist party), in certain states under constitutions inspired by the former Soviet republics there was no formal office of head of state, but rather the head of the legislative "soviet" branch of power was considered the head of state. In the Soviet Union this office had names such as "Chairman of the Central Executive Committee of the USSR," "Chairman of the Presidium of the Supreme Council," as well as "Chairman of the Central Executive Committee of the All-Russian Congress of Soviets" in the case of Soviet Russia (until 1922).

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This may even lead to an institutional variability, as in North Korea, where, after the presidency of party leader Kim Il Sung, the office was vacant for years, the late president being granted the posthumous title (akin to some ancient far eastern traditions to give posthumous names and titles to royalty) of president "in eternity" (while all real power, as party leader, itself not formally created for 4 years, was inherited by his son Kim Jong Il, initially without any formal office) until it was formally replaced on September 5, 1998, for ceremonial purposes, by the office of the Chairman of the Presidium of the Supreme People's Assembly, while the party leader's post as Chairman of the National Defense Commission was simultaneously declared "the highest post of the state," not unlike Deng Xiaoping earlier in the People's Republic of China.

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Complications with categorisation

While clear categories do exist, it is sometimes difficult to choose which category some individual heads of state belong to. Constitutional change in Liechtenstein in 2003 gave its head of state, the Prince, constitutional powers that included a veto over legislation and power to dismiss the cabinet. It could be argued that the strengthening of the Prince's powers, vis-a-vis the legislature, has moved Liechtenstein into the semi-presidential category. Similarly the original powers given to the Greek President under the 1974 Hellenic Republic constitution moved Greece closer to the French semi-presidential model. And the power of the monarch of the Commonwealth realms to dismiss any of his or her governments at will would suggest that any of the realms should nominally belong to the semi-presidential category also. In reality, the category to which each head of state belongs is assessed not by theory but by practice. In practice no Commonwealth realms monarch has forced a government from office since the early nineteenth century, while, in reality, the Greek republic, even before the powers of the President of the Republic were curtailed in 1986, operated as a standard parliamentary system. Unless and until a Prince of Liechtenstein exercises the theoretical powers that office now possesses, the principality would still remain categorised as a parliamentary system.

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Another complication exists with South Africa, in which the President is in fact elected by the legislature (similar, in principle, to a prime minister) but also holds the title of President, serves for a fixed term, and is expected to be the nation's head of state. Nauru and Botswana are similar.

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Panama, during the military dictatorships of Omar Torrijos and Manuel Noriega, was nominally a presidential republic. However, the elected civilian presidents were effectively figureheads with real political power being exercised by the chief of the military.

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Roles of the head of state

Often depending on which constitutional category (above) a head of state belongs to, they may have some or all of the roles listed below, and various other ones.

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Symbolic role

, with Prince Philip, hanging in a Canadian courthouse.]]One of the most important roles of the modern head of state is being a living national symbol of the state; in monarchies this extends to the sovereign being a symbol of the unbroken continuity of the state. For instance, the Canadian monarch is described by the government as being the personification of the Canadian state, and is described by the Department of Canadian Heritage as the "personal symbol of allegiance, unity and authority for all Canadians." Buckingham Palace: The Queen and Commonwealth: Canada: The Queen's role in Canada

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In many countries, official portraits of the head of state can be found in government offices, courts of law, even airports, libraries, and other public buildings. The idea, sometimes regulated by law, is to use these portraits to make the public aware of the symbolic connection to the government, a practice that dates back to mediaeval times. Sometimes this practice is taken to excess, and the head of state begins to believe that he is the only symbol of the nation, resulting in the emergence of a personality cult where the image of the head of state is the only visual representation of the country, surpassing other symbols such as the flag, constitution, founding father(s) etc. A modern champion in this field was Adolf Hitler, the Nazi Führer. Other common iconic presences, especially of monarchs, are on coins, stamps, and banknotes; more discreet variations see them represented by a mention and/or signature. Furthermore, various institutions, monuments, and the like, are named for current or previous heads of state, such as streets and squares, schools, charitable and other organisations; in monarchies (e.g. Belgium) there can even be a practice to attribute the adjective 'royal' on demand based on existence for a given number of years. However such political techniques can also be used by leaders without the formal rank of head of state, even party - and other revolutionary leaders without formal state mandate.

