According to convention, the prime minister is the leader of the majority party or largest party in a coalition of parties in the House of Representatives which holds the confidence of the House. The governor-general may also dismiss a prime minister who is unable to pass the government's supply bill through both houses of parliament, including the Australian Senate, where the government doesn't normally command the majority, as happened in the 1975 constitutional crisis. Other commentators argue that the governor-general acted improperly in 1975 as Whitlam still retained the confidence of the House of Representatives, and there are no generally accepted conventions to guide the use of the governor-general's reserve powers in this circumstance. However, there is no constitutional requirement that the prime minister sit in the House of Representatives, or even be a member of the federal parliament (subject to a constitutionally prescribed limit of three months), though by convention this is always the case. The only case where a member of the Senate was appointed prime minister was John Gorton, who subsequently resigned his Senate position and was elected as the member for Higgins in the House of Representatives.