The above is not an exhaustive list, and new situations may arise. The most notable use of the reserve powers occurred in November 1975, in the course of the 1975 Australian constitutional crisis. On this occasion the governor-general, Sir John Kerr, dismissed the government of Gough Whitlam when the Senate withheld Supply to the government, even though Whitlam retained the confidence of the House of Representatives. Kerr determined that he had both the right and the duty to dismiss the government and commission a new government that would recommend a dissolution of the Parliament. Events surrounding the dismissal remain extremely controversial.