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In general, the active duties amount to a ceremonial role. Thus in diplomatic affairs, heads of state are often the first person to greet an important foreign visitor. They may also assume a sort of informal host role during the VIP's visit, inviting the visitor to a state dinner at his or her mansion or palace, or some other equally hospitable affair.

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At home, they are expected to render luster to various occasions by their presence, such as by attending artistic or sports performances or competitions, expositions, celebrations, military parades and remembrances, prominent funerals, visiting parts of the country, enterprises, care facilities (often in a theatrical honour box, on a platform, on the front row, at the honours table etc.), sometimes performing a symbolic act such as cutting a ribbon or pushing a button at an opening, christening something with champagne, laying the first stone, and so on. Some parts of national life receive their regular attention, often on an annual basis, or even in the form of official patronage.

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As the potential for such invitations is enormous, such duties are often in part delegated: to such persons as a spouse, other members of the dynasty, a vice-president —for whom this is often the core of their public role— or in other cases (possibly as a message, for instance, to distance themselves without giving protocollary offence) just a military or other aide.

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For non-executive heads of state there is often a degree of censorship by the politically responsible government (such as the prime minister), discreetly approving agenda and speeches, especially where the constitution (or customary law) assumes all political responsibility by granting the crown inviolability (in fact also imposing political emasculation) as in the Kingdom of Belgium from its very beginning; in a monarchy this may even be extended to some degree to other members of the dynasty, especially the heir to the throne.

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Chief diplomatic officer

The head of state accredits his or her country's ambassador, High Commissioners or rarer equivalent diplomatic mission chiefs (such a a papal nuncio), through sending formal Letter of Credence to other heads of state and, conversely, receives the letters of their foreign counterparts. Without that accreditation, they cannot take up a role and receive the highest diplomatic status. However, there are provisions in international law to perform the same diplomatic functions, or at least part of them, such as accrediting, with a lower title with the head of government, or functioning within another mission.

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The head of state also signs international treaties on behalf of the state, or has them signed in his/her name by ministers (government members or diplomats); subsequent ratification, when necessary, usually rests with the legislature.

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In Canada, Australia and New Zealand, these roles of the head of state have been taken over by the vice-regal representative.

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:Example 1: Article 59 (1) of the Basic Law of the Federal Republic of Germany states:
::The Federal President shall represent the Federation in its international relations. He shall conclude treaties with foreign states on behalf of the Federation. He shall accredit and receive envoys.
:Example 2: Section 2, Article 81 of the Constitution of the People's Republic of China states:
::The President of the People's Republic of China receives foreign diplomatic representatives on behalf of the People's Republic of China and, in pursuance of decisions of the Standing Committee of the National People's Congress, appoints and recalls plenipotentiary representatives abroad, and ratifies and abrogates treaties and important agreements concluded with foreign states.

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Chief executive officer

In the majority of states, whether republics or monarchies, executive authority is vested, at least notionally, in the head of state. In presidential systems the head of state is the actual, de facto chief executive officer. Under parliamentary systems the executive authority is exercised by the head of state, but in practice is done so on the advice of the cabinet of ministers. This produces such terms as "Her Majesty's Government" and "His Excellency's Government." Examples of parliamentary systems in which the head of state is notional chief executive include Australia, Austria, Canada, Denmark, Italy and the United Kingdom. The few exceptions include the Czech Republic, Ireland and Sweden, where executive authority is explicitly vested in the cabinet.

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:Example 1 (presidential system): Article 2, Section 1 of the United States Constitution states:
::The executive Power shall be vested in a President of the United States of America.

