mandate to obey the advice of the Prime Minister and the Council, Article 75 declares that both "shall hold office during the pleasure of the President." This means the President has the constitutional power to dismiss the Prime Minister or Council at anytime. If the Prime Minister still retained a majority vote in the Lok Sabha, however, this could trigger a constitutional crisis because the same article of the Constitution states that the Council of Ministers is responsible to the Lok Sabha and must command a majority in it. In practice the issue has never arisen, though President Zail Singh threatened to remove Prime Minister Rajiv Gandhi from office in 1987. Presidential Power to Legislate When either or both Houses of Parliament are not in session, the Prime Minister, acting via the President, can unilaterally exercise the legislative power, creating ordinances that have the force of law. These ordinances expire six weeks after Parliament reconvenes or sooner if both Houses disapprove. The Constitution declares that ordinances should only be issued when circumstances arise that require "immediate action." Because this term is not defined, governments have begun abusing the ordinance system to enact laws that could not pass both Houses of Parliament, according to some commentators. This appears to be more common with divided government; when the Prime Minister's party controls the lower house but not the upper house, ordinances can be used to avoid needing the approval of the opposition in the upper house. In recent years, around ten ordinances have been passed annually, though at the peak of their use, over 30 were passed in a single year. Ordinances can vary widely on their topic; recent examples of ordinances include items as varied as modifications to land owner rights, emergency responses to the COVID-19 pandemic, and changes to banking regulations. Federalism The first article of the Constitution declares that India is a "Union of States." Under the Constitution, the States retain key powers for themselves and have a strong influence over the national government via the Rajya Sabha. However, the Constitution does provide key limits on their powers and gives final say in many cases to the national government. State Powers in the Constitution Rajya Sabha At the Union level, the States are represented in the Rajya Sabha or Council of States. The Fourth Schedule of the Constitution lays out the number of seats that each State controls in