Why the consultation on cohabitation rights is to be welcomed

In 2021, I published a book entitled Religion and Marriage Law: The Need for Reform. Most of that book focused on the need to modernise the law on how to get married but the penultimate chapter focused on cohabitation rights. That chapter might be seen as an afterthought. But, as I pointed out in the introduction to that chapter, ‘it was in many ways the most important’ of the reform proposals I was advocating. The new Government consultation, A Fairer End to Relationships, is to be welcomed, therefore, since it includes proposals to give cohabitation rights on separation and death alongside modernising the law on financial remedies on divorce.

Why cohabitation rights matter 

From a religious perspective, the cohabitation rights proposed in A Fairer End to Relationships may cause concern for some in terms of seemingly undermining the status of marriage. Such fears are ill-founded. Under these proposals, the rights afforded to cohabitants will still differ and be less than those enjoyed by married couples and civil partners. Moreover, giving cohabitating couples in England and Wales the kind of rights that they enjoy in many other jurisdictions would make a major difference to the issue of what have been called ‘unregistered religious marriages’, ‘religious only marriages’ or ‘non-qualifying ceremonies’. These exist where the couple undergo a wedding ceremony that does not comply with the Marriage Act 1949. Religious marriages are recognised under the Act but in relation to religious weddings other than Church of England, Quaker and Jewish ceremonies the ceremony must take place in a registered place of religious worship in order to be legally binding. It therefore excludes religions that do not have such buildings or do not have a tradition of getting married in such buildings. Though the couple are married in the eyes of their faith, they are not married in the eyes of the law.

There are all sorts of reasons why couples might have unregistered religious marriages: it may be the choice of the parties (in some communities, religious marriages effectively allow the couple to date, to be together without a chaperone), it may be because the parties are unsure of the law or it might be because it is difficult or impossible for a religious ceremony reflecting their beliefs to be held in a way that is compatible with marriage law requirements. What is clear is that couples who are in such relationships have no legal redress on relationship breakdown on the basis of their relationship (as opposed in relation to property or children) and this does lead to hardship, especially where one or both of the parties are unaware of this.

This is perhaps epitomised by the facts that led to the case of HM Attorney General v Akhter & Ors [2020] EWCA Civ 122. In 1998, Nasreen Akhter and Mohammed Shabaz Khan had a nikah ceremony. They intended to register the marriage under civil law but never got around to it and indeed as time went on Khan refused to register it. They had four children together and while they lived in Dubai between 2005 and 2011 they were considered by the authorities there to be validly married. After 18 years and back in the UK, the relationship broke down in 2016 and Akhter issued a petition for divorce from Khan. At first instance, Mr Justice Williams took a ‘holistic’ view to conclude that this should be treated as a void marriage and so entitled to legal redress. The Attorney General appealed and the Court of Appeal rejected such creativity holding that there was no ceremony under the Marriage Act. Such a ‘non-qualifying ceremony’ was outside the scope of marriage and divorce legislation. Akhter and Khan were cohabitants and denied any legal redress on grounds of relationship status.

This case highlighted the lack of redress for those who are in unregistered religious marriages either where this is unwitting on the part of one or both of the parties or where this is not agreed by one of the parties (such as in this case where the husband promised that they would comply with marriage registration laws at a later date). The fact that such couples have no redress under English law has often meant that they seek a remedy instead from religious courts, tribunals or councils. Numerous empirical studies have shown that a number of the marital status cases decided by such bodies concern couples who are not married under English law. And in such cases, these religious authorities are the only place that couples can turn to, which is problematic to say the least.

Providing some rights to cohabitants on relationship breakdown would provide some redress. It would not recognise their marriage – and that is why reform of the law on cohabitation is needed alongside reform of the law on getting married (a consultation on that is promised by the government before the summer recess). But it would mean that claimants like Akhter would receive some redress from English law – and that there would always be the option of such redress in addition to going to a religious court, tribunal or councils. Such bodies would then always be a form of alternative dispute resolution rather than the only option as they presently are.

What is being proposed? 

That penultimate chapter in Religion and Marriage Law: The Need for Reform surveyed the various approaches taken to cohabitation rights on separation neighbouring jurisdictions as well as the models proposed by the Law Commission and under private member Bills. It concluded that these various approaches actually had much in common. Three main characteristics of a scheme were distilled and these three characteristics can also be found in the proposals found in A Fairer End to Relationships.

The first characteristic is that the scheme would apply if the couple meet the definition of being cohabitants. Some proposals provided more details as to what would be considered as part of the definition of the term cohabitants than others but they tended to agree that having a child together or living together for a certain amount of time was required. This is reflected in the proposals in A Fairer End to Relationships. It is proposed that the new system would apply ‘where two people are living together as a couple in an enduring family relationship’. Courts would determine this using ‘a non-exhaustive checklist of factors’. Both of the parties would need to be over 18 and cannot be relatives or those who are married or in a civil partnership (who would have access to the separation rights available there). The system would be restricted to couples who have been living together for three years or have had a child together. Individuals would need to make an application within two years of separation for the claim to be considered by a court. These requirements largely follow the Law Commission’s 2007 recommendations.

The second characteristic is that the statutory scheme will apply to cohabitants on separation provided that they have not opted-out. The various proposals often prescribed what form that the opt out would need to take to be effective. This opt out rather than opt in requirement would ensure that cohabitation rights are afforded to couples who are choosing to cohabit thinking that they will accrue marriage-like legal rights as well as those where there is an intention to marry but the couple do not get around to it. The proposals in A Fairer End to Relationships follow such an opt-out approach, suggesting statutory safeguards based on the Law Commission’s recommendations in its 2014 Report, Matrimonial Property, Needs and Agreements, on pre-nuptial and post-nuptial agreements: in short, a valid contract, made by deed, agreed after each party has received disclosure of material information about the other party’s financial situation and after each party has received independent legal advice.

The third and final characteristic is that the scheme would allow a cohabitant to seek a remedy on separation if certain circumstances are met. Here, the various proposals differed with Lord Lester’s Cohabitation Bill simply stating that the court could make a financial order if ‘having regard to all the circumstances, the court considers that it is just and equitable to make an order’. The other proposals were not broad but instead provided slightly different lists of factors for the court to take into account. A Fairer End to Relationships states that the Government has decided against the ‘compensation-based’ approach proposed by the Law Commission and proposes instead a ‘needs-based’ approach that follows the proposals in respect of divorce but makes several modifications to underline the differences between marriage (and civil partnership) as opposed to cohabitation. Courts would not have the same discretion to meet needs as they have in divorce cases. In assessing needs in cohabitation cases, a two-stage approach would be taken: beginning with children’s needs and followed by the individual’s own financial needs. There would be no equivalent of the third stage proposed for divorce cases that would involve consideration of discretionary needs (that is, the consideration of ‘lifestyle luxuries’). A list of factors would be considered by the court when deciding what is a fair ‘needs-based’ assessment: earning capacity; financial resources of each individual; any physical or mental disability; age; and length of relationship. Where the qualifying criteria is met, it is proposed that courts would have access to a broad set of remedies ‘which reflect what is available on divorce, including property adjustment orders, lump sum orders and pension sharing orders’. The court would also have access to maintenance orders, ‘although the government proposes these would only be available in exceptional circumstances’.

Concluding thoughts

As with any consultation, there is a debate to be had in relation to the details and in particular to the similarities and differences between the frameworks that would apply to the end of cohabiting relationships compared to the end of marriages and civil partnerships. Yet, overall, the need for such reform is clear. Some carefully defined cohabitation rights on separation are needed not only because of the huge numbers of people in such relationships generally who currently lack redress (often unwittingly), but also because of the problem of unregistered religious marriages in particular. As I have argued in Religion and Marriage Law: The Need for Reform and subsequent publications, there is a need for reform of both of the law on getting married and of cohabitation rights. These two reforms would complement each other. Reform of the law on getting married will inevitably not recognise all forms of relationship and so without cohabitation rights on separation, some couples will be denied protection, including some parties who did not wittingly and voluntarily assent to this. The introduction of cohabitation rights alone would not recognise religious weddings that cannot meet the legal requirements as marriages (with all the rights that this would bring). Both are needed. Reform of the law on getting married would extend the types of weddings that are legally recognised, removing the discrimination found in the archaic legal framework, while cohabitation rights on separation would provide a back-stop protection for those whose marriages continue not to be recognised by the State. It is to be hoped that the promised consultation on reforming the law on getting married will shortly follow A Fairer End to Relationships and that both will quickly lead to legislation. Indeed, it would make sense for the changes to appear in the same bill, bringing the law on adult intimate relationships fully into the twenty-first century.

The consultation is open now and runs until 14 August.

