Most ruling parties these days are minorities. As argued earlier, winning a majority only after distribution of preferences cannot be regarded as full-hearted and positive majority support for everything the winning party might want to do. When no party wins a majority of votes, it is not obvious which, if any, should win a majority of seats.
Furthermore, non-proportional electoral systems often do not deliver their claimed objective of strong majority government. The weakest governments in our region are found not in Tasmania, but Papua New Guinea, which uses not proportional representation but first-past- the-post. [118]
Some believe that first-past-the-post voting would free the political system of minor parties. [119] This belief is wrong, for in other countries first-past-the-post has utterly failed to stop minor parties from winning significant numbers of votes...
"A Canadian Rhinoceros Party spoofed its way to fifth place among the parties in the 1979 election, securing 62,623 votes in three provinces. Its posters supported, among other things, a proposal to repeal the law of gravity." [120]...or seats: "Britain now has a multi-party system. The roll-call would do credit to Italy: Conservatives, Labour, Democrats, Greens, SDP, Scottish and Welsh Nationalist, and at least three Northern Irish parties. All this without proportional representation." [121]
Nor has the majority-preferential system in Australia succeeded in doing so either. For the past six years, the Bannon Labor Government in South Australia has depended on the support of two Independents; [122] and in 1968 "an obscure rural Independent named Stott, who won his seat by just one vote, allowed the Liberals to form a government, and later crossed the floor to bring them down" [123] after Labor and Liberals tied 19-19 in the South Australian House of Assembly. Labor came to power Federally in 1943, without an election, by gaining the support of two Independents.
From 1911 to 1956, with a single-member system, Victoria had twenty-nine unstable and short-lived governments. And in the last Federal, New South Wales, and Queensland elections there were real fears that enough Independent or minor-party candidates would be elected to deny either government or opposition an outright majority. [124]
So the single-member system has failed in its supposed aim of keeping out all minor parties. But it treats minor parties very unequally. As we have seen, the system rewards minor parties with a narrow regional or sectional base, whose supporters are concentrated enough to amount to a majority in a number of electorates, [125] and discriminates against minor parties whose supporters are evenly dispersed.
In any hung Parliament, these territorially-concentrated minorities (possibly with separatist or secessionist goals, such as the Scottish Nationalists or the Parti Quebecois) would have more seats and wield more power than minor parties with a broader base of support. [126]
But would this multi-party situation not be further exacerbated by proportional representation? In fact, it would not. The Hare-Clark system would actually discourage political fragmentation and promote integration.
It is untrue that "there may be something intrinsically destabilising in proportional representation voting." [127] Nothing in the nature of proportional representation leads inevitably to hung Parliaments, as is seen from the fact that large majorities have been won by the conservatives in the Senate (1975) and by Labor in the New South Wales Upper House (1978 and 1981).
It is true that minor-party and independent candidates customarily receive more votes for the Senate than for the House of Representatives. But the cause is not the lower House's higher quota, as most voters would not know the significance of electoral details such as quotas.
Even if they did realise the greater difficulty of a minor candidate winning a House seat, they could still support a minor party for the House if they wanted, for the preferential system (as most voters do generally know) ensures a vote is not wasted on a minor candidate. [128]
It seems more likely that voters distinguish between the lower house of government and the Upper House of review. [129] When choosing a lower house, they are "subject to the sobering reality that... nearly all members... could be part of a government." [130]
By contrast, the "by-election atmosphere" of upper house elections encourages voters to vote against the government (and often against the opposition as well). Queensland has no upper house, so the logic of Senate results cannot be applied.
It is further evidence that the DLP's Senate vote collapsed (despite a lower quota) at the 1975 election - the election when it first seemed that control of the Senate would determine which major party would govern. During the long, calm Menzies reign, with five Senators elected (and a quota of 16.7%) in each State at each election, the DLP regularly won several seats. But in the double dissolution of 1975, the voters - when the fear of deadlock and instability looked real - polarised between the Liberal-National and Labor parties; and, even though the Senate quota was halved (to 9.1%), the DLP won no seats at all.
By contrast, the best Senate result for minor candidates in modern times (20% of the votes) was in 1970, [131] at the last separate half-Senate election - that is, the most recent election where the fate of the government was not at stake. [132]
Unlike other forms of proportional representation, the Hare-Clark system would make it harder for minor parties to win votes and seats.
