From 1984, opposition politicians began being elected in parliament. 2 seats out of 74 seats went to opposition politicians. Subsequently, in 1988, the People's Action Party won 76 out of 77 seats; in 1991, People's Action Party won 77 seats out of 81 seats. In 1997, 2001 and 2006, 2 opposition candidates were elected during each respective parliamentary election. In 1988, former solicitor general of Singapore and opposition politician Francis Seow was also detained without trial. He was later charged with tax evasion but he fled overseas and sought asylum successfully in the United States of America. He was convicted of tax evasion "in absentia". Workers' Party member Gopalan Nair also fled Singapore in the 1990s. Dr Catherine Lim argues that a climate of fear hurts Singapore. Prominent opposition politicians bankrupted and/or jailed in the 20th century also include Joshua Benjamin Jeyaretnam, Tang Liang Hong and Chee Soon Juan.