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Source: 2001 Tamil Nadu Legislative Assembly election

The twelfth legislative assembly election of Tamil Nadu was held on 10 May 2001. All India Anna Dravida Munnetra Kazhagam (AIADMK)-led front won the elections and its general secretary, J. Jayalalithaa was sworn in as Chief Minister, even though she could not legally run as MLA in this election. She was unanimously nominated as Chief Minister by her party and was ready to serve her second term. But due to criminal and corruption charges from her first term, on 21 September 2001, a five-judge constitutional bench of the Supreme Court of India ruled in a unanimous verdict that "a person who is convicted for a criminal offense and sentenced to imprisonment for not less than two years cannot be appointed the Chief Minister of a State under Article 164 (1) read with (4) and cannot continue to function as such". Thereby, the bench decided that "in the appointment of Dr. J. Jayalalithaa as Chief Minister there has been a clear infringement of a Constitutional provision and that a writ of quo warranto must issue". In effect, her appointment as Chief Minister was declared null and invalid with retrospective effect. Therefore, technically, she was not the Chief Minister in the period between 14 May 2001 and 21 September 2001. After her resignation on 21 September 2001, she put in O. Panneerselvam, as the official 13th Chief Minister of Tamil Nadu, until she could clear up the charges from her first term, so she can take up the mantle of Chief Minister officially, on 2 March 2002.