In Pham v Secretary, Department of Education, Employment and Workplace Relations [2009] FCA 1310 the appellant contended that the Governor General was not validity appointed, and thus the judges appointment was not valid. The Court held that the Governor-General was appointed to his office in accordance with the current Letters Patent (as amended on 11 May 2003) by Commission dated 29 July 2003 passed under the Royal Sign Manual and the Great Seal of Australia, and he took oath of allegiance and prescribed oath of office on 11 August 2003.