The small numbers of seats would set relatively high quotas - 16.667% in a five-member electorate, 12.501% in a seven-member electorate, 10.001% in a nine-member electorate - and we have it on the authority of the Leader of the Queensland Liberal Party (moreover, talking about the Senate, where votes for such minor parties are higher) that:
"those who are voted for partly in protest, or deliberately in protest, against the lot - the ratbag minorities, the confused minorities, or the ultimate political harlots, the Democrats - can always get 8%. They cannot get above 10%; and they certainly cannot get 16%." [133]
Of course, a candidate does not need to win a full quota on first preferences, any more than a candidate needs a majority of primary votes in a single-member seat. But even so, experience with Senate elections since 1949 showed that, with a quota of 16.7%, a minor candidate needed an average of 12% on first preferences to be elected. [134]
The quota under Hare-Clark is much higher than the four or five percent usually suggested as a threshold under party-list systems. [135]
In fact, to win one seat the quota under Hare-Clark in a five-member electorate actually amounts to more votes (though over a wider area) than if the same area were divided into five single-member electorates. [136]
We should not assume that the currently high levels of support for minor parties and Independents will be permanent. [137] In fact, the scope under Hare-Clark for free choice of candidates could well make it easier for a single party to win over 50% of the primary vote. Minor parties might lose the protest vote, if major parties were astute enough to include in their teams candidates who would attract votes away from minor parties:
"Because STV encourages the parties to present a balanced slate of candidates, including representatives of all the various factions in the party, it may serve to discourage party fragmentation... If STV allowed changes in public sentiment to be better reflected in the existing party structure, then new parties and protest movements would be less necessary." [138]
In the long-term, the minor groupings could well disappear and the system consolidate into a two-party system, as in Malta and (with some recent exceptions) Tasmania* and Eire:
"Tasmania* is the only province [sic] of Australia where the two-party system has succeeded in beating off challengers to its hegemony. There is no Country Party in Tasmania; and, in the 1950s, the right-wing breakaway from the Australian Labor Party, the Democratic Labor Party, was unable to win seats because the ALP used to put up Right-wing candidates among its slate of candidates... [139]
Tasmania*, in fact, holds "an Australian record for unbroken control of a State Parliament by a single party." [140] There have been a few brief periods [141] (less frequent since the number of seats was increased from 6 to 7 per electorate) [142] when governments depended on an Independent's support. But, as seen above, similar situations have occurred in other States and at the Federal level; and, in a small Assembly (35 members), a single vote can often turn the balance whatever the electoral system. The collapse of the Holgate Government in 1982 cannot be blamed on Hare-Clark, for the two MPs who withdrew their support from the government were the Whip and a former Premier of the governing party, and thus would have had safe seats under any electoral system. [143]
It took eighty years of proportional representation before Tasmania* had its first coalition with a minor party, the Green Independents, holding the balance of power. Even so, the Greens only got their start because of the failure of the major parties (particularly Labor) to include enough conservation-minded candidates on their tickets. If the major parties wish to return to the pure two-party model, they need only offer the voters Labor and Liberal candidates with sufficient environmental credibility to draw votes away from the Greens.
| * For the details of votes received, seats won and governments formed, by the major parties and "others", in Tasmanian elections since 1909, see Tasmanian Elections and Governments. |
So, over the long term, Hare-Clark would reduce the number of separate parties. But - at least in the short-term transition period - there might be hung parliaments, where no party has a majority. Would this not mean "a danger of instability in constantly-changing coalitions and majorities which might emerge from time to time"? [144]
The standard arguments against coalition government ring hollow to us. Australia and most States, including Queensland, have had coalition governments for most of their history. These coalitions have by no means been weak and unstable. It would be hard to claim that Joh Bjelke-Petersen, who governed in coalition with the Liberals for 14 of his 18 years as Premier, was a weaker or less decisive Premier than Mike Ahern, who enjoyed a single-party majority throughout his entire term.
Under Hare-Clark, coalitions will be necessary only if the voters want them; and if so, such coalitions can work satisfactorily.
