upheld. Oldham East and Saddleworth On 28 May 2010, the defeated Liberal Democrat candidate Elwyn Watkins lodged a petition against the election of Phil Woolas (Labour) in Oldham East and Saddleworth constituency. The petition challenged leaflets issued by Woolas's campaign as having contained false statements of fact concerning Watkins' personal character, which is an illegal practice under section 106 of the Representation of the People Act 1983. The statements attempted to link Watkins with Muslim extremists and death threats to Woolas, accused him of reneging on a promise to live in the constituency, and implied that his campaign was funded by illegal foreign political donations. During the court case a number of emails between Woolas and his campaign team emerged. In one, Woolas's agent, Joe Fitzpatrick, emailed Woolas and campaign adviser Steven Green, to say: "Things are not going as well as I had hoped ... we need to think about our first attack leaflet." A reply from Fitzpatrick said: "If we don't get the white vote angry he's gone." The court hearing finished on 17 September 2010, with the judges reserving their judgement until 5 November 2010. On that day Woolas was found to have breached section 106 of the Representation of the People Act 1983 in relation to three of the four statements complained about, and the judges ruled that his election was void. Phil Woolas applied for a judicial review into the ruling, stating that "this election petition raised fundamental issues about the freedom to question and criticise politicians" and that it "will inevitably chill political speech". He succeeded in overturning the finding in respect of one of the three statements but the main findings of the election court judgment were upheld. A by-election on 13 January 2011 resulted in the election of Debbie Abrahams (Labour). Analysis At 9:41 on 7 May, the BBC confirmed a hung parliament. The Conservatives stood at 290 seats, Labour at 247 and Liberal Democrats at 51. One constituency seat (Thirsk and Malton) was contested on 27 May because of the death of the UKIP candidate and was won by the Conservative Party, whilst another seat (Oldham East and Saddleworth) later had its result declared void; Labour won the resulting by-election. The result showed an overall 5.1% swing from Labour to the Conservatives, the third largest national swing achieved in a General Election since 1945 and similar to the 5.3% swing achieved