John O'Donovan, a Fine Gael TD, challenged the Electoral Amendment Act 1959, which had been passed by a previous Fianna Fáil government, on the basis that there were "grave inequalities" with "no relevant circumstances to justify" them. In "O'Donovan v. Attorney-General" (1961), the Supreme Court held that the Act was unconstitutional and suggested that the ratio of representation to population across constituencies should differ by no more than 5%. The court, interpreting the "so far as it is practicable" condition of the Constitution, suggested a 5% variation as the limit without exceptional circumstances.