three months of the appointment. The prime minister and treasurer are traditionally members of the House, but the Constitution does not have such a requirement. Before being sworn in as a minister of state, a person must first be sworn in as a member of the Federal Executive Council if they are not already a member. Membership of the Federal Executive Council entitles the member to the style of The Honourable (usually abbreviated to The Hon) for life, barring exceptional circumstances. The senior members of the Executive Council constitute the Cabinet of Australia. The prime minister is, like other ministers, normally sworn in by the governor-general and then presented with the commission (letters patent) of office. When defeated in an election, or on resigning, the prime minister is said to "hand in the commission" and actually does so by returning it to the governor-general. In the event of a prime minister dying in office, or becoming incapacitated, or for other reasons, the governor-general can terminate the commission. Ministers hold office "during the pleasure of the governor-general" (s. 64 of the Constitution of Australia), so in practice, the governor-general can dismiss a minister at any time, by notifying them in writing of the termination of their commission; however, their power to do so except on the advice of the prime minister is heavily circumscribed by convention. 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