Indeed, Hare-Clark would have avoided two of the main causes of friction between the Liberal-National Coalition partners. Firstly, the Liberals resented the fact that the zonal system cheated them of their rightful number of seats and, before 1977, deprived them of the Premiership; but even with equal electorates, they could well have been under-represented in Parliament as the third party. Secondly, the parties quarrelled bitterly over three-cornered contests and joint Senate tickets. [145]
Because three-cornered contests were seen as threatening the unity of the coalition, [146] each party was confined to its own existing strongholds. [147] It was not until the 1980 Senate election that every voter in Queensland could choose between the conservative parties; [148] and it was not until the 1983 election, after the Coalition broke down, that the Nationals could go all out for majority status in their own right by contesting every seat. Under Hare-Clark, each coalition partner can contest every electorate, as allies rather than rivals; the Liberals may be able to take the last seat from Labor if their National allies cannot, or the Greens may be able to take the last seat from the Liberals if their Labor allies cannot.
Since the last election in Tasmania, Labor and Greens have worked together harmoniously - no less so than the two parties in the Liberal-National coalition, or the different factions in the ALP. Neither Labor nor Greens - nor, for that matter, the opposition Liberals regard themselves as unfairly "ripped off" by the electoral system.
Some argue that coalitions are less accountable because the voters cannot "pin down" responsibility on a single party. This ignores the fact that the voters need only hold the coalition parties jointly accountable - as happened in the Federal elections of 1972 and 1983. In any case,
"The desire to be exonerated from failure and associated only with success is a characteristic of political parties in all democracies. The dexterity with which governments in non-proportional representation systems find scapegoats for their failures means that the issues of responsibility and accountability are not much more clear-cut than in proportional representation systems." [149]
Indeed, the essential factor in securing accountability is a politically-aware electorate which is more likely to develop under an electoral system which (like Hare-Clark) encourages voters to think for themselves.
Some object that, "whilst electors under proportional representation may be able better to influence the composition of Parliament, they would have much less influence on the political colour of the government itself. ... The voter does not vote for the combination of parties that will form the coalition." [150]
This is certainly not the case with Hare-Clark, or any other form of preferential voting. The alliance of Labor and Greens in Tasmania was approved by the voters in the 1989 election, when 80% of the Greens' preferences flowed to the ALP. [151] Likewise, during the years of the Liberal-National Coalition in Queensland, the flow of preferences between the parties demonstrated that the coalition had conservative voters' support.
However, in real life it should be remembered that: "even if this implausible idea of electors carefully checking-off items on the parties' shopping lists bore any relation to the truth, the mandate argument would still run full tilt into the problem that electoral victory is constructed out of a popular minority and does not rest on the support of a majority." [153]
The principle of majority rule requires that, if a skeptical electorate has refused to give any one party a clear mandate for its entire manifesto, then the proper solution is to work out a common program knowing what will command the most support. Whether this would require a coalition, or a single party governing alone but taking care that it had other parties' support, it is actually safeguarding the rights of the majority of voters. [154] It is hard to see why the largest party should not have to negotiate and deal with others. That is, after all, exactly what all of us do in our everyday lives.
"Fear or dislike of coalition is felt not by the ruled but by the rulers, who naturally find life much easier if they know they can carry all their proposals and need not bow to criticism from outside their own party." [155](emphasis added)
However, this is generally put forward as a theory, seldom backed by concrete evidence. In fact, it is directly refuted by Queensland's own experience. From 1957 to 1983, the Nationals depended on Liberal support to give them a majority in Parliament. Yet how could anyone claim the Nationals were "held to ransom" by the Liberals over that time? If either party was dominant, it was the Nationals.
Even when the minor party (such as the Democrats in the Senate) is not a coalition partner, it is "difficult to see how a small party can impose on the country any policy peculiar to itself and opposed unitedly by the larger parties" [156] - as can be seen from the many votes taken in the Senate in which Liberal/National and Labor Senators join together to outvote the Democrats. If small parties (like the religious parties in Israel) do abuse their balance of power position, it is only because the major parties let them do so, by failing to reach agreement among themselves.
The New Zealand Royal Commission on the Electoral System considered that the possibility of minor-party "blackmail" can be overrated:
"Overseas experience indicates that the extent to which a minor party can exact an excessive price for its support is limited. If voters consider a small party to be demanding unreasonable concessions for its support, or to have been irresponsible in changing the government, that party can be heavily penalised at the next election." [157]
As shown above, at any time of feared instability or deadlock Australian voters have tended to abandon minor parties and polarise between government and opposition camps. In Queensland's 1983 State election, where concern over stability was a major issue, minor parties (other than National, Labor, and Liberal) won less than 1% of the votes; and the Liberal vote dropped by half.