Thanks to Professor Sharon Thompson for her comments on a draft of this post. All errors remain my own.

Russell Sandberg

Cite this article as: Russell Sandberg, “Consultation on cohabitation rights: a welcome development” in Law & Religion UK, 8 June 2026, https://lawandreligionuk.com/2026/06/08/consultation-on-cohabitation-rights-a-welcome-development/.

The Government has accepted Lord Mann’s recommendations on tackling antisemitism in the NHS. In the wake of a series of attacks on the Jewish community, including intimidation and abuse within the NHS, in October 2025 the former Secretary of State and the Prime Minister commissioned Lord Mann to lead an urgent review into how the NHS and its regulatory system recognises, reports and tackles antisemitism and other forms of racism.

The results of the review have now been published, with a comprehensive set of recommendations to strengthen accountability, to improve reporting and investigation processes, and to embed an anti-racist culture across the health system, better to protect patients and staff from discrimination and abuse. Lord Mann:f

• sets out recommendations to tackle “routine ostracism” of Jewish people in the NHS, including stronger accountability and mandatory training;
• reemphasises the role of NHS employers as the first line of defence against racism and discrimination for patients and staff;
• recommends that NHS employers should be required to meet new staff standards and complete mandatory anti-racism training to tackle antisemitism; and
• calls upon the Government to make it clear that all racism in the NHS is abhorrent.

A specific recommendation is to prohibit staff from wearing “political symbols”.

The Government says that it is clear that all racism in the NHS is abhorrent, and NHS employers are the first line of defence and must take urgent action. With 16% of Muslim staff and 20% of Black and minority ethnic staff also reporting discrimination in the last year, and it believes that the reforms will benefit everyone who experiences hatred or abuse in the health service. Secretary of State for Health, James Murray, said:

“The NHS was built on the principle that everyone should be treated equally and with respect. Racism and discrimination betray everything the NHS stands for and its ability to provide safe, world-class care. Lord John Mann has made a series of robust and practical recommendations which we are accepting.”

A fairer end to relationships

The Government has launched a consultation on A fairer end to relationships. The consultation covers three discrete but linked areas:

• financial remedies on divorce and dissolution;
• financial provision for cohabitants on separation; and
• inheritance provision for cohabitants on death.

It invites views on:

• “a ‘codification-plus’ model of reform, which would bring settled case law principles, such as those of ‘needs’ and ‘sharing’, into statutory form”;
• further targeted reforms, including introducing qualifying nuptial agreements which would enable couples to make binding financial arrangements in advance of divorce or dissolution;
• introducing a statutory framework of rights and protections for eligible cohabitants at the point of separation; and
• proposals to modernise the law affecting cohabitants on intestacy and on access to financial provision from a deceased partner’s estate.

The accompanying press release explains that the proposals support the Government’s manifesto commitment to “strengthen the rights and protections for women in cohabiting relationships”. The consultation closes on 14 August.

A longer analysis by Professor Russell Sandberg, Why the consultation on cohabitation rights is to be welcomed, will be posted early next week.

Other Lords Spiritual??

In a rather strange written question, Lord Patten (Con) asked HMG “why leaders of faith groups such as Jewish, Muslim and Roman Catholic leaders in the House of Lords are not considered as Lords Spiritual”.

To which Baroness Anderson of Stoke-on-Trent, Parliamentary Secretary in the Cabinet Office, replied on Tuesday (carefully avoiding the obvious answer, “Because they aren’t”) as follows:

“The presence of the Lords Spiritual in the House of Lords reflects the constitutional position of the Church of England as the established Church and the Sovereign as the Supreme Governor of the Church. The Government believes the House of Lords benefits from having a membership with a wide and diverse range of backgrounds including faith and religion.”

MPs to debate e-petition after lack of progress with assisted dying bill

The Hansard Society reports that, tomorrow, MPs will debate an e-petition calling on the Government to ensure that bills supported by MPs and the public have sufficient time to complete their passage through Parliament. The petition, e-petition 752673, which was published on 4 February 2026, has attracted more than 115,000 signatures. It was prompted by concerns that the Terminally Ill Adults (End of Life) Bill – commonly known as the assisted dying bill – ran out of parliamentary time after more than 1,000 amendments were tabled in the House of Lords. The petition will be debated in Westminster Hall at 4:30 pm on Monday, 8 June.

The Society notes that whatever one’s view of assisted dying, questions remain about whether and how the Bill could be re-introduced in the new parliamentary session. Its recent briefing examines whether the Parliament Act could be used to secure its enactment. It explores the constitutional issues involved, reviews previous uses of the Act, and considers the procedural lessons they offer for the future of the Bill.

Freedom of assembly and Falun Gong

In Serbian-Chinese Friendship Society FDH v Serbia [2026] ECHR 105, the Third Section held that the Serbian Government had violated Article 11 ECHR (freedom of assembly) when it banned a demonstration to protest against the Chinese persecution of Falun Gong that had been planned to coincide with the visit of the President of China to Serbia.

It noted at [46] that the ECtHR requires that domestic law provide for “adequate and effective legal safeguards against arbitrary and discriminatory exercise of the discretion left to the executive” and that “This ‘judicial review’ must make it possible to obtain an assessment of the proportionality and necessity of the impugned restriction” in accordance with Article 11(2). In the present dispute, there was no evidence in the case file that the relevant Serbian authorities had carried out any specific security assessments before deciding to prohibit the public gatherings planned by the applicant society [72] and:

“Even if there had been a genuine risk of violent confrontation between the protestors and counter‑protestors, this, in and of itself, should not have resulted in the decisions to prohibit the planned public gatherings, without the authorities having first complied with their positive obligation to try to ensure the peaceful conduct of the planned events and the safety of all persons concerned”… [73].

There had therefore been a violation of Article 11 and of Article 13 read in conjunction with Article 11. [With thanks to Religion Clause.]

The rule of law and why it matters: Key Stage 1

The Council of Europe has published an explainer on the importance of the Rule of Law. Obviously, no regular or even occasional reader of this blog needs any such explanation; unfortunately, however, many others clearly do.

News from the auction houses

As a segue to Shirani Herbert’s guest post, Sale of church treasures: Re St Peter, Little Budworth, we were informed by David Turner KC that the painting in question, “The Good Shepherd” by William Dyce (1806–1864), was sold at Bonhams on 25 March 2026 for £267,100 inc. premium.

This week, there have been stories on the movement of artwork in the opposite direction; the BBC reported that a hatchment stolen from St Leonard’s Church, Flamstead, Hertfordshire, had been identified  and will be unveiled on 4 June as part of the Flamstead Arts Festival. There are similarities with the hatchment from St Margaret’s Church on the Felbrigg estate in Norfolk, stolen in 1993 but eventually returned by the Essex Police Rural Engagement Team.

Quick links

• Jasjit Singh, The Conversation: Who can carry a kirpan in the UK? Religion, law and the question of risk.

The Report makes recommendations to the UK Government and the Welsh Government on a future-proof framework to enable the regulation of new funerary methods. The Commission has not recommended the introduction of any specific new funerary method; that will be a matter for the respective Governments.

Key recommendations include:

• A power for the Secretary of State (in relation to England) and the Welsh Ministers (in relation to Wales) to make regulations approving the use of individual new funerary methods and setting out how they should be carried out.
• A power to make regulations enabling trials of new funerary methods to be authorised.
• A requirement for the regulation-maker to have regard to the importance of following principles:
  • Treating humans with dignity
  • Protecting the environment
  • Protecting public health and public safety.
• A new criminal offence of carrying out a new funerary method that has not been regulated under the power, other than in accordance with authorisation given for a trial, which will clarify the law in this area.
• A power to create new offences in secondary legislation of carrying out regulated new funerary methods in contravention of legislation.
• A requirement to include in regulations:
  • a requirement for the use of a new funerary method on the body of a deceased person to be registered; and
  • details of how and by whom this registration must be carried out
• A requirement to include in regulations provision about the inspection of facilities.
• Amendments to primary legislation governing death registration so that the requirements are broadly the same for a regulated new funerary method, and for new funerary methods carried out in an authorised trial, as for burial and cremation.

This Report has been laid in the Westminster Parliament and the Senedd. It includes two draft Bills, one for England and one for Wales.

The petition concerns a memorial which was unlawfully introduced into the churchyard of All Saints, Broughton on a date unknown in December 2025 [1]. It was brought in the name of Mrs Janet Watson, widow of Mr Ian Watson over whose grave the memorial was erected, although the de facto petitioner was Ms Susan Smith trading as Brook Smiths Funeral Directors in Skipton [2].

