an appointment—for example, Ron Davies resigned in Victoria Park in 1986 to become Agent-General for Western Australia in London, whilst Deputy Premier Herb Graham resigned in Balcatta in 1973 to become chairman of the Licensing Board. "Holds an office or place in the service of the Crown" at the time at which they take up their seat (Section 36-37). This has never been used at state level, although it has occurred in other States and in the Federal Parliament (for example, the circumstances leading to the federal Lindsay by-election in 1996.) Becomes "of unsound mind". Pledges allegiance to a foreign power after their election. This does not apply to members who are already dual citizens at the time of their election, unlike the equivalent section in the Federal Constitution. Fails to attend the House for one entire session without the permission of the House. The last time this caused a by-election was in 1915 when Joseph Gardiner, the Labor member for Roebourne, disappeared, necessitating a by-election in which an Opposition candidate was victorious, wiping out the Government's one-seat majority. Additional reasons not within Section 38 include: Death. This last occurred in January 2008, when Trevor Sprigg, the member for Murdoch, died suddenly and a by-election had to be called. Resignation, "by writing under his hand, addressed to the Speaker" (Section 25). This last occurred in September 2014, when Troy Buswell, the member for Vasse, resigned from the Parliament, necessitating a by-election. A Court of Disputed Returns voids the results. The last time a by-election took place for this reason was in 1983, when Gavan Troy, the Labor candidate, narrowly defeated incumbent Liberal member Tom Herzfeld in Mundaring. The seat was won by Troy by a larger margin at the resulting by-election. Ministerial by-elections Until a constitutional amendment in 1947, it was necessary for members who were appointed as a Minister to resign their seat and contest their seat at a ministerial by-election. This was because the Ministers became members of the Executive Council, which reported to the Governor of Western Australia and was therefore deemed an "office of profit" under the Crown. Most ministerial by-elections were a formality with the Minister being re-elected unopposed, but on two occasions, in 1901 and 1917, Ministers were defeated at the by-elections, in the former case directly causing the fall of the Morgans Ministry. List of Legislative Assembly by-elections 2020–2029 2010–2019 2000–2009 1990–1999 The