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If Ludlam had resigned from the Senate in the normal manner, the party would have had a choice about who they ran, and my understanding was there was a number of contenders in the wings, JSJ was not one of them.
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But because Ludlam was disqualified due to citizenship, the seat was filled by a recount, and JSJ was automatically elected. Steele-John could have chosen to resign and let the party conduct a full preselection, but didn't. Since then, he has been preselected and elected, but always from incumbency.