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Representative democracy, also known as indirect democracy, is a type of democracy where elected people represent a group of people, in contrast to direct democracy. Nearly all modern Western-style democracies function as some type of representative democracy: for example, the United Kingdom (a unitary parliamentary constitutional monarchy), Germany (a federal parliamentary republic), France (a unitary semi-presidential republic), and the United States (a federal presidential republic). Representative democracy can function as an element of both the parliamentary and the presidential systems of government. It typically manifests in a lower chamber such as the House of Commons of the United Kingdom, and the Lok Sabha of India, but may be curtailed by constitutional constraints such as an upper chamber and judicial review of legislation. Some political theorists (including Robert Dahl, Gregory Houston, and Ian Liebenberg) have described representative democracy as polyarchy. Representative democracy places power in the hands of representatives who are elected by the people. Political parties often become central to this form of democracy if electoral systems require or encourage voters to vote for political parties or for candidates associated with political parties (as opposed to voting for individual representatives). The power of representatives is usually curtailed by a constitution (as in a constitutional democracy or a constitutional monarchy) or other measures to balance representative power: An independent judiciary, which may have the power to declare legislative acts unconstitutional (e.g. constitutional court, supreme court). The constitution may also provide for some deliberative democracy (e.g., Royal Commissions) or direct popular measures (e.g., initiative, referendum, recall elections). However, these are not always binding and usually require some legislative action—legal power usually remains firmly with representatives.