documents on behalf of the Governor-General. The Governor-General has the power to dismiss any member of the Executive Council, but that power is rarely exercised in practice. It might be exercised if, hypothetically, a minister or former minister were convicted of a serious criminal offence. One notable case was that of the Queensland Senator Glen Sheil. Malcolm Fraser's government was re-elected at the 1977 election on 10 December, and on 19 December he publicly announced the ministry he would be recommending to the Governor-General, which included Senator Sheil as the new Minister for Veterans' Affairs. Sheil was sworn in as an Executive Councillor but, prior to the scheduled swearing-in of the Ministry, he made public statements about apartheid that were at odds with the government's attitude to the issue. Fraser then advised Governor-General Sir Zelman Cowen not to include Sheil in the ministry—advice that Cowen was required by convention to follow. Sheil's appointment as an Executive Councillor without portfolio was terminated on 22 December. Meetings Meetings of the Executive Council do not require the Governor-General's attendance, but the Governor-General must be notified of the meeting in order for it to be valid. A quorum for meetings is the Governor-General and two serving ministers or assistant ministers. If the Governor-General is not in attendance, quorum is the Vice-President and two serving ministers or assistant ministers. In the absence of the Vice-President, quorum is three ministers, one of whom, a senior minister, will preside. In practice, meetings will only be attended by a small number of Councillors rather than the full Cabinet. Most of the powers vested in the Governor-General, such as appointments and the authorisation of budgets, are exercisable only by "the Governor-General in Council" – that is, under advice from the Federal Executive Council. The Council acts as a formal ratification body for decisions of the Cabinet. In a parallel manner to the Royal Assent given to legislative Acts by the Governor-General after they have passed both Houses of Parliament, proposed executive actions will receive the approval of the Governor-General in Council after they have been agreed to by the Prime Minister and Cabinet. An example of a Federal Executive Council meeting which the Governor-General presided over was the meeting on 11 September 2022, when the Executive Council advised the Governor-General David Hurley to proclaim Charles III as the new head of state of Australia. The proclamation of Charles III