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:Example 2 (constitutional monarchy): Under Chapter II, Section 61 of the Commonwealth of Australia Constitution Act 1900:
::The executive power of the Commonwealth is vested in the Queen and is exercisable by the Governor-General as the Queen's representative, and extends to the execution and maintenance of this Constitution, and of the laws of the Commonwealth.

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:Example 3 (constitutional monarchy): According to Section 12 of the Constitution of Denmark 1953:
::Subject to the limitations laid down in this Constitution Act the King shall have the supreme authority in all the affairs of the Realm, and he shall exercise such supreme authority through the Ministers.

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:Example 4 (republican parliamentary system): According to Article 26 (2) of the 1975 Constitution of Greece:
::The executive power shall be exercised by the President of the Republic and by the government.

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Chief appointments officer

The head of state appoints most or all the key officials in the government and civil service, including members of the cabinet, the prime minister or equivalent, key judicial figures, and all major office holders. In many parliamentary systems, the head of government (e.g. prime minister) is appointed with the consent (in practice often decisive) of the legislature, and other figures are appointed on the head of government's advice. Some countries have alternative provisions: under Article 4 of the Instrument of Government, 1974, the constitution of Sweden grants to the parliamentary speaker the role of formally appointing the prime minister.

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In practice, these decisions are often a formality. The last time a British monarch unilaterally selected the UK's prime minister was in 1963, when Queen Elizabeth II chose Sir Alec Douglas-Home to succeed Harold Macmillan as her chief advisor in that country. In Canada, a similar situation took place wherein Governor General Lord Byng of Vimy appointed Arthur Meighen after William Lyon Mackenzie King refused to resign the premiership. Governor-General of Australia Sir John Kerr appointed Malcolm Fraser as caretaker prime minister after dismissing Gough Whitlam.

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In presidential systems, such as that of the United States, appointments are nominated by the President's sole discretion, but this nomination is often subject to parliamentary confirmation (in the case of the US, the Senate has to approve cabinet nominees and judicial appointments by simple majority).

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The head of state may also dismiss office-holders. There are many variants on how this can be done. For example, members of the Irish Cabinet are dismissed by the President on the advice of the Taoiseach (prime minister); in other instances, the head of state may be able to dismiss an office holder unilaterally; other heads of state, or their representatives, have the theoretical power to dismiss any office-holder, while it is exceptionally rarely used. In France, while the president cannot force the prime minister to tender the resignation of his government, he can, in practice, request it if the prime minister is from his own majority. In presidential systems, the president often has the power to fire ministers at his sole discretion. In the United States, convention calls for cabinet secretaries to resign on their own initiative when called to do so.

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:Example 1 (semi-presidential system): Chapter 4, Section 2 of the Constitution of the Republic of Korea states:
::The Prime Minister is appointed by the President with the consent of the National Assembly.
:Example 2 (parliamentary system): Article 13.1.1 of the Constitution of Ireland:
::The President shall, on the nomination of Dáil Éireann lower house, appoint the Taoiseach minister.

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Legislative roles

signs a bill into law at a public ceremony.]]

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Most countries require that all bill passed by the house or houses of the legislature be signed into law by the head of state. In some states, such as the United Kingdom, Belgium and Ireland, the head of state is, in fact, formally considered a tier of parliament. However, in most parliamentary systems, the head of state cannot refuse to sign a bill, and, in granting a bill their assent, indicate that it was passed in accordance with the correct procedures. The signing of a bill into law is formally known as promulgation. Some monarchical states call this procedure Royal Assent.

:Example 1 (presidential system): Article 1, Section 7 of the United States Constitution states:
::Every Bill which shall have passed the House of Representatives and the Senate, shall, before it become a Law, be presented to the President of the United States.
:Example 2 (parliamentary system): Section 11.a.1. of the Basic Laws of Israel states:
::The President of the State shall sign every Law, other than a Law relating to its powers.

