ban on political activities. They were put on trial, found guilty, and fined, but resumed publication in November 1994 as a non-partisan newspaper. Parliamentary career, arrest and presidential campaign Sallah again unsuccessfully contested the Serekunda East constituency in the 1997 election but was elected to the new constituency of Serekunda Central in the 2002 parliamentary election. As the United Democratic Party (UDP) had boycotted the election, the PDOIS, with two seats, emerged as the largest opposition party, and Sallah became the Minority Leader in the National Assembly. He also served as a member of the Pan-African Parliament in this period. In June 2005, he was expelled from the National Assembly along with three other opposition MPs on the grounds of dual party membership. NADD, an opposition alliance that the PDOIS had joined earlier that year, had been registered as a political party, and the Supreme Court of the Gambia ruled that holding dual membership was against the Gambian Constitution. Some criticised the ruling, claiming that it was a move to silence parliamentary opposition as there was nothing in the Constitution that regulated political parties. On 29 September, a by-election was held in Serrekunda Central, in which Sallah was re-elected by a "huge" margin. On 15 November 2005, he was arrested along with two other opposition leaders on the grounds of subversion, accused of having collaborated with the President of Senegal. The charges, however, were dropped following the intervention of Olusegun Obasanjo, then-President of Nigeria. Sallah was NADD's candidate in the 2006 presidential election, where he came third and won 5.98% of the vote. During the election, the US Embassy described Sallah as "known and respected throughout the country and abroad for his constant admonishment of President Jammeh's government for its failure to adhere to the country's constitution and the principles of democracy." They also wrote: "A win by Halifa Sallah would almost certainly usher in a new era in Gambian government and politics. Sallah's ideas are consistent with democratic principles and we would expect a Sallah administration to be a reliable friend of the US." Further arrests, 2016 campaign and Barrow presidency He lost his seat in the National Assembly in the 2007 parliamentary election to Sainey Jaiteh, a member of the ruling APRC. While not mentioning Sallah by name, Yahya Jammeh made a coded reference to him and Hamat Bah when he expressed his satisfaction at the defeat of