Ms Smith filed a petition and made written representations to the Court in the form of an email dated 29 January 2026. In her email she “admits that the headstone should not have been fixed without [the incumbent, the Rev Findlow’s] permission” [4]. Hill Ch. noted that several issues needed to be addressed regarding the grant of a confirmatory faculty in these circumstances, including:

• the reason why works were undertaken without prior permission and therefore unlawfully;
• the likelihood of a repetition of the unlawful works in the future; and
• whether permission would have been forthcoming had permission been sought prospectively[5].

The Chancellor was unconvinced that Ms Smith was unaware of the illegality of her actions, and her justification — wanting the bereaved widow to see the memorial before Christmas — was rejected as unreasonable; her conduct was described as ill-thought and somewhat reckless, causing avoidable distress. He could find no objective and reasonable justification for Ms Smith causing or permitting the headstone to be introduced without authority[9].

The Chancellor was concerned about a risk of repetition due to the funeral director’s poor understanding of the faculty jurisdiction. Since Ms Smith elected not to adduce evidence in reply to the statement of the incumbent, he accepted as unchallenged Rev Findlow’s evidence that the headstone did not comply with the Churchyards Regulations, particularly regarding height and potential safety concerns, with similar issues noted in two other installations handled by the same funeral director.

Whilst the height issue might be satisfied after settlement of the grave had taken place, the extension of the court’s consideration to the other installations raised further concerns. These two other headstones had been introduced into the churchyard by Ms Smith in the recent past (Cameron and Hale) and photographic evidence indicated that the latter was already leaning forward. Consequently, the Court could not be satisfied that the Watson, Cameron and Hale headstones had been safely erected, a concern is heightened by Ms Smith’s choice not to challenge or respond to Mr Findlow’s evidence on this[14].

The Chancellor concluded that convening a hearing or at least a site visit so the abiding concerns could be fully investigated, or directing the Archdeacon to investigate these matters fully, would be unduly costly and disproportionate[15]. However, he did consider that an independent memorial mason should inspect all three headstones (at the expense of Ms Smith) and certify whether they were safe and whether their installation was in accordance with industry standards as recommended by NAMM and BRAMM, including but not limited to BS 8415. In the event that any issues are raised, the matter should be referred to him for further directions[16].

He therefore directed:

• That a confirmatory faculty may issue in respect of the headstone unlawfully erected by Ms Smith over the grave of Mr Ian Watson.
• Such faculty would not issue until:
  (a) an independent memorial mason had certified the safe and competent erection of headstones over the Watson, Cameron and Hale graves. He directed that the Archdeacon to oversee the certification process, the costs of which are to be borne by Ms Smith; and
  (b) the costs of and occasioned by these proceedings are paid in full by Ms Smith.
• In the event that items (a) and (b) are not completed within 28 days, the Watson headstone is to be removed.

The Chancellor declined to ban the funeral director from future work in the diocese, believing she had learned a salutary lesson from these events. However, he reserved the right to revisit his conclusion should the certification process reveal matters of concern [18].

A similar situation existed in Victoria, Australia until the new legislation was passed in November last year. Extracts from the government Press Release announcing the change are reproduced below.

Pet burials in human cemeteries

12 November 2025

Victoria now allows pets to be buried at cemeteries alongside their owners, becoming just the second jurisdiction in Australia to do so. 

It is important to note that the new law is permissive rather than mandatory, and changes provisions relating to public cemeteries rather than what is permissible on private property. Consequently, it does not compromise existing religious and other provisions. Furthermore, the wording “in places of interment” has the potential for a wide interpretation of “alongside their owners”.

As in the UK, there are requirements on the ownership of the land used and the protection of watercourses for all pet burials. Victoria has no state-wide prohibition on home burial of domestic animals, provided environmental and public‑health requirements are met. Under the new provisions, families must complete a funeral permit application including detailed interment details to cemetery managers. In terms of the Cemetery Trust, these include accurate record keeping of position on plot, burial depth, and individual identity of all remains, allowing for respectful and legal management of graves. Any additional cemetery-specific or religious site regulations must be followed, some private cemeteries will have additional restrictions. Documentation and recording are critical to address the previous problem of improper or unrecorded pet interments that threaten disruption.

Summaries to the both consistory court judgments reviewed during May are here.

This review also includes: CDM Decisions and Safeguarding; CFCE Determinations; and Links to other posts relating to ecclesiastical law. An index to these and earlier judgments in here.

Churchyards and burials

Churchyard Regulations

Re St. Edward Kempley [2025] ECC Glo 1 The Chancellor of the Diocese of Gloucester considered a petition for a memorial at St. Edward’s Church, Kempley, featuring a carved “green man”, to reflect the association with Morris dancing of the person to be commemorated by the proposed memorial[1,2]. Initial advice from church authorities opposed the design, viewing the green man as a non-Christian or potentially pagan symbol[3].

The Chancellor undertook further research, including expert academic input based upon a short paper that the Reverend Dr Helen Hall had co-authored with Professor Javier Garcia Oliva at Manchester University, entitled: ‘The Green Man/Foliate Head as a Symbol in the Context of Christian Memorialisation.’ This showed that the green man appears in medieval church architecture and can carry Christian meanings linked to themes of death, resurrection, and redemption [8].  Scholarly opinion now suggests that earlier claims of pagan origins, such as the work of Lady Raglan (1939) are largely discredited[9].

The court also applied principles from prior cases, that memorials should not introduce symbols likely to cause offence or controversy among churchyard visitors: Re All Saints Stretton-on-Dunsmore [2023] ECC Cov 2 (three lions); Re St. Oswald Dean [2016] ECC Car 5 and Re St. Mary Canwell [2020] ECC Lic 2 (masonic symbols). However, given evolving understanding and contemporary acceptance (including its appearance on the 2023 Coronation invitation), the Chancellor found the symbol unlikely to offend a significant body of people. Concluding that the green man can reasonably be interpreted as a Christian symbol, he granted the faculty, permitting the memorial as proposed. [Re St. Edward Kempley [2025] ECC Glo 1] [Post] [Top of section] [Top of post].

Re St. Thomas Stanningley [2026] ECC Lee 2 The petition sought a faculty authorizing the removal of unauthorised items which had been placed on or near tablets over plots where cremated remains have been interred. These ornaments are not permitted under the Churchyard Regulations for the Diocese of Leeds, nor are they sanctioned under bespoke regulations [1]. Hill Ch. stated that the objections, taken thematically,  could be fairly summarized as follows[3]:

• that when family members made arrangements for the ashes to be interred in a plot in the Garden of Remembrance, they were not informed of the existence, content or enforceability of the Regulations and, accordingly, they should not be bound by their contents;
• that had they been alerted to the restrictions in the Regulations in advance, they would have made alternative provision for the interment of the cremated remains in a burial ground with less restrictive provisions;
• that the plots (together with the ornaments) are carefully and lovingly maintained and are considered to be a beautiful tribute to much loved family members.
• that the younger generation of the bereaved derive considerable comfort from the various ornaments and decorations, a particular example being given of a four-year old girl laying flowers for a fondly remembered grandmother.
• that a colourful graveyard is more welcoming and easier to visit.

Fully understanding how they may well derive comfort from the items, objects and ornaments loving left on or near individual tablets, he noted that Churchyard Regulations existed to ensure consistent practice in the churchyard [4]. The main issue was whether the families concerned had notice in advance of the existence of the Regulations. They say they did not. The petitioners suggest otherwise. It was impossible to resolve this matter definitively without oral testimony and cross-examination, but the Chancellor regarded the convening of a hearing to be pastorally challenging and disproportionate to the resolving of the dispute[5].

Looking at all the surrounding circumstances, it appeared uncontroversial that the Regulations were on the parish website from at least 2018. Their content was routinely brought to the attention to those seeking to inter the cremated remains of family members within the garden of remembrance, although it is possible that during the inter-regnum a couple of years ago when there was no incumbent in place, there may have been some neglect in the practice [6].

He was satisfied that the Regulations were sufficiently available even though in one or more instances express notification to the families did not take place. In the circumstances it seemed to him that a faculty should properly be granted to authorise the removal of items which do not comply with the Regulations. The Chancellor proposed to authorize the issuance of such a faculty 21 days from 5 May 2-26 which would allow the families the opportunity to remove the items voluntarily [7].

He added that to the extent that any of the families concerned would not have interred the cremated remains of a family member had the Regulations been expressly brought to their attention in advance, this may well be a basis upon which the remains might be exhumed and reburied in another Christian burial ground, as an exception to the presumption of permanence enunciated in Re Blagdon Cemetery [2002] Fam 299. A faculty would be required but he was content to indicate (i) that the Court was likely to look favourably on any petition and (ii) that the prescribed fees would be waived. [Re St. Thomas Stanningley [2026] ECC Lee 2] [Top of section] [Top of post].