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In some parliamentary systems, the head of state retains certain powers in relation to bills to be exercised at his or her discretion. They may have authority to veto a bill until the houses of the legislature have reconsidered it, and approved it a second time; reserve a bill to be signed later, or suspend it indefinitely (generally in states with the Royal Prerogative; this power is rarely used); refer a bill to the courts to test its constitutionality; refer a bill to the people in a referendum.

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If he or she is also chief executive, he or she can thus politically control the necessary executive measures without which a proclaimed law can remain dead letter, sometimes for years or even forever.

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Military role

, Queen of Canada, the United Kingdom and the other Commonwealth countries, inspects the guard at the opening of Expo 67, in Montreal.]] reviews a line of troops at the recommissioning ceremony for the USS New Jersey.]]A head of state is generally the literal, or notional, commander-in-chief of a state's armed forces, holding the highest office in all military chains of command.
:Example 1: Article II, Section 2 of the United States Constitution states:
::The President shall be Commander in Chief of the Army and Navy of the United States, and of the Militia of the several States, when called into the actual Service of the United States.
:Example 2: Article III, Section 15 of the Constitution Act, 1867, a part of the Constitution of Canada, states:
::The Command-in-Chief of the Land and Naval Militia, and of all Naval and Military Forces, of and in Canada, is hereby declared to continue to be vested in the Queen. Constitution Act, 1867

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In a constitutional monarchy or non-executive presidency the head of state may hold the ultimate authority over the armed forces but will only normally, as per either written or conventional laws, exercise their authority on the advice of their ministers, meaning de facto decision making on military manoeuvers lies with the cabinet. The monarch or president will, however, perform ceremonial duties related to the country's armed forces, and will sometimes appear in military uniform for these purposes; in the case of a female sovereign her consort and other members of the royal family may also appear in military garb. This is generally the only time a head of state of a stable, democratic country will appear dressed in such a manner, as statesmen and public are eager to assert the primate of (civilian, elected) politics over the armed forces.

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In military dictatorships, or governments which have arisen from coups-d'etat, the position of commander-in-chief is obvious, as all authority in such a government derives from the application of military force; occasionally a power vacuum created by war is filled by a head of state stepping beyond his or her normal constitutional role, as King Albert I of Belgium did during World War I. In these, and revolutionary, regimes, the head of state, and often executive ministers whose office in legally civilian, will frequently appear in military uniform.

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Summoning and dissolving the legislature

A head of state is often empowered to summon and dissolve the country's legislature. In most parliamentary systems, this is done on the advice of the head of government (e.g. Prime Minister) or cabinet. In some parliamentary systems, and in some presidential systems, however, the head of state may do so on their own initiative. Some states have fixed term parliaments, with no option of bringing forward elections (e.g. Article II, Section 3, of the U.S. Constitution). In other systems there are usually fixed terms, but the head of state retains authority to dissolve the legislature in certain circumstances. Where a head of government has lost the confidence of parliament, some heads of state may refuse a parliamentary dissolution, where one is requested, forcing the head of government's resignation.
:Example: Article 13.2.2. of the Constitution of Ireland states:
::The President may in absolute discretion refuse to dissolve Dáil Éireann on the advice of a Taoiseach Minister who has ceased to retain the support of a majority in Dáil Éireann

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Other prerogatives

  • Right of pardon
  • Granting nobility, knighthood and various titles and other honours

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Selection and various types and styles of Heads of State

Various heads of state use a multitude of different styles and titles, often with many variations in content under diverse constitutions, even in a given state. In numerous cases, two or more of the following peculiar types apply, not counting the primary duo monarchy-republic. There are also several methods of head of state succession in the event of the removal or death of a sitting head of state.

