Allow me to correct @tradegoveuk. Your comparison does not support your conclusion. Allow me to explain (thread)
https://twitter.com/tradegovuk/status/1314522278244298752
1) Your sample. You compare the UK system to Canada, Japan and Australia. Two of these systems are Westminster systems. That does not support a conclusion relating to “the world”.
2) Why do I say that? The real power in treaty scrutiny is an up or down vote on an FTA in Parliament. That exists, for example, in the US or the EU. Not in the UK.
3) But let’s also look at your statement about Japan. I have doubts. And I have to explicitly state: I do not speak Japanese. Nor am I an expert on the Japanese constitution. But it seems to me...
... that Art. 73 of the Japanese constitution gives the Diet a vote on treaties. Something that the UK Parliament does not necessarily have (there’s a vote on treaty implementation, there’s CRaG, but no mandatory up or down vote).
Note: when I say vote on implementation I mean that treaties sometimes have to be implemented through legislation. Parliament gets to vote on that legislation. Under a convention, the FCO will put the implementing legislation before Parliament before ratification.
Are there any Japanese constitutional experts out there that can confirm whether the Japanese constitution gives the Diet an up or down vote on FTAs?
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