Moreover, Hare-Clark will encourage a two-party or two-bloc system even in normal times. It may well be true that "Australian voters ... prefer a straight choice between two parties;" [158] but voters will not stay with only two parties if the politicians they want to vote for are running with a dozen different parties - as is likely to happen with any kind of list system. By contrast, Hare-Clark allows different shades of opinion to be fairly represented within the two major parties. Thus Hare-Clark produces a two-party system if the voters want it, and makes it more likely the voters will want it.
In a single-member system, the balance of power is enjoyed by the swinging voters in marginal electorates; and any minor party or pressure group that can sway these voters has a strong potential to blackmail the major parties.
Under a single-member system, these voters can have an influence far in excess of their numbers. As one newspaper pointed out, John Cain's future in Victoria's 1988 election was "in the hands of only 1,133 voters in four marginal Melbourne seats." [161] This tiny minority, representing less than one percent of the voters, can swing perhaps twenty percent of the seats possibly defeating a number of hard-working sitting members unlucky enough to represent marginal electorates. But under Hare-Clark, the swinging voters can affect only a correspondingly small number of seats; and the sitting members defeated will be those whom the voters judge most expendable.
Under Hare-Clark, the support of the party with the balance of power is needed to ensure that the government has the support of the majority. By contrast, under the single-member system, concentrating on the swinging marginals can produce a result, as in the 1990 Federal election, where the government wins office although rejected by the majority.
"the DLP... supported by a very small percentage of the population, held the major political parties to electoral ransom on the strength of... its preferences... [yet] for seven House of Representatives elections (from 1955 to 1972), polled between 5.0 and 9.4 percent of the national vote, yet never once gained a single seat in the House. Surely an equitable electoral system would have been one that gave such a party a voice in Parliament to reflect its vote, but at the same time denied that party the opportunity to manipulate the entire system to suit its purposes?" [162]
With a system of proportional representation for the lower house of government, minor parties with the support of sizeable numbers of voters could no longer wield power without responsibility, [163] "... wallowing in the luxury of the knowledge that they will never be in the position of having to govern, and confront problems, in their own right." [164]
When the single-member system excludes minor parties from Parliament, they are free to sit on the sidelines and criticise; if they hold a balance of power in the Upper House, they can be accused of exercising their power irresponsibly. [165] But they represent sizeable numbers of voters, and in a democracy we cannot throw their votes away. Instead, "... there is only one way of forcing the minor parties to abandon ratbaggery, and that is to insist that they take a genuine share of responsibility, as well as power." [166]
A Hare-Clark system of proportional representation for the lower house would ensure that no party could hold a balance of power without sharing some responsibility for the government's decisions, particularly unpopular decisions: "... if a minor party or independent is to exercise power over the fate of legislation or a government, then they should also be required to shoulder their part of the responsibilities of government, to join a coalition in the house where responsibility for government resides." [167]
Another objection is that proportional representation would bring not too little stability, but too much; it would "blunt the edge of radical change" [168] and entrench "government by permanent centrism and coalitionism." [169] This view considers the impossibility of parties winning large majorities without 50 percent of the votes to be undemocratic, since "democracy should... permit an electorate which changes its mind to express this dramatically in terms of the character of government." [170]
However, in Australia proportional representation has been supported by politicians and commentators on the political left (Arthur Gietzelt, Frank Hardy, [171] Bill Hayden [172], Donald Horne [173]) and right (PP McGuinness [174], Robin Gray [175], Campbell Sharman [176]) as well as the centre. In Britain, Arthur Scargill is a supporter, [177] along with many European socialists. [178]
Nor has proportional representation prevented radical and strong-minded politicians Éamonn de Valéra in Éire, Dom Mintoff in Malta, Jack Lang in New South Wales - from coming to power, provided they gained a majority of the votes.
Even when no single party has such a majority and a coalition is formed, minor parties in the coalition could well have a radical rather than a moderating influence. [179] It is interesting to compare the Social Democrats in Germany, in coalition with the liberal Free Democrats, with their counterparts in Sweden, in coalition with the Communists.