CDM Decisions and Safeguarding

Penalties by consent

Name: The Revd ROBERT PAUL DILLINGHAM  
Diocese: Chichester
Date imposed: 20th April 2026
Relevant CDM section: 16(1)
Statutory Grounds of Misconduct: 8(1)(d) conduct unbecoming or inappropriate to the office and work of a clerk in Holy Orders
Penalty: Prohibition for life

Name: The Revd TOM BIRCH 
Diocese: Newcastle
Date imposed: 10th March 2026
Relevant CDM section: 16(1)
Statutory Grounds of Misconduct: 8(1)(aa) failing to comply with the duty under section 5 of the Safeguarding and Clergy Discipline Measure 2016; 8(1)(c) neglect or inefficiency in the performance of the duties of his office; and 8(1)(d) conduct unbecoming or inappropriate to the office and work of a clerk in Holy Orders
Penalty: Rebuke and Injunction

Name: The Revd Canon JONATHAN (Jonnie) SAMUEL PARKIN
Diocese: Bristol
Date imposed: 6th March 2026
Relevant CDM section: 16(1)
Statutory Ground of Misconduct: 8(1)(d) = Conduct unbecoming & inappropriate to the office & work of a clerk in Holy Orders
Penalty: Removal from office, injunction & limited prohibition for 3 years (with effect from 23rd May 2026).

CFCE Determinations

The dates of the Cathedrals Fabric Commission for England may be found by scrolling down to the bottom of the page Cathedrals Fabric Commission.

The programme for 2026 is here and the next meeting will be on Thursday 2  July 2026. The last set of published minutes is for the meeting on Thursday 22 October 2025.

Links to other posts

Recent summaries of specific issues that have been considered in the consistory courts include:

Church Treasure

• Sale of church treasures: Re St Peter, Little Budworth, (19 May 2026).

Churchyards

• Burial of pets in churchyards – an overview, (1 June 2026).
• The Green Man/Foliate Head as a symbol in the context of Christian memorialisation, (26 May 2026).

[Top]

Updated: 1  June 2026 at 17:07.

Notes on the conventions used for the navigation between cases reviewed in this post are summarized here.

This post reviews the current legislation on the burial or scattering of the cremated remains of humans and animals, which includes burial law, provisions on animal by-products and ecclesiastical law. However, there is no single instrument which addresses both. Burying an animal in a church or municipal cemetery, including the placement of an urn in a coffin, is illegal; nevertheless, burial in a pet cemetery on private land or scattering of the ashes is permissible in most cases. A subsequent post will review recent developments in Australia in which the burial of humans and animals may be accommodated.

Burial

An earlier post considered Groundwater pollution from cemeteries (22 March 2017) following the introduction of a new tranche of EA position statements on groundwater protection. The potential contamination of groundwater from burials is a major factor to be considered and Environment Agency Guidance (1 April 2022) indicates that different rules apply to:

• domestic pets;
• pet cemeteries; and livestock and
• wild game.

The EA guidance indicates that permission is not required to bury domestic pets on one’s own land, for which there are no minimum good practice groundwater protection requirements. However, if pets are to be buried in a churchyard or cemetery, it is necessary for it to be registered as a pet cemetery with the Animal and Plant Health Agency, (APHA). In addition, the owners/managers will need to comply with:

• minimum good practice groundwater protection requirements;
• the Animal By-products (Enforcement) (England) Regulations 2013;
• the voluntary code of practice of the Association of Private Pet Cemeteries and Crematoria.

Examples of pet cemeteries

In January 2010, the Daily Express ran the story Pet Lovers Can be Buried with their Animals which revealed that the village of Stainton by Langworth, near Lincoln, was to become the only place in England where humans could be near their dogs, cats and even hamsters forever.

It stated: “West Lindsey District Council gave permission for the scheme because the local churchyard of St John the Baptist is, like many others in Britain, fast running out of space”. [Clearly, the lack of space aspect of the comment is unrelated to the provision for pet burials in the newly authorized cemetery.] Importantly, however, the Orchard Burial Ground is privately owned, and as such the owner has the option to inter pets, provided other legislative requirements are satisfied. The web site for the cemetery indicated that there are areas where “people, pets or even people with their pets, can be buried”; i.e. separate areas where people can be buried; ashes can be scattered; people and their pets can be buried alongside each other; and for pet burials.

The Association of Private Pet Cemeteries and Crematoria notes:

“Pet crematoria are controlled under the Animal By-Product Regulations and, in some areas, Waste Management Licensing…Licensing for Pet Crematoria and Cemeteries is only concerned with the operation as a disposal site. There are no regulations controlling how the cremations should be carried out to ensure the correct ashes are collected, for the dignified handling of the animals or to distinguish between ashes going to a normal disposal site or to a specific memorial area. The standards set by the Association are the only ones that provide this distinction”.

Individual cremation

The Federation of Burial and Cremation Authorities (FBCA) Code of Cremation Practice states:

“6. Separately Cremated: Each deceased person given to the care of the Cremation Authority shall be cremated separately. Exceptions may be made for instance in the case of mother and baby or twin children providing that the next of kin has made a specific request in this regard”.

This is not the case for the burial of animals, for which both individual cremation, or a communal options may be available.

Scattering of ashes

In view of their essentially inert nature, the scattering of cremation ashes presents few environmental issues, and is permissible providing it is undertaken with the permission of the landowner. However, consistory courts are unwilling to grant a faculty other than placing ashes contained in a buried urn in the grave space or for “strewing” the ashes, i.e. pouring of the ashes directly into the grave or directly onto the ground in the grave before immediately covering them over with earth, rather than “scattering” them broadcast. [See Re Holy Trinity Trowbridge St. Thomas [2025] ECC Sal 1 [Revised], which is further discussed here. Courts are also unwilling to permit the “mingling” or mixing of ashes from more than one source [See Re Hereford Cemetery [2023] ECC Her 1].

Comment

Unlike in most other European jurisdictions, the bereaved family has, by law, a potentially significant role in determining the subsequent treatment of the ashes. Under Regulation 30 Cremation (England and Wales) Regulations 2008, the cremation authority:

“(1)(a) must dispose of the ashes in accordance with the applicant’s instructions for ashes; or (b) in any case where the applicant does not give instructions for ashes […] where “instructions for ashes” means the instructions given on the application form completed by the applicant, or any subsequent written instructions given by the applicant to the cremation authority”. 

Furthermore, The Cremation (England and Wales) Regulations 2008: guidance for funeral directors, (9 September 2024), stresses “Funeral directors must not complete and/or sign the application form on behalf of the applicant. The application form must be completed and signed by the applicant, supported by the funeral director.” [Footnote 3: clarifies: “The applicant for cremation should usually be a near relative or an executor”].

Footnote

At L&RUK we do not give legal advice, or purport to do so. This post summarizes the issues relating to the burial of pets. For specific queries on the application of the legislation, professional legal advice and the opinion of the competent authorities should be sought.

Projects already underway: The Historic Religious Buildings Alliance has drawn attention to the fact that in Year 1 of the recently-launched Places of Worship Renewal Fund (PWRF), a limited amount of funding will be available for “projects that have lost anticipated match funding”. Historic England’s website says this:

“Will the fund support projects already underway?”

In Year 1 only, a limited amount of funding will be available to projects that have lost anticipated match funding. This will be provided under stream 1 (grants from £10,000 to £50,000) for projects that began on or after 1 October 2025 and are due to complete by 30 September 2026, provided that they:

• • Meet all other PWRF eligibility criteria
  • Have not previously received funding through the Listed Places of Worship Grant Scheme.

To apply for funding in year 1 for works already in progress or completed, please email PWRF@HistoricEngland.org.uk and you will be sent a separate application form to complete and return.”

All other PWRF eligibility criteria must be met, and the HRBA is encouraging a careful reading of the website before pursuing this possibility.

Expressions of Interest: The deadline for submitting Expressions of Interest for grants from the first round of the Fund has been extended to Sunday 14 June 2026. A second round will follow soon after in September 2026. The latest date by which applicants will receive a response to their Expression of Interest is now 3 July.

Full applications: The deadline for making a full application has been extended from 16 July to 5 pm on Sunday 26 July. [With thanks to the Historic Religious Buildings Alliance.]

Data (Use and Access) Act 2025: implementation

New regulations under the Data (Use and Access) Act 2025, which come into operation on 19 June 2026, require all organisations to handle data protection complaints expeditiously and to have a data protection policy in place. Under the regulations, they must:

• designate a data protection lead;
• give people a way of making data protection complaints to the organisation;
• acknowledge receipt of complaints within 30 calendar days of receiving them;
• without undue delay, take appropriate steps to respond to complaints, including making appropriate enquiries, and keep people informed; and
• without undue delay, tell people the outcome of their complaints.

