after a recount. At the time of nomination, Bartlett had been an academic employed by the Australian National University. He claimed to have legal advice that this did not disqualify him under s 44(iv) and his eligibility was not challenged at the same time as that of Hughes. However, the Commonwealth Solicitor-General has suggested that the Senate may need to refer his position to the High Court and the Greens are seeking further legal advice. Steve Martin (2018) After Senator Jacqui Lambie was found to be ineligible under s 44(i) owing to foreign citizenship, her apparent successor was deemed to be Steve Martin. Martin was mayor of Devonport, Tasmania throughout the period of the election; the question arose whether this was an office of profit under the Crown. The parties agreed that his position was an "office", that it was "of profit" and that the Executive branch of the Government of Tasmania was an element of "the Crown"; the issue was whether the office was "under" the Crown. This was understood to turn upon whether the executive government had "effective control" over appointment to the office (which was by election) or over the tenure or conduct of the office. The High Court, sitting as the federal Court of Disputed Returns on a reference from the Senate, reviewed the Australian and prior English history of the term "office of profit" and determined unanimously that Martin was not ineligible by reason of s 44(iv), there not being a sufficient degree of ministerial control over the tenure or conduct of the office of mayor. Martin was the second-listed candidate for the Jacqui Lambie Network party in Tasmania. When found to be eligible, he could have stepped down, creating a casual vacancy to which Lambie could have been appointed. He refused to step down and was expelled from the party for disloyalty. He took his seat as an independent. (v) Pecuniary interest in an agreement with the Commonwealth As with subsection 44(iv), the aim of subsection 44(v) is to prevent corruption of members by the Executive. It is also to avoid a conflict of interest that could lead a member of the Parliament to give priority to their own financial interest over impartial judgement of policy. Re Webster (1975) What constituted a "pecuniary interest" did not arise for consideration by the High Court until 1975 when the Senate referred questions concerning the eligibility of