Elections for the US Presidency take place every four years, usually on the first Tuesday in November. And yet the new US President is not sworn into office until January 20, a full two and a half months later. In Britain on the other hand the transition from one leader to the next is brutally swift. Within days, even hours, of a change of leadership, TV cameras are set up in Downing Street to show the outgoing Prime Minister with bags packed even as the incoming PM arrives to take his or her place. These are two of the proudest democracies on earth. Is this difference merely a reflection of the Presidential versus the Parliamentary system? Not really. Around the world, democracies manage their leadership transitions  somewhere in between these two extremes.

In the most recent Canadian leadership election on October 19, 2015, Justin Trudeau defeated incumbent Stephen Harper, who had been nine years in office. Trudeau was sworn in on November 4,  15 days later.

The 2013 Australian election took place on September 7. Opposition leader Tony Abbott defeated incumbent Kevin Rudd. He was sworn in as Prime Minister by Governor-General Quentin Bryce on  September 18,  11 days later.

Emmanuel Macron was declared winner of the Presidential elections in France on May 7, 2017. He was sworn in 7 days later, on May 14.

In the 2014 Indian General Election, as always a massive exercise, results were declared on May 16. The BJP won a historic victory over the Congress Party of India, which had been dominant since Independence in 1949. The incoming Prime Minister Narendra Modi was sworn into office on May 20, 4 days later.

What are the advantages of immediate swearing-in? This method can seem, superficially, to be safer. Especially in a tight election, where results might be disputed, it gives no time for extraneous actors to enter the stage, no time for an unstable period when no one is sure exactly who is in charge. The 'lame-duck' period, when an exiting President is about to lose power, is circumscribed. A power vacuum is avoided. In Sierra Leone, in the 1967 elections, the outcome was in dispute for several days, with the competing parties neck and neck, and a few independent MPs undecided. Eventually, in the confusion, the military stepped in and seized power for itself. With immediate swearing-in once the Chief Electoral Commissioner or his equivalent, announces the final result, the winner is sworn in. Period. On the same day even. In Sierra Leone the haste can seem precipitous. Especially when, as required by the Constitution, the swearing-in is done by the Chief Justice. In recent Sierra Leone elections, the top judge has been unceremoniously hauled from rest to perform this duty, even at night! (This is quite reminiscent of the  first act of Sierra Leone coup makers, which has been to call upon the CJ, guns at the ready, to perform this all-important ceremony!) No doubt all concerned understand or at least hope that once the ceremony is performed by the Chief Justice, the judiciary would be severely hampered in the event that it was called upon to adjudicate on the manner they came to office.

This leads us to one of the main benefits of delayed swearing-in: the opportunity for appeals by the losing side and judicial review of the conduct of the Elections Commission. Theoretically, such judicial review conducted whilst the incumbent leader, who may not be an active contestant, is still in office provides an opportunity for a genuinely independent, neutral process and avoids the potentially very messy business of "un-swearing-in" a new President. Even if the incumbent leader is an active contestant in the election he has not been afforded the protection of an immediate swearing-in before judicial review. In the 2017 general elections in Kenya, the incumbent Uhuru Kenyatta was declared the winner by the electoral commission on August 11. His opponent, Raila Odinga, disputed the results and announced he would challenge them in the Kenya Supreme Court. Swearing-in was delayed and to their great credit, the Kenya Supreme Court, having heard the available evidence, was courageous enough to nullify the results and order that a new election be held. This was duly conducted, although eventually Odinga declined to participate, and Kenyatta was eventually sworn-in for his second term on November 28.

Judicial review however raises the question of whether judges are well placed to decide on the technicalities of electioneering. Granted that all human activities are subject to law, there are, however, many technical activities that require in court the advice of technical experts. If the Electoral Commission are in fact the best-placed technical experts to decide on an election outcome (and who else might be better placed?) might it not be superfluous to call upon the judiciary to oversee their work? If one accepts this argument then perhaps immediate swearing-in, a la the Sierra Leone style, can be justified.

In the American system, with a long delay between announcement and swearing-in, it is claimed that this period is necessary in order for one administration to smoothly transition into another, for officials to prepare proper handing-over notes, brief their incoming counterparts and the like. It could be argued that in a non-antagonistic setting all this may be done even after the incoming officials have assumed office.

Delayed swearing-in, though, especially the longer delays, gives the appearance of fairness and of supreme confidence in the stability of the political system.

In Nigeria, notorious for instability, coup and counter-coup little more than a generation ago, a leisurely swearing-in, unconcerned with security issues,  now seems to be the norm. The 2015 general elections were held on 28 and 29 March, 2015. Challenger Muhammadu Buhari defeated incumbed President Jonathan Goodluck. The incoming President was sworn in on May 29, two months later. In 2019,  Buhari was reelected in the elections of February 23. Results were announced a few days later, but the delay till swearing-in, again on May 29, was a full three months.

Ghana, no stranger to political instability in the 1960s, 70s and 80s, now seems unworried about its ability to effect peaceful political transition. In the 2016 Ghanaian General Elections, held on December 7, results were announced on December 9, with Nana Akufo-Addo defeating incumbent John Mahama for the Presidency. Akufo-Addo was sworn into office on January 7, 2019, 29 days after the announcement of results.

In South Africa, the President is answerable to his party and can be recalled by the party executive. Since the end of apartheid, with the powerful African National Congress dominant in South African politics, the South African presidency has been decided by the ANC as much as by a national vote. Once the ANC announced its decisions, South African Presidents Thabo Mbeki (2008) and Jacob Zuma (2018) were replaced and their successors sworn in within a matter of days.