When TN Sashan was heading the one-member Election Commission of India, Prime Minister Narsimha Rao appointed two more commissioners — MS Gill and GVG Krishnamurthy. Seshan challenged the move but in 1995, a Supreme Court bench ruled in a 5–0 decision that the appointment of two additional ECs was legal, that the CEC was only primus inter pares (first among equals), and that the two could overrule the CEC. From that point on, the EC has consistently been a three-member body. And when Seshan’s term ended in December 1996, Gill was named the new CEC.