The Information Commissioner’s Office has published guidance on the new requirements, here. Presumably, larger religious organisations will already have appropriate procedures in place; smaller ones, however, might not.

Upcoming consultation on weddings law

In reply to a question from Ben Lake (Ceredigion Preseli, Plaid), Catherine Atkinson, Parliamentary Under-Secretary at the MoJ said this:

“The Government has announced its intention to reform weddings law when parliamentary time allows. The reforms reflect a commitment to making marriage law fairer, simpler, and more modern, whilst also protecting the solemnity and dignity of marriage. The current aim is that the consultation on the reform of weddings law in England and Wales will be launched before the summer recess, which commences on 16 July 2026.”

Update regarding the appointment of the next Bishop of Bristol

On 27 May, the Church of England announced that “The Crown Nominations Commission (CNC) for Bristol met in April and nominated a candidate for the See of Bristol. The individual has since decided, with regret, to withdraw from the nomination for family reasons”. A separate announcement was made by the Diocese.

Inevitably, social media was quick to question why two names had not been supplied to the CNC, to which Madeleine Davies of the Church Times quickly responded: “…In 2019, standing orders were changed to relieve CNCs of the requirement to provide a second name ‘in the light of the fact that the second name is very rarely needed‘”, GS 2144. Readers will recall that on 17 February 2025, it was reported that the individual nominated to be the next Bishop of Durham had withdrawn from the process, for which the reasons were unstated. Further, the initial considerations of the CNC for the Sees of Carlisle and Ely failed to nominate a candidate.

In a recent post on 14 April, Stephen Parsons noted that there were:

“nine diocesan episcopal posts that are vacant or to become vacant by the summer.  Two further diocesan posts are in temporary abeyance (Lincoln and Salisbury) while the current incumbents await the result of disciplinary enquiries that are being undertaken. That would possibly bring the total number of diocesan vacancies to 11. This total means that around 25% of the senior episcopal posts in England are currently in or about to enter a temporary vacancy”.

Quick links:

• Hilary Aldred and Virginia Henley, Lexology: What should charities be doing now given the forthcoming changes to employment law?
• Shaun de Freitas, Australian Journal of Law & Religion: Freedom of Religion in Communities of Legal Scholarship: A Christian Perspective.

And finally…

An English-language Bangladeshi newspaper reports that the life of a buffalo that allegedly bears a more-than-passing resemblance to the current President of the US, and which had been sold by the breeder to a customer for sacrifice during the feast of Eid-ul-Adha, will be spared after a special intervention by the Ministry of Home Affairs. This time, you really couldn’t make it up…

**********

Introduction

This short paper seeks to examine:

• What has contemporary academic scholarship established about the origins, symbolism and interpretation of the Green Man image in English architecture, particularly in ecclesiastical settings.
• Why there are associations with the image and paganism in some parts of contemporary culture.
• Whether a Green Man image is permissible on a memorial headstone, in light of the applicable law and regulations.

 Origins, symbolism and interpretation of the Green Man image

The Green Man symbol, in the sense of the “foliate head”, begins to appear in England in the early 12^th century. The historian Ronald Hutton summarises its origins as follows:

“They were revealed to have been a motif originally developed in India, which travelled through the medieval Arab empire to Christian Europe. There it became a decoration for monks’ manuscripts, from which it spread to churches.”[1]

There are some earlier instances of humans or animals appearing with vegetation, but this is hardly surprising, given the inspiration of the natural world. It is also possible that some aspects of the artistic style of the foliate head designs were influenced by other societies, including pagan ones.[2] This is to be expected, given that neither decorative images nor cultural symbols ever arise in a cultural vacuum, and Christian spiritual buildings and objects frequently reflect this, e.g. consider the Pictish illustrations and illuminations in the Book of Kells.[3]

Nevertheless, it has now been convincingly established that the Green Men images as they appear in churches were understood by both their creators and observers as fitting within a Christian worldview.[4] Furthermore, it is reasonable to observe that Christian sacred art frequently depicts images intended to be perceived negatively e.g. Medieval depictions of Hell, or figures of demons tempting souls.[5]  The fact than an image or symbol might be appropriately displayed in a place of worship does not necessarily signify that it would be appropriate for inclusion in a memorial. It is therefore a material consideration that the Green Man was generally construed in a positive light.[6]

In a recent and highly detailed work, Miller demonstrates that the Green Man was it appears in church carvings is a distinctly Christian image, whatever antecedent influences it may have had.[7] He correctly observes that the Medieval worshipping community who produced the Green Man was well versed in both Biblical narratives and Christian lore, and would undoubtedly have made ready and sophisticated connections. He links the image with  stories about Adam, and the Garden of Eden, the Quest of Seth,[8] as well as meditations on the cross and crucifixion, for example, Jacobus Voragine’s The Golden Legend [9] and Honorius of Autun’s Imago mundi (an encyclopaedia and Christian world history).[10]

One narrative of particular relevance was the “Legend of the Rood”, an interconnected collection of stories derived from the overarching narrative of the Bible, demonstrating that even the Fall and expulsion from the Garden of Eden were part of God’s Divine plan, and that the wider picture of Christ’s death and resurrection.[11] As Adam lies dying, he sends his son Seth back to the Garden of Eden to beg a potion that will render him immortal. Unsurprisingly, he is refused entry by the angelic guard, and no elixir is forthcoming.  Nevertheless, mercy is shown, and he is given a seed from the tree bearing the fruit picked and eaten by the first humans. By the time that Seth returns, Adam has already died, so the grieving son places the seed under his father’s tongue and buries him in a place that will one day become Golgotha. A tree grows, which is eventually cut down. Over centuries, the wood is put to many uses, but it eventually becomes the cross of Christ. Thus, the eternal life lost by humanity through rejection of God is regained not through a magical elixir, but the painful sacrifice and glorious resurrection of Christ.

The Green Man would have connected more than one story and trope within the Christian cosmos, but above all else, was linked to the promise of rebirth. Trees had long been associated with the crucifixion in northern European Christian culture, and the symmetry of a tree as the vehicle for both the fall and redemption of humankind was stressed.[12]

Alongside the Scriptural narrative, there is there is the reality that deciduous trees are natural, organic symbols of rebirth. This also would not have been lost on the people making and viewing the Green Man images. Yet it is important to stress that they would have done so through the specifically Christian cultural paradigm in which they moved.   The people who gazed at Green Men in churches would not only have thought of winter and spring, but also made the connection between this seasonal death and rebirth, and the cosmic journey from death brought by the Fall to the life flowing from the crucifixion and resurrection. This raises the legitimate question, however: if the Green Man was clearly and profoundly a Christian symbol, why has it come to have pagan associations?

Associations with the image and paganism in some parts of contemporary culture

The answer to this question lies the wider quest of some folklorists in the early twentieth century to find evidence of an unbroken tradition of ancient pagan religion, that has survived the Christianisation of the British Isles. The work of Margaret Murray in respect of witchcraft was a notable example of this. Murray argued that the witches persecuted in Europe during the Early Modern era were in fact secret practitioners of a surviving pagan religion. For a while, mainstream scholarship embraced this idea, although it has now been conclusively disproven.[13] Nevertheless, it has retained a hold in popular culture and imagination.

The treatment of the Green Man by the folklorist Lady Raglan in 1939 is part of this broad trend within the discipline. She made connections between the Green Man figures in churches, and the unrelated phenomena of May Day processions and Jack-in-the-Green, as well as the popular “Green Man” pub sign. Research in the later twentieth century again unequivocally discredited this, illustrating the true origin of the foliate heads set out above, as well as the genesis of the other traditions mentioned (neither of which is of any great antiquity).[14]

However, the idea had attracted attention and gained a lot of support, including from many within the neo-pagan community. The Green Man came to be embraced by various neo-pagan writers and speakers, having an obvious connection with themes of nature and the changing seasons, important aspects of the spirituality of many people within these groups, as well as an apparent connection with pre-Christian faith.

In the current era, some pagans remain unaware of that these theories have been rejected by the academic community, whilst others reject these findings. There are also some modern pagans who are aware that the carvings have no direct connection to any ancient faith, and were made and used by Christian people, but nevertheless choose to retain the image because they find it helpful. Therefore, the Green Man continues to be found within Pagan circles.

The Green Man as an image on a memorial headstone, in light of the applicable law and regulations

Taking into account all of the above, the Green Man is very different from the Masonic symbols discussed in Re St Mary Canwell [2020][15] and the leading case of Re St Oswald’s Churchyard[16] The reasoning in both cases related to the questions about the compatibility of Freemasonry and Christianity, which have been acknowledged by the formal structures of the Church of England (although the judgments were careful to stress that they were not making any determination on that issue).

