From the 1860s, Irish Republican Brotherhood (IRB) leaders Charles Kickham and John O'Leary favoured abstentionism. In 1869, G. H. Moore suggested nominating imprisoned republicans for election, knowing they were precluded as convicted felons from taking seats. On this basis, Jeremiah O'Donovan Rossa (in 1870) and John Mitchel (twice in 1875) were returned at by-elections in Tipperary; O'Donovan Rossa was in prison at his election, while Mitchel was in exile. Kickham envisaged a "great national conference" calling on Irish MPs to withdraw from Westminster. A motion to that effect was proposed by Charles Guilfoyle Doran and passed at the convention of the Home Rule League (HRL). "Honest" John Martin, "independent nationalist" MP for Meath from 1871 to 1875, spoke in Westminster only to raise nationalist protests, and refused to vote. In the 1874 election, 59 HRL MPs were returned, including John O'Connor Power in Mayo, who was a member of the IRB Supreme Council. He was to fall out with the IRB over allegations of misappropriating election funds, and became progressively less radical. O'Connor Power believed that Westminster was the best platform to argue Ireland's case for self-government. Withdrawal from Parliament would be an abandonment of the Home Rule party to those who favoured conciliation rather than confrontation. By 1876 it was clear that the HRL would never be able to organise a national convention, and MPs elected with its endorsement would remain at Westminster. An alternative to abstentionism was obstructionism, including the use of filibuster. This was practised by the HRL and its successor, the IPP under Charles Stuart Parnell from the late 1870s. Arthur Griffith's "Sinn Féin Policy", formulated between 1905 and 1907, called for Irish MPs to abstain from Westminster and sit in a parallel parliament in Dublin. The first Sinn Féin abstentionist candidate was Charles Dolan in 1908. Having sat as MP for North Leitrim for the IPP, he resigned after joining Sinn Féin, and lost the ensuing by-election. Laurence Ginnell's 1909 proposal that the United Ireland League (UIL) adopt abstentionism caused a near-riot; he left the UIL but continued to sit at Westminster until he joined Sinn Féin in 1917. Abstentionism was opposed by most nationalists, especially after the January 1910 general election when the IPP held the balance of power at Westminster and secured passage of the Third Home Rule Bill from the Liberal government.