In India, a governor is the constitutional head of each of the twenty-eight states. The governor is appointed by the President of India for a term of five years, and holds office at the President's pleasure. The governor is de jure head of the state government; all its executive actions are taken in the governor's name. However, the governor must act on the advice of the popularly elected council of ministers, headed by the chief minister, who thus hold de facto executive authority at the state-level. The Constitution of India also empowers the governor to act upon his or her own discretion, such as the ability to appoint or dismiss a ministry, recommend President's rule, or reserve bills for the President's assent. Over the years, the exercise of these discretionary powers have given rise