The Green Man is not a symbol from a movement like Freemasonry, nor can it really credibly be described as a pagan symbol which some Christians have adopted. It is a Christian symbol, carved in the stone of Church buildings because it would cause those who saw it to reflect on some of the core themes and stories of the faith. In light of this, it is difficult to see how it could be construed as being an inappropriate image for a Christian burial place.

It must be acknowledged that there will be some observers who may be unaware of the history of the Green Man and may misguidedly construe the symbol as pagan.    However, the weight of the scholarship is overwhelmingly that it is indeed Christian in nature.

Helen Hall and Javier Garcia Oliva, 16 January 2024

Bibliography

Boenig, Robert, Anglo-Saxon Spirituality: Selected Writings, Paulist Press (2000)

Caciola, Nancy Discerning Spirits: Divine and Demonic Possession in the Middle Ages, Cornell University Press, 2006)

Corrigan, “The Function and Development of The Foliate Head in English Medieval Churches” University of Birmingham (2020)

Cate Gunn, ‎ Liz Herbert McAvoy, ‎ Naoë Kukita Yoshikawa, Women and Devotional Literature in the Middle Ages Boydell and Brewer, (2023)

Hutton, Ronald, “How Pagan Were Medieval English Peasants?” Folklore No. 122(3) (2011), 253

Le Goff, Jacques, “In Search of Sacred Time: Jacobus de Voragine and The Golden Legend ”Princeton University Press (2014)

MacDermott, Mercia, Explore Green Men, Explore Books (2006)

Muir, Lynette, The Biblical Drama of Medieval Europe, CUP (2003),

Netton, Ian Islam, Christianity and the Mystic Journey: A Comparative Exploration, Edinburgh University Press (2011)

Purkiss, Diane, The Witch in History: Early Modern and Twentieth Century Representations, Routledge (1996)

Skipworth, Hannah, “Signs of Life: Images of the living world in Honorius Augustodunensis and Hildegard of Bingen” Monash University (2021)

Smither, Edward, Missionary Monks: An Introduction to the History and Theology of Missionary Monasticism Cascade Books, (2016).

Notes

[1] R Hutton, “How Pagan was Medieval Britain?” Gresham College 7 June 2023

[2] I Corrigan, “The Function and Development of The Foliate Head in English Medieval Churches” University of Birmingham (2020)

[3] E Smither, Missionary Monks: An Introduction to the History and Theology of Missionary Monasticism Cascade Books, 2016 72

[4] M MacDermott, Explore Green Men, Explore Books (2006)

[5] N Caciola, Discerning Spirits: Divine and Demonic Possession in the Middle Ages, Cornell University Press, (2006) 165

[6] I Netton, Islam, Christianity and the Mystic Journey: A Comparative Exploration, Edinburgh University Press (2011), 25

[7] S Miller, The Green Man in Medieval England; Christian Shoots from Pagan Roots, Cambridge Scholars Publishing (2022)

[8] Gunn, G, ‎Herbert McAvoy,L, and ‎Kukita Yoshikawa, N, Women and Devotional Literature in the Middle Ages Boydell and Brewer, (2023)154

[9] Le Goff, J, “In Search of Sacred Time: Jacobus de Voragine and The Golden Legend ”Princeton University Press (2014)

[10] Skipworth, H, “Signs of Life: Images of the living world in Honorius Augustodunensis and Hildegard of Bingen” Monash University (2021)

[11] Muir, L, The Biblical Drama of Medieval Europe, CUP (2003), 134

[12] Boenig, R, Anglo-Saxon Spirituality: Selected Writings, Paulist Press (2000) 272

[13] Purkiss, D. The Witch in History: Early Modern and Twentieth Century Representations, Routledge (1996)

[14] R Hutton, “How Pagan was Medieval Britain?” Gresham College 7 June 2023

[15] Re St Mary Canwell [2020] ECC Lic 2

[16] Re St Oswald’s Churchyard [2016] ECC Car 5

“Pope Leo XIV has taken up the legacy of his predecessor, writing a social encyclical which addresses one of the principal challenges of the contemporary age: artificial intelligence. Divided into five chapters, Magnifica humanitas has an underlying premise: technology is not ‘a force antagonistic to humanity’, nor is it ‘inherently evil’. However, ‘technology is never neutral, because it takes on the characteristics of those who devise, finance, regulate, and use it’. He appeals for the safeguarding of humanity, promotion of truth, dignity of work, social justice, and peace”.

The five chapters are:

• “A Dynamic Approach Faithful to the Gospel”—traces the Social Doctrine of the Church in recent magisterium and the Second Vatican Council, highlighting “its dynamic character”.
• “Foundations and Principles of the Social Doctrine of the Church”. These foundations, he says, include the dignity of the person, created in the image and likeness of God. It is important to recall this since “the pressure of new ideologies or certain highly powerful interests” can reduce the human person to “a resource to be used and exploited” or “on what they achieve or produce”.
• Technology and Dominance. The Grandeur of Humanity in Light of the Promises of AI stresses the need to approach artificial intelligence with vigilance. Pope Leo warns about the “technocratic paradigm” already denounced by Pope Francis and how it can require that every choice be dictated exclusively by measuring efficiency and profits.
• Safeguarding Humanity at a Time of Transformation. Truth, Work, Freedom—the Pope calls for an “ecology of communication” based on truth. He urges transparency in how content is selected, protection of personal data, serious journalism founded on argumentation and verification, a new awareness in the “proper and critical” use of digital tools, and the integration of different forms of knowledge.
• The Culture of Power and the Civilization of Love—Pope Leo XIV turns to war, saying “the digital revolution is changing the nature of conflict.” The Pope calls for an ethical approach, without which decisions about the life and death of persons will become increasingly impersonal due to a use of force regarded as an “immediate and viable option”.

Artificial Intelligence 

Pope Leo XIV indicates that it is not his intention to offer a comprehensive treatment of artificial intelligence, nor to give an overview of the extensive relevant literature, since authoritative contributions already exist, including within the ecclesial context (reference [123]). He limits himself to recalling a few essential elements for a moral and social discernment that safeguards the primacy of the human person, in order to ensure that it will always be human intelligence, with its conscience and freedom, that guides technical innovations and responsibly determines their use and limits. He comments [emphasis added]:

• It is appropriate to preface this discussion with two considerations. First, any statement regarding AI risks becoming quickly outdated, given the remarkable pace at which these systems are developing. Second, all of us, including those who design them, possess only a limited understanding of their actual functioning. Indeed, current AI systems are more “cultivated” than “built,” for developers do not directly design every detail, but instead create a framework within which the intelligence “grows.” As a result, fundamental scientific aspects — such as the internal representations and computational processes of these systems — remain, at present, unknown. There thus emerges an urgent need for a twofold commitment: on the one hand, a deepening of scientific research; on the other, the exercise of moral and spiritual discernment.
• It is not possible to provide a single, comprehensive definition of AI. What can be stated, however, is that we must avoid the misconception of equating this type of “intelligence” with that of human beings. These systems merely imitate certain functions of human intelligence. In doing so, they often surpass human intelligence in speed and computational capacity, offering tangible benefits across many fields. Yet this power remains entirely tied to data processing. So-called artificial intelligences do not undergo experiences, do not possess a body, do not feel joy or pain, do not mature through relationships and do not know from within what love, work, friendship or responsibility mean.
• Nor do they have a moral conscience, since they do not judge good and evil, grasp the ultimate meaning of situations, or bear responsibility for consequences. They may imitate language, behaviour and analytical skills, or even simulate empathy and understanding, but they do not understand what they produce, for they lack the affective, relational and spiritual perspective through which human beings grow in wisdom. Even when these tools are described as capable of “learning,” their way of doing so is different from that of a human person. It is not the experience of those who allow themselves to be shaped by life and grow over time through choices, mistakes, forgiveness and fidelity. Rather, it is a form of statistical adaptation based on data and feedback, which can be very effective, but does not imply inner growth.

References

[123] Cf. Dicastery for the Doctrine of the Faith – Dicastery for Culture and Education, Note Antiqua et Nova (14 January 2025): AAS 117 (2025), 159-210; Francis, Message for the 57^th World Day of Peace (8 December 2023): AAS 116 (2024), 54-64; Francis, Message for the 58^th World Day of Social Communications (24 January 2024): AAS 116 (2024), 261-266; Francis, Address to the G7 Session on Artificial Intelligence: “An exciting and fearsome tool” (14 June 2024): AAS 116 (2024), 866-875; International Theological Commission, Quo vadis, humanitas? Thinking about Christian anthropology in the face of some scenarios on the future of humanity (9 February 2026); Message for the 60^th World Day of Social Communications (24 January 2026): L’Osservatore Romano, 24 January 2026, 2-3.

Pope Leo XIV’s address in English at the publication of his Encyclical Letter Magnifica humanitas, on safeguarding the human person in the age of Artificial Intelligence.

Here are some important law-and-religion news stories from around the web:

• The U.S. Department of Health and Human Services announced a restructuring of its Office for Civil Rights that will create separate divisions focused on religious liberty and conscience protections, civil rights enforcement, and health privacy and cybersecurity. HHS said the changes are intended to combat anti-Christian bias and race-based discrimination while strengthening enforcement efficiency.
• A Virginia appeals court revived a lawsuit against McLean Bible Church over claims that church leaders improperly handled a 2021 elder election and disenfranchised members. The court ruled that limited judicial review of the dispute is not automatically barred by the First Amendment.
• A new lawsuit in Utah, backed by pro-life advocates with religious and fetal personhood arguments, claims that disposing of unused IVF embryos violates wrongful death laws. The case has raised concerns that similar religion-influenced legal challenges to IVF practices could spread to other states.
• A Texas jury ordered an insurer to pay more than $7 million to Southwestern Baptist Theological Seminary after the insurer denied coverage for legal costs related to lawsuits involving former seminary president Paige Patterson and the school’s handling of sexual assault allegations. The case arose from broader controversy within the Southern Baptist Convention over abuse and institutional accountability.
• Two senators introduced a bipartisan bill aimed at combating antisemitism and increasing security protections for Jewish institutions, including a proposal to expand federal nonprofit security grants to $1 billion annually. The legislation would also address antisemitism on college campuses and require greater transparency from social media companies on moderating antisemitic content.
• The Vatican’s Synod office released a new document outlining the path toward a global ecclesial assembly in 2028, continuing the Catholic Church’s “Synod on Synodality” process launched under Pope Francis. The plan establishes stages for dioceses, bishops’ conferences, and continental church bodies to evaluate how “synodality” is being implemented in local churches over the next several years.
• A Catholic nun in Los Angeles runs Francisco Homes, a housing program for formerly incarcerated men, including immigrants facing deportation. Her ministry sits in the context of ongoing debates over immigration enforcement and deportation policy.
• Archbishop John Ricard, the former archbishop of Baltimore and first leader of the National Black Catholic Congress, has died at age 86. Ricard was a prominent Black Catholic leader known for advancing Black Catholic ministry and advocacy within the Church for decades.

The post Around the Web appeared first on LAW AND RELIGION FORUM.

L&RUK has reported on developments in the Listed Places of Worship Fund (“the Fund”) since 2017 when it was announced that it would continue at its current levels until March 2020, with no changes planned to the eligibility criteria or application process. In March 2025, Harlow Consulting issued a questionnaire aimed at those responsible for looking after listed places of worship. The user survey was conducted on behalf of the Department for Culture, Media and Sport as part of an evaluation of the Listed Places of Worship Grant Scheme.

On 22 January 2026, the Government announced a £1.5 billion package of support for “cultural organisations” over the coming five years, with “£230 million for heritage, protecting and preserving heritage buildings, including listed places of worship, across the country”. Specifically in relation to places of worship:

“In recognition of the important role religious heritage buildings play in the UK’s national story, a new £92 million fund called the Places of Worship Renewal Fund will replace the £23 million Listed Places of Worship Grant Scheme and bring these important buildings into line with other heritage assets. It will give them access to the same level of financial support from the Government as historic houses, monuments and other heritage sites.”

At the same time, DCMS published Evaluation of the Listed Places of Worship Scheme – Final Report. This concluded that “in most cases the grant is contributing directly to securing more repair and maintenance to listed places of worship”.

Recent Developments

On 19 May 2026, the Department for Culture, Media and Sport (DCMS) issued the Press Release Leaking church roofs to be fixed and heritage buildings revitalised as applications open for £48 million of heritage funding. This explained: “[p]art of the wider £1.5 billion Arts Everywhere Fund, these investments will be targeted at areas of high deprivation, which face the greatest fundraising challenges”.

More informative was the subtitle “Three heritage funds have opened for Expressions of Interest, including the new £92 million Places of Worship Renewal Fund, as well as the second rounds of the Heritage at Risk Capital Fund and Heritage Revival Fund“. These are summarized below.

Places of Worship Renewal Fund

Offering up to £23 million this year, the new Places of Worship Renewal Fund will support a range of small to large projects, from urgent structural repairs to physical access improvements and the installation of new facilities to expand community use. A further £69 million will be made available across the course of this parliament.

Listed places of worship across the country have reported falling behind on structural repairs and maintenance, with those in areas of high deprivation facing overwhelming challenges to fundraising for the capital costs of building works. The Places of Worship Renewal Fund targets those areas of the greatest need, helping remove previously insurmountable financial barriers to crucial repairs with upfront capital grants. It is open to listed places of worship serving all faiths.

The new funding scheme brings listed places of worship in line with the funding opportunities that other heritage buildings enjoy, with confirmation of the scheme for the next four years providing much-needed certainty to the church sector. The scheme will be delivered by Historic England, who have well developed relationships across the sector and can draw on their depth of experience to support communities and volunteers with projects of all sizes.

Heritage at Risk Capital Fund

A second round of the Heritage at Risk Capital Fund has opened for Expressions of Interest, backing projects that ensure heritage buildings are fit for the future and continue to tell our national story in communities across the country. The fund prioritises projects that restore heritage sites serving disadvantaged communities and which demonstrate strong local benefits, from job creation to cultural events.

Up to £15 million in funding is available to at-risk heritage sites this year, as part of a total £75 million Heritage at Risk Capital Fund. Note however, that  that “Private dwellings, places of worship and commercial buildings are only exceptionally considered“.

Heritage Revival Fund

The Heritage Revival Fund has also opened applications to its second round, with funding doubling to £10 million per year. The fund – worth £45 million in total – helps communities to rescue and repurpose neglected historic buildings and transform them to meet modern needs, focusing on regenerating historic buildings in town centre locations to create new arts and culture venues, workspaces, affordable housing, and more.

Comment

The Church of England has issued the Press Release New listed places of worship fund launched which notes: “[s]ome types of work attract a zero or lower rate of VAT and there is an introduction to these here: Understanding VAT Zero‑Rating for Church Works | The Church of England.

Further information has also been published by Historic England .

This month, I have had the pleasure of teaching an online seminar on the Supreme Court of the United States for students in Yerevan State University’s Master’s Program in American Studies. The seminar focuses on the Court’s power of judicial review and the limits on that power—limits imposed by the other branches of government, by the Court itself, and by the American people. We also have been discussing current proposals for Supreme Court reform. I have used the Court’s Religion Clause jurisprudence as an example of its influence in US life.

The seminar has been a lot of fun. The students have asked excellent questions about constitutional law, judicial power, and the Court’s role in American public life. I am grateful to Yerevan State University, the Master’s Program in American Studies, Alexander Markarov, and Vahagn Aglyan for the invitation and for their hospitality.

The post Movsesian Teaches Seminar at Yerevan State University appeared first on LAW AND RELIGION FORUM.

The first post on Law & Religion UK addressed the successful challenge of the National Secular Society, (NSS), and Mr Clive Bone, a former Bideford town councillor, to the inclusion of ‘Prayers’ as the first substantive item of business at full meetings of the Council, National Secular Society & Anor, R (on the application of) v Bideford Town Council [2012] EWHC 175 (Admin) (10 February 2012).

This held that that saying prayers as part of the formal agenda of a council meeting was unlawful, since S111 of the Local Government Act 1972 did not authorize it, and there was no other statutory power permitting prayers. The ruling turned purely on statutory powers; the court did not find a human‑rights breach.

Although Bideford Council was granted leave to appeal, this was overtaken by events as the Secretary of State for Communities and Local Government, Eric Pickles fast-tracked section 1 of the Localism Act 2011 to give local (and parish councils from April 2012) “power to do anything that individuals generally may do”, in an attempt to restore their ability to hold “Council Prayers” following the High Court ruling. However, this did not apply to Wales, nor to smaller parish councils or certain single‑purpose authorities.

There remained legal uncertainty about whether the general power covered prayers, and the Local Government (Religious etc. Observances) Act 2015  was introduced specifically to remove all doubt and to provide a clear statutory basis. The Act fully reversed the effect of the Bideford ruling and councils in England and Wales may: include prayers or other observances as part of the formal agenda; choose the form of observance (e.g. Christian, multi‑faith, or non‑religious reflective observance); and allow councillors to opt out without disadvantage (a practice encouraged but not mandated). The Act does not require councils to have prayers; it simply permits them.

As we observed at the time, the initial action taken by the NSS appeared to be an example of “be very careful what you wish for”, (although at the time we suggested “that in practice relatively little would change as a consequence of the new Act, but equally, future legal action along the lines of Bideford seemed unlikely).

Recent Events

The opinions of Local Authorities to “Council Prayers” have changed since events at Bideford, and last year the NSS observed that Reform councillors imposed prayers on Derbyshire County Council after the party had taken control of the Council. More recently in Kent County Council (KCC), on 12 May 2026 Local Government Lawyer reported that the County Council’s monitoring officer had warned she may have to issue a section 5 report after members voted to debate a constitutional amendment that would see the Lord’s Prayer livestreamed during full council meetings. 

A report by monitoring officer Petra Der Man had indicated that prayers could lawfully be held either off camera at the start or end of meetings, or in a separate room for those wishing to participate. However, Kent County Council, controlled by Reform UK, passed a motion to begin meetings with the Lord’s Prayer and the national anthem, both to be livestreamed. The move followed a committee decision to put the issue to all 81 councillors, and an amendment allowed the prayer to be broadcast despite earlier legal warnings.

Introduction

Church of England churches own a store of moveable assets which have come to be called “church treasures” and are highly prized. They may consist of ancient artefacts, silver, items of historic interest and works of art, and may include secular items which have been deposited in churches.

As “Treasures on Earth” – A Report by a Working Party of the Council for Places of Worship (General Synod 08132 (1973)), quoted in 2014 by the Court of Arches in Re St Lawrence Oakley with Wootton St Lawrence [2014] Court of Arches, [2015] Fam 27 [35], stated:

“One of the most excellent ambitions of Christians … has been to express their faith in the language of the arts – in architecture, sculpture, painting, mosaic, music and poetry – and thus to build houses of God which are symbols of that faith, thereafter furnishing them with objects as nearly worthy of the worship of God as human skill can make them.  The triumphant realisation of that godly ambition by men in every age from that of the early Chistian church down to the present day has been instrumental in creating the great store of treasures owned by the churches …”

It may sometimes be tempting for a church struggling with financial difficulties to sell some of its treasures in order to fund its needs – perhaps to repair its roof or to modernise its heating system.  On the other hand a church may find that one of its treasures has become more of a liability than an asset because the church cannot afford the expense necessary to retain its valuable treasure due to the costs incurred in storage, insurance and restoration.

However, church treasures may not be disposed of without the permission by way of a faculty granted by the Consistory Court. The Court of Arches had made it clear in Re St Lawrence Oakley that there was “a strong presumption against” the sale of church treasures and that a faculty should not be granted by the Consistory Court unless there were “sufficiently compelling” grounds to outweigh that strong presumption.

Re St Peter, Little Budworth

The dilemmas which parishes could face in regard to their church treasures and the issues which confront the Consistory Court when considering an application by a parish for a faculty to dispose of a church treasure were well illustrated by the Consistory Court of the Diocese of Chester in Re St Peter Little Budworth [2025] ECC Chr 1, when the churchwardens of Saint Peter’s Church, Little Budworth, a post-medieval Grade II* listed church, applied for a faculty to sell by auction one of its church treasures: a painting entitled “The Good Shepherd” by William Dyce (1806–1864), a Scottish-born painter who had been associated with the Pre-Raphaelite Brotherhood.  [1]

The painting depicts a full-length portrait of Jesus Christ with a lamb in one arm and a crook in his hand, guiding sheep through a narrow opening into an enclosed field.  It had been given to the church in 1924 by a parishioner, Brian Stock, in memory of a family member, James Henry Stock (1855–1907), who had been Member of Parliament for Liverpool Walton from 1892 to 1906.  [2], [18].

For over 50 years the original painting had not been physically displayed in the church as it had been on loan to various museums.  A reproduction had hung in the church for some time since the removal of the original. By 1977, the painting had been visibly deteriorating.  It was believed that that was due largely to atmospheric conditions in the church.  In 1978, the painting was sent to the Walker Art Gallery in Liverpool, where “minimal restoration” was carried out.  The painting remained on loan in Liverpool until it was transferred to the Manchester City Art Gallery in 1987.  It remained on loan there until 2024, when the parish was informed by the gallery that the painting was no longer wanted.  [24]

The prospect of the physical return of the painting concerned the churchwardens and the Parochial Church Council, with the result that in December 2024, arrangements were made for the painting to be collected by the auctioneers, Bonhams, where it remained pending a decision as to its future.  [24] Since then, the parish had explored alternative options for the display of the painting but had had no success.  Several other galleries, including the Walker Gallery, the Aberdeen Art Gallery and the Victoria and Albert Museum which had been contacted, were not interested mainly due to lack of funds and budgetary constraints.  [27] – [31].

In those circumstances, the Churchwardens of St Peter’s petitioned the Consistory Court for authority to sell the painting by auction at Bonhams. The petition was formally unopposed. The Church Buildings Council (“CBC”) had reservations about the sale but did not wish to become a party opponent.  [1] [4]

The CBC said that its guidance entitled “Brief Guide to Disposals and Loans” (May 2024) should be given due consideration. That guidance made it clear that sales should be “sparingly exercised” and a strong justification needed to be made in order for the Chancellor to make a decision.  The CBC did not feel a strong case had been made in the present petition.  [5]

The Chancellor, Judge David Turner KC, observed that this was not one of those cases where the parish prayed in aid a particular financial crisis or existential “emergency” for the sale of the painting, which had not been displayed in the church for over 50 years.  [32] [33] The churchwarden petitioners had concluded that they simply did not have the funds to appraise, and then implement, the complex conservation and restoration work that was plainly required.  [34]

If the parish were to invest the sum needed to adapt the church for the purposes of storing a painting, the petitioners said that it would hasten the closure of the church and the withdrawal of parish ministry.  [12] They were convinced that the necessary work to effect the required environmental changes and a “security upgrade” were unaffordable and, in any event, should not be prioritised over the undoubted need for maintenance and improvement generally to the fabric of the church building, the earliest parts of which dated back to 1490.  [34]

The petitioners made clear their desire to insulate the roof void, replace the boiler and heating system, improve external paths, renew internal and external signage, and provide large print service books. [35] Given the fragility of parish finances, the very modest congregational profile and the indisputable existing fabric needs, the petitioners argued that it was simply not possible for them to provide and sustain the facilities required to reinstate the painting in the church. They said, “We cannot afford for a painting that has not been displayed for 50 years to be returned to Saint Peter’s.”  [38]

The Diocesan Advisory Committee (“DAC”) was sympathetic to that reasoning and recommended the grant of the faculty sought. The DAC’s reasons were: that the painting was not original to the church building; that there was a reproduction on display and the sale of the original would not cause any visible change in the church; that the original had not been in the church for over 50 years; that the parish did not want the liability of having to keep the original in the church; that the environment in the church was not suitable for the original and the church was not financially resourced to upgrade its environment and security to make it more favourable for keeping the original there; that the parish was not financially resourced to carry out restoration to the painting; and that the parish had not been able to find another museum to take the painting on loan.  [39], [40]

The Chancellor said that a great deal of jurisprudence had been generated around the disposal of church treasures, and the modern law was identified in the St Lawrence Wootten case. That case identified several matters of relevance, including the following.  [41]

Church treasures should only be removed in the most exceptional circumstances.  They were not “ordinary assets”.  They belonged to the parishioners and were in the care for the time being of the current generation, who had a duty to have regard to their care for the future. They formed part of the original “story” of the church and those who worshipped, cared for and sought to benefit it. They were held in common not only with our predecessors, but also our successors. They were not to be idolised but were expressions of creativity and faith which still had a story to tell and a faith to express.  [42(i)]

When it came to the consideration of sale, the starting point was a strong presumption against sale. In order for petitioners to succeed in overcoming that strong presumption, they had to demonstrate that there were factors of such weight, either individually or cumulatively, that they demonstrated that the grounds were sufficiently compelling to outweigh the strong presumption against sale.  Jurisdiction to allow sales was to be “sparingly exercised”.  [42(iii)]

“Financial need” falling short of “financial emergency” would seldom on its own outweigh the strong presumption against sale, but it could and must be weighed with any other factors favouring such sale. It followed that a critical or emergency situation would carry more weight than more normal (or near universal) pressures on parish finances.  [42(v)]

Insurance and security were always matters of concern, but it was important to remember that there was no legal requirement to insure for full market value and that a determined thief might always succeed, despite whatever reasonable measures were put in place by a parish. