By Gavin V. Emmanuel
Part Three: Term Limits and the Wrong Transplant
Parts One and Two made the case against fixed election dates on two distinct grounds: that such a calendar is incompatible with the constitutional doctrine of responsible government embedded in the Antigua and Barbuda Constitution, and that the practical experience of Westminster jurisdictions (most vividly the United Kingdom) confirms that imposing a statutory timetable on a confidence-based system produces paralysis, not accountability. Part Three turns to the second major reform proposal: term limits for prime ministers. Here the constitutional incompatibility operates differently, but runs just as deep.
If fixed election dates represent a misunderstanding of how the Westminster system manages time, then term limits for prime ministers represent a more fundamental misunderstanding of how it manages power. Where fixed dates impose a calendar on a system built around confidence and flexibility, term limits impose an individual cap on a system built around parliamentary choice. Both reforms borrow from a presidential vocabulary and apply it to a parliamentary grammar. The results, in either case, are incoherent.
The proposition is familiar: no prime minister should serve more than a fixed number of terms. Advocates frame this as democratic renewal, a check on the consolidation of personal power, a remedy for what critics of Caribbean governance sometimes call “hyper-executive dominance.” The framing is understandable. The solution is wrong.
Begin, again, with the constitutional text. Section 69 of the Constitution of Antigua and Barbuda provides that the Governor-General shall appoint as Prime Minister the member of the House of Representatives who, in the Governor-General’s judgement, is best able to command the support of the majority of members of that House. The provision does not ask how long that person has previously held office. It does not ask how many elections they have contested or won. It asks one question: does this individual command the confidence of the legislature now? That is the entirety of the Westminster qualification for executive office. A term limit does not supplement this provision. It contradicts it.
In a presidential republic, the logic of term limits is coherent because the president’s authority flows directly from the electorate. The voters give their power to a person, and they can be told, by constitutional design, that they have given it enough times. But a prime minister’s authority does not flow from the electorate directly. It flows from the House of Representatives. The people elect members; the members choose a leader; the leader governs. A term limit imposed on the prime minister does not constrain executive power in this model. It constrains the House of Representatives itself; it tells elected members of parliament that they may not confer their confidence on a particular individual, regardless of their own democratic judgement. That is not a check on executive authority. It is a veto on the legislature’s sovereign discretion.
This is what constitutional scholars call the “presidentialization trap.” By treating the prime minister as an individual with a personal mandate and a fixed tenure, term limits gradually reshape the office to resemble an executive presidency, concentrating public attention on the person rather than the party, weakening the cabinet and the caucus, and encouraging voters to think in terms of individual leaders rather than parliamentary majorities. The irony is that critics of Caribbean governance who invoke “hyper-executive dominance” as the problem are proposing a reform that would accelerate precisely the dynamic they claim to oppose.






