ordinarily possessed by citizensparticularly a "right of abode" allowing entry, residence and employment, as well as eligibility to vote and even to sit in the country's parliament. The most relevant example is that, in the UK, a citizen of a Commonwealth country counts as a "Commonwealth citizen" (i.e. of the Commonwealth of Nations, not to be confused with citizenship of the Commonwealth of Australia). Sarina v O'Connor (1946) and Crittenden v Anderson (1950) Following the 1946 federal election, an unsuccessful candidate for West Sydney, Ronald Grafton Sarina, petitioned the High Court to declare the election of William O'Connor void under s 44(i), claiming that as a Roman Catholic, O'Connor was under an allegiance to a foreign power. In December that year, Sarina's solicitor sought leave to withdraw the petition, which was granted. A similar case arose in 1950, with independent candidate Henry William Crittenden petitioning for Gordon Anderson (Kingsford Smith) to be disqualified on the basis of his Catholicism. Justice Fullagar ruled against Crittenden, saying that were his premise to be sustained, it would prevent any Catholic from holding a seat in the Australian parliament. The decisive factor was that to exclude Catholics from the parliament would be to impose a "religious test" for public office, contrary to Constitution s 116. Fullagar J also said that the petition invited analysis of the relations between church and state over centuries, the relationship between Italy and the Papal States, and the sovereignty of the Vatican City Statenone of which, in his opinion, was relevant to the election of an Australian member of parliament. The case was dismissed, with Crittenden ordered to pay Anderson's costs. Nile v Wood and Re Wood (1987) Robert Wood was elected as a Senator for NSW in 1987. The Call to Australia party's Elaine Nile challenged his election on grounds that included that "His actions against the vessels of a friendly nation indicate allegiance, obedience or adherence to a foreign power". This related to Wood being fined $120 for paddling a kayak in front of the US warship in Sydney Harbour. The High Court, Brennan, Deane and Toohey JJ, dismissed the petition in December 1987 on technical grounds. The brief judgment made a number of observations about subsection 44(i), relevantly including that it required an identified foreign power and an acknowledgement of allegiance. It was later discovered that Wood had not been an Australian citizen at the time