Some claim that Tasmanian politics (as in Eire) concentrate excessively on purely "parish-pump" matters, [180] due to "the loose organisation and lack of clear ideology maintained by the Hare-Clark system." [181] But this is inevitable in such small, rural societies. [182]
In Malta, by contrast, the two parties are very sharply distinguished. The Malta Labor Party is anti-clerical, anti-American, and neutralist, while the Nationalists are pro-Catholic-Church, pro-American, and conservative. So opposed are the two parties that, with optional preferential voting, supporters of one party will not even record preferences for candidates of the opposing party. [183] So radical is the Malta Labour Party that it has banned US warships from the country's harbours. No "grey centrism" here.
However, the moderating influence of Malta's proportional representation system can be seen from the fact that, in January 1987, the two parties unanimously agreed on a series of constitutional amendments - a better record of inter-party cooperation on constitutional reform than we have seen in Australia for many years.
118. C/f Roy Eccleston, "Evans offers PNG lesson in discipline" (The Australian, 26 April 1990). [Back to text]
119. Mungo MacCallum, "Minorities can be too mighty" (Melbourne Herald, July 1989). [Back to text]
120. Howard R Penniman, "Campaign Styles and Methods", in Democracy at the Polls: A Comparative Study of Competitive National Elections (1981), ed David Butler, Howard R Penniman, and Austin Ranney, p 132. [Back to text]
121. Richard Holme, "Hopes and fears", New Statesman and Society, 21 July 1989, p 22. [Back to text]
122. Scott Bennett, "Parties and Elections", in Australian State Politics (ed Brian Galligan; Melbourne, Longman Cheshire, 1986), p 224. [Back to text]
123. Mungo MacCallum, "Minorities can be too mighty" (Melbourne Herald, July 1989). [Back to text]
124. David O'Reilly, "The Politics of Disillusion" (The Bulletin, 16 February 1988), pp 20-29. The Queensland Liberals should be regarded as a minor or third party in the 1989 Queensland election, as they were not in any pre-arranged coalition with either Government or Opposition. [Back to text]
125. As in Canada; Irvine, p 98. [Back to text]
126. Bogdanor, p 189. [Back to text]
127. Ray, p 126. [Back to text]
128. In Queensland, minor parties' votes (28% in 1957 - due to the ALP split; 17% in 1960; 12% in 1963) actually dropped after first-past-the-post was abandoned and preferential voting restored. [Back to text]
129. Hughes, pp 224-225, 314; Ray, pp 125, 136. [Back to text]
130. Ihlein, p 21. [Back to text]
131. Ray, p 125. [Back to text]
132. Laurie Oakes, "Haunting times for Hawke" (The Bulletin, 27 June 1989), p 35. [Back to text]
133. Hansard, Queensland Legislative Assembly, 24 August 1988, p 37. [Back to text]
134. Gietzelt (July 1981), p _. [Back to text]
135. The Netherlands requires 0.67% (equal to a quota for one of the 150 seats); Israel, 1% [now 1.5%]; Denmark, 2%; Spain, 3%; Sweden, 4%, and West Germany and France, 5%. [Back to text]
136. Sharman, footnote 11, p 111. [Back to text]
137. Paul Kelly, "The Rising Tide of Senate Review"; Lex Watson, "The Senate: An Uneasy Compromise" (Australian Society, September 1986), p 34; George Winterton, "Constitutional Reform: Some Thoughts on Possible Amendments" (Quadrant, September 1988), p 21. [Back to text]
138. Bogdanor, pp 244, 250. [Back to text]
139. Bogdanor, pp 244-245; c/f Townsley, p 63. [Back to text]
140. R A Herr and Charles Woollard, "Lobbying, Legitimacy, and Brokerage Politics in the Tasmanian Parliament", in Responsible Government in Australia, ed Patrick Weller and Dean Jaensch (1980), p 125. [Back to text]
141. Ray, pp 129-130. [Back to text]
142. Gietzelt (July 1981), p 45. [Back to text]
143. The Muldoon Government in New Zealand was defeated in 1984 when a dissident National MP crossed the floor in Parliament. [Back to text]
