In 1975, John Bloomfield's portrait of Tim Burstall was rejected because it had been painted from a photograph, and not from life. The prize was then given to Kevin Connor. John Bloomfield took action in 1981 saying that the winner that year, Eric Smith had not painted his subject from life. In 1983 John Bloomfield went to court to try to get back the 1975 prize but was unsuccessful. In 1995 the application form of the Archibald Prize was changed to make it clear that the subject must be painted from life.