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In a monarchy, the Monarch is the Head of State. This is a relatively recent phenomenon; until the last few decades a sovereign was seen as the personal embodiment of the state ("L'etat c'est moi", so to speak), and therefore could not be head of himself or herself (hence many constitutions from the 19th century and earlier make no mention of a "head of state"). Though some still maintain that calling a Monarch Head of State is incorrect, it has now become a widespread political convention to attach the label to Monarchs, regardless of their political position.The Emperor (Tennō) of Japan is defined as a symbol, not head, of state by the post-war constitution (contrasting with the former divine status) but is treated as a head of state under diplomatic protocol.

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For the numerous styles in past and present monarchies, in most cases commonly -though often not quite accurately- rendered as King or Emperor, but also many other (e.g. Grand duke, Sultan), see Prince, princely state and monarchy.

In a republic, the head of state is nowadays usually styled President, and usually their permanent constitutions provide for election, but many have or had other titles and even specific constitutional positions (see below), and some have used simply 'head of state' as their only formal title.

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Shared and substitute heads of state

Interim

Whenever a head of state is not available for any reason, constitutional provisions may allow the role to fall temporarily to an assigned person or collective body.

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In a monarchy, this is usually a regent or collegial regency (council). In a republic, this is - depending on provisions outlined by the constitution or improvised - a vice-president, the chief of government, the legislature or its presiding officer.

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Delegation

illustrating her different positions as sovereign. Left: as Queen of New Zealand, wearing the Order of New Zealand, the Queen's Service Order, and the sash and the star of the New Zealand Order of Merit; centre: as Queen of Canada, wearing the Sovereign's insignia of the Order of Canada and the Order of Military Merit; right: as Queen of the United Kingdom, wearing the insignia of the Order of the Garter and the Royal Family Orders of King George V and King George VI.]]

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In cases where one person is head of state of multiple sovereign countries there may be need to appoint a permanent representative in each (except in the head of state's country of primary residence). Examples are all but one of the Commonwealth realms, where their king or queen resides in another of the Crown's kingdoms, the United Kingdom, and so is represented in the others by a crown-appointed governor-general (unhyphenated in Canada as "Governor General"), as well as Andorra, which is headed by two non-resident co-princes, one of which is also the President of France.

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Acting Joint Head of State Barbara Prammer, Austria. Capitano Reggente Valeria Ciavatta, San Marino. Acting President Natasa Micic, Serbia. Executive President Megawati Sukarnoputri, Indonesia ...

In Commonwealth realms the Governor-General may fulfill many of the roles of a head of state, but is typically not, either legally or conventionally, regarded as the head of state, but rather as an appointed representative of the head of state mandated to act in his or her place, even when the monarch is present in the country. Some governors-general are considered de facto heads of state because, though not the de jure (juridical or legal) head of state, in practice they function like a head of state in most or all jurisdictions.

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In diplomatic situations, governors-general, if treated as de facto heads of state, are sometimes accorded a status akin to a head of state, but that is by tradition and on a case by case and person by person basis, not automatic. At state banquets, for example, toasts are made to the head of state (e.g. "Her Majesty the Queen of Australia"), never to a governor-general, except insofar as a personal toast may be proposed subsequently to "Governor-General and Mrs. Smith" as hosts of, or guests at, the banquet. Similarly, letters of credence may contain the name of the head of state, not the governor-general, even if it is the latter who signs and receives them.

In 2005, Canada, Australia and New Zealand changed their policies and now all Letter of Credence address solely the Governor-General of the relevant state, not to Queen Elizabeth II, making these countries the only sovereign nations to not expressly issue or receive letters in the name of their respective head of state. Despite the fact that the Governor General in each country remains the representative of the monarch, are appointed by her to that role, and thus are still constitutionally issuing Letters of Credence indirectly on behalf of the Queen, even if no longer explicitly by name, the Office of the Prime Minister of Canada stated in its press release announcing the changes to the Letters of Credence and Recall, issued December 29, 2004, that "in international diplomatic practice, Letters of Credence are formal diplomatic instruments that are presented by High Commissioners and Ambassadors to the Head of State of the host country... Letters of Credence and Recall presented by foreign High Commissioners and Ambassadors to Canada will now be addressed to the Governor General directly." This wording implies that the government of Canada, as least during the premiership of Paul Martin, regarded the Governor General as the Canadian Head of State. Prime Minister of Canada: Canada updates diplomatic practice, Governor-General of Papua New Guinea, is the viceregal representative of Elizabeth II, Queen of Papua New Guinea.]]

