The last days of President Donald Trump in office have been disgraced with the second impeachment by the US House, after he was charged with “incitement of insurrection'' over the deadly mob siege of the US Capitol.
Trump’s counterpart on the other side of the ocean, the UK Prime Minister Boris Johnson is technically safe from facing the same type of ordeal, as impeachment in Britain has been considered obsolete since 1806. However, a similar process of holding government officials and Downing Street leadership accountable for their actions and decisions while in office is still very much alive.
The process of setting off a confidence motion – a test for the government that can only operate as long as they have the ‘confidence’ or support of the House of Commons – is not clear cut and simple in Britain.
As the current government struggles to cope with the pressure of fast rising numbers of Covid-19 cases, the economic fallout of an ongoing lockdown and the widespread uncertainty following Brexit, there are many unhappy voices among the public and the parliamentary chambers, blaming the incompetence of Boris Johnson and his Cabinet.
Dozens of petitions to hold a vote of no confidence in Johnson’s government over his handling of the Covid-19 pandemic and the Brexit negotiations have been filed.
While Johnson is yet to face the test of the vote, he had dealt with similar trials in the past, when in 2019 the Plaid Cymru party drafted plans to censure Johnson for the unlawful suspension of parliament.
The development came days after the US Democratic Party began a formal impeachment inquiry into Donald Trump.
"I admit, the idea of impeaching a prime minister seems extraordinary - unique even. But we are in extraordinary times. I have made clear to opposition leaders that Boris Johnson cannot be allowed to get away scot-free with breaking the law by shutting down parliament,” leader of Plaid Cymru in Westminster, Liz Saville Roberts said at the time.
Johnson’s predecessor Theresa May was not as lucky and had to face two votes of no confidence, in 2018 and 2019, over her handling of the Brexit negotiations.
She survived both of them, but her government was left largely weaker and she eventually announced her resignation effective on 7 June, 2019.
Another Prime Minister, same political party initiating motion for a PM’s impeachment – in 2004 Plaid Cymru’s Adam Price intended to impeach Tony Blair acting in contempt of Parliament by taking Britain to war in Iraq.
His initiative was shut down by the then Leader of the House of Commons Peter Hain. Back then Boris Johnson actively supported the idea of impeaching Tony Blair.
"He [Blair] treated parliament and the public with contempt, and that is why he deserves to be impeached. It does not mean that he would be forced to resign: only that he would have to explain himself … and say why he felt it necessary to be so reckless with the truth,” wrote Boris Johnson in 2004.
UK ministers operate according to the principle of ministerial accountability, which means they have a duty to Parliament “to account, and be held to account, for the policies, decisions and actions of their departments.”
If found in breach of the code, ministers can be brought to account via such mechanisms for scrutiny, as select committee hearings, questions or debates and calls for resignation.
Former Home Secretary Amber Rudd was forced to resign in 2018 after she was fund to have misled the Home Affairs Select Committee over whether the department had issued targets for the removal of illegal immigrants, which became known as the Windrush Scandal.
Prior to dying out in the UK, the impeachment process was relatively common in the 14th century until the establishment of the Tudor dynasty and secondly in the 17th and 18th centuries.
The procedure was last used, unsuccessfully, in 1806 for Lord Melville (Dundas).