The second legislative council election to Madras Presidency after the establishment of diarchical system of government by the Government of India Act, 1919 was held in 1923. Voter turnout was higher than the previous election. Swarajists, a breakaway group from Indian National Congress participated in the election. The ruling Justice Party had suffered a split, when a splinter group calling themselves anti-Ministerialists left the party. It won the highest number of seats but fell short of a majority. Nevertheless, Madras Governor Willington invited it to form the government. Incumbent Justice chief minister Panagal Raja was nominated by party leader Theagaraya Chetty to continue as chief minister for a second term. The government survived a no-confidence motion (with the support of non-elected members), brought against it on the first day of its tenure by the opposition headed by C. R. Reddy.
Background
Split in Justice Party
Constant infighting within the Justice Party led to the creation of a group calling themselves anti-ministerialists. This group included notable members like C. Natesa Mudaliar, T. A. Ramalingam Chettiar, C. R. Reddy and P. Subbarayan. They challenged Theagaroya Chetty's leadership alleging that he was exercising autocratic control over the party. Chetty's support for British oppression of the Non-cooperation movement was disapproved by members of his party including Subbaroyan and R. K. Shanmugam Chettiar. Inclusion of no Tamil members by Theagaroya Chetty in the ministry caused resentment among Tamil members. Members of the previous ministry Raja of Panagal and Kurma Venkata Reddy Naidu were Telugu members and A. P. Patro was from Orissa. Theagaroya Chetty also had Telugu ancestry.
Birth of Swarajists
The years after the 1920 election witnessed major developments at the national level. Gandhi and his followers including C. Rajagopalachari strongly believed in Congress not participating in the elections. However, Chittaranjan Das (C. R. Das), Motilal Nehru and few others encouraged Congress participation in election. The party passed a resolution on 7 September 1922 to allow its members to stand as candidates and participate in the elections. C. R. Das's attempt to move a resolution advocating active participation in elections, at the Congress meeting held in Gaya in December 1922 after the imprisonment of Gandhi failed. Soon afterwards, C. R. Das and his followers formed Swaraj Party on 1 January 1923. Their platform included fighting the elections and participating in the elections and continue non-cooperation from within the diarchy. However, they did not secede from Congress and remained as a Pressure group within the Congress. After much debate between the pro- and anti-Council entry members within the Congress, a special meeting held in late September 1923 in Delhi authorised willing Congressmen to participate in elections while reinstating its commitment to non-cooperation. Rajagopalachari who did not attend the meeting expressed his support for Council entry. Despite his national support for Council entry, he continued working against it in Tamil Nadu. After Gandhi was released from Jail in February 1924, he was willing to accommodate the Swarajists in the Congress fold while expressing dislike for Council entry. He advised Rajaji also to follow a similar course in Madras and it was not until 1925 Rajaji publicly accepted Gandhi's advice. S. Srinivasa Iyengar joined the Swarajists and became the leader of the party machinery for the Madras Presidency.
Constituencies
The Madras Legislative Council had a total of 127 members in addition to the ex–officio members of the Governor's Executive Council. Out of the 127, 98 were elected from 61 constituencies of the presidency. The constituencies comprised three arbitrary divisions – 1)communal constituencies such as non-Muhammadan urban, non-Muhammadan rural, non-Brahman urban, Mohamaddan urban, Mohamaddan rural, Indian Christian, European and Anglo-Indian 2)special constituencies such as landholders, Universities, planters and trade associations (South India Chamber of Commerce & Nattukottai Nagarathar Association) and 3) territorial constituencies. 28 of the constituencies were reserved for non-Brahmans. 29 members were nominated, out of whom a maximum of 19 would be government officials, 5 would represent the Paraiyar, Pallar, Valluvar, Mala, Madiga, Sakkiliar, Thottiyar, Cheruman and Holeya communities and 1 would represent the "backward tracts". Including the Executive Council members, the total strength of the legislature was 134.