The Governor-General has the power to dismiss any member of the Executive Council, but that power is rarely exercised in practice. It might be exercised if, hypothetically, a minister or former minister were convicted of a serious criminal offence. One notable case was that of the Queensland Senator Glen Sheil. Malcolm Fraser's government was re-elected at the 1977 election on 10 December, and on 19 December he publicly announced the ministry he would be recommending to the Governor-General, which included Senator Sheil as the new Minister for Veterans' Affairs. Sheil was sworn in as an Executive Councillor but, prior to the scheduled swearing-in of the Ministry, he made public statements about apartheid that were at odds with the government's attitude to the issue. Fraser then advised Governor-General Sir Zelman Cowen not to include Sheil in the ministry—advice that Cowen was required by convention to follow. Sheil's appointment as an Executive Councillor without portfolio was terminated on 22 December.