144. Michael Tate (ALP, Tas), Hansard, Senate, 7 May 1987, p 31. [Back to text]
145. Hughes, p 232; Scott et al, p 54; Sharman, pp 105-106. [Back to text]
146. Bogdanor, pp 252-253. [Back to text]
147. Scott et al, pp 54. [Back to text]
148. Hughes, p 233; Scott et al, p 54. [Back to text]
149. Wilson, p 18. [Back to text]
150. Hain and Hodgson, p 18. [Back to text]
151. David Barnett, "The Green Mess" (The Bulletin, 31 October 1989), p 52. [Back to text]
152. Hain and Hodgson, p 19. [Back to text]
153. Richard Holme, "Parties, Parliament, and PR" in 1688-1988: Time for a New Constitution? (1988), p 138. [Back to text]
154. Wilson, p 18. [Back to text]
155. Lakeman, p 158. [Back to text]
156. Lakeman, p 162. [Back to text]
157. New Zealand Royal Commission, p 54, para. 2.144. [Back to text]
158. Henry Mayer, "Big Party Chauvinism and Small Party Romanticism", in Australian Politics: A Fifth Reader (Melbourne, Longman Cheshire, 1980), p 345. [Back to text]
159. R W Johnson, "Third party insurance" (New Statesman and Society, 19 January 1990), pp 12-13. [Back to text]
160. Ormond Wilson, "Some Thoughts on the Report of the Royal Commission on the Electoral System" (Political Science, December 1987), p 160. [Back to text]
161. The Australian, 21 September 1988. [Back to text]
162. Elaine Thompson, "Elections and Democracy", in Change the rules! Towards a Democratic Constitution (1977), p 176. [Back to text]
163. McGuinness, "The wrong vote for the wrong reason" (Weekend Australian, 10-11 March 1990); c/f Max Teichmann, "Vale the Democrats?" (Australian Society, August 1986). [Back to text]
164. Gareth Evans (ALP, Victoria), Hansard (Senate, 3 March 1979), p 409. [Back to text]
165. "Minister lashes at "zealots" in Senate" (Courier-Mail, 5 December 1987); Paul Kelly, "The Rising Tide of Senate Review." [Back to text]
166. McGuinness, "The wrong vote for the wrong reason" (Weekend Australian, 10-11 March 1990). [Back to text]
167. Lex Watson, "The Senate: An Uneasy Compromise" (Australian Society, September 1986), p 34. [Back to text]
168. Hain and Hodgson, pp 5-6. C/f John Dearlove and Peter Saunders, Introduction to British Politics: Analysing a Capitalist Democracy (Cambridge, Blackwell, 1984), p 99; Roy Hattersley, "The centre cannot hold" (The Guardian, 19 December 1988); Prof Paul Hirst, Law, Socialism, and Democracy (1983), pp 116-117; Stephen Howe and Hilary Wainwright, "Change from below" (New Statesman and Society, 30 June 1989), pp 16-17; Noel Malcolm, "An invitation for Mr Hattersley to cast modesty aside" (The Spectator, 12 August 1989), p 6. [Back to text]
169. Hain and Hodgson, p 8. [Back to text]
170. Hain and Hodgson, p 29. [Back to text]
171. "The Most Democratic Constitution in the World?", in Change the Rules/Towards a Democratic Constitution (1977). [Back to text]
172. "Hayden pledges to act on electoral reform" (Labor Review, August 1981); "Hayden calls for action on voting" (Courier-Mail, 17 November 1980). [Back to text]
173. Horne, Power from the People: A New Australian Constitution? (Victorian Fabian Society pamphlet No. 32, October 1977), pp 7, 20. [Back to text]
174. McGuinness, "The wrong vote for the wrong reason" (Weekend Australian, 10-11 March 1990). [Back to text]
175. Bruce Montgomery, "Revitalised Gray shuns pairing with greens to balance votes" (The Australian, August __ 1989). [Back to text]
176. James, pp 92-112. [Back to text]
177. Stephen Howe and Hilary Wainwright, "Change from below" (New Statesman and Society, 30 June 1989), pp 16-17. [Back to text]
178. Hilary Wainwright, "A Socialism to Warm the Heart" (New Statesman and Society, 6 May 1988), p 20. [Back to text]
179. Dawn Oliver, "Reform of the Electoral System? (Public Law, 1983), p 117. [Back to text]
180. Bogdanor, p 248. [Back to text]
181. Davis, p 187. [Back to text]
182. Ihlein, p 22; Bogdanor, p 247. [Back to text]
183. Lakeman, pp 85-86. [Back to text]