to the Supreme Court. Former systems Canada In a manner reminiscent of the British House of Lords, members of the Canadian Senate were appointed for life. Since the Constitution Act, 1965, however, senators must retire upon reaching the age of 75. Though senators appointed before the amendment were grandfathered in by the legislation, there are no longer any lifetime senators present in the Canadian Senate. Orville Howard Phillips, the last senator for life, resigned his seat in 1999. France In France, during the Third Republic, the Senate was composed of 300 members, 75 of which were inamovible ("unremovable"). Introduced in 1875, the status was abolished for new senators in 1884, but maintained for those already in office. Émile Deshayes de Marcère, the last surviving sénateur inamovible, died in 1918. Overall there had been 116 lifetime senators. In 2005, there was questioning about the status of former presidents of the Republic. According to the constitution of the Fifth Republic, former presidents are de jure members of the Constitutional Council, which poses a problem of possible partiality. Some members of Parliament and commentators suggested that it should be replaced by a life membership in the Senate. This proposal was, however, not enacted. Romania The 1923 Constitution instituted the membership by right (senator de drept) in the Senate for: the heir-apparent or heir-presumptive to the throne Metropolitan bishops and diocesan bishops of the Orthodox and Greek-Catholic churches heads of state-recognised religious bodies the president of the Romanian Academy former presidents of the Council of Ministers former ministers with at least six years’ seniority former presidents of either legislative chamber who held this function for at least eight ordinary sessions former senators and deputies elected to at least ten legislatures, irrespective of their duration former presidents of the High Court of Cassation and Justice reserve and retired generals former presidents of the National Assemblies at Chişinău, Cernăuţi and Alba Iulia, which proclaimed their respective provinces’ union with Romania in 1918 (see Union of Bessarabia with Romania, Union of Bukovina with Romania and Union of Transylvania with Romania) The membership by right was maintained under the 1938 Constitution and it was abolished together with the Senate on July 15, 1946, by the Communist Party-dominated government of Petru Groza. Although the current constitution of Romania re-established the bicameral Parliament in 1991, it did not reinstate the office of senator by right. South and Central America The