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Similarly, a 2004 report issued by the Canadian Standing Committee on Government Operations and Estimates recognised that the nation is a constitutional monarchy, however described the 1947 Letters Patent as having devolved all powers of the sovereign to the Governor General, making the latter head of state, and then continued to refer to the Governor General as head of state throughout the report. The Standing Committee on Government Operations and Estimates: Second Report: The Governor General of Canada:Role, Duties and Funding for Activities That same year, the then Governor General, Adrienne Clarkson, attended a ceremony in France to recognize Canada's involvement at Juno Beach in the D-Day landings of 1944. Her office stated that she was present as Canada's head of state, and thus the Governor General was treated as the senior official in attendance, over even the Queen who was also present at the ceremony. While laying wreaths, the ceremony commentator stated that the Governor General was laying a wreath on behalf of Canada, whereas the Queen was laying a wreath on behalf of the Commonwealth. Rideau Hall later retracted the assertion that the Governor General attended as head of state, saying that it was an error of a junior official, but this did not explain the unusual shift in protocol observed at the ceremony itself.

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p North Korea's No. 2 leader and ceremonial head of state Kim Yong Nam is pictured during an interview with Kyodo News agency in Pyongyang, North Korea Wednesday, Sept. 10, 2008. Kim said there is 'no problem' with the supreme leader, and senior diplomat Song Il Ho also said that reports about Kim Jong Il's health are 'not true,' according to Japan's Kyodo News agency. (AP Photo/Kyodo News) /p

In opposition to this thinking, in the opening of his first speech in the Canadian House of Commons as Prime Minister, Stephen Harper stated: "I'd like to acknowledge and thank a number of people. First of all I'd would like to pay tribute to our head of state, Her Majesty Queen Elizabeth II." Prime Minister backs the Speech from the Throne As well, the Governor General of Canada's website now refers to the Queen of Canada as Canada's head of state. Governor General of Canada: Role and Responsibilities of the Governor General However, the Canadian Letters of Credence and Recall continue to be issued in the name of, and addressed to the Governor General alone.

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The question of whether the sovereign or the Governor General is head of state has also arisen in Australia, where some, especially amongst those on the monarchist side of the republic debate, and most notably Professor David Flint, National Convenor of Australians for Constitutional Monarchy in his book The Cane Toad Republic, and Sir David Smith in his book Head of State: the Governor-General, the Monarchy, the Republic and the Dismissal, have stated that the Governor General is the Australian head of state, and the Queen as Australia's sovereign. Dispelling the myths:the Head of State

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Flint says that under inter national law and diplomatic practice, the Governor-General is the Australian Head of State, and that soon after the Commonwealth of Australia came into existence, the High Court of Australia unanimously ruled that the Governor-General is the “constitutional head of the Commonwealth” and the State Governors are the “constitutional heads of state.”R v Governor of South Australia [1] HCA 31; (1907) 4 CLR 1497In the case of Andorra, two Co-Princes act as the principality's heads of state; one is also simultaneously the President of France, residing in France, and the other is the Bishop of Urgell, residing in Spain. Each Co-Prince is represented in Andorra by a delegate, though these persons hold no formal title.

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As a colony or other dependent state or territory lacks the authority to vest in a true head of state of its own, it either has no comparable office, simply receiving those roles exercised by the paramount powers (in person or, most of the time, through an appointed representative, often styled (Lieutenant-)governor, but also various other titles, on the Cook Islands even simply King/Queen's Representative) or has one, such as a formerly sovereign dynasty, but under a form of metropolitan guardianship, such as protection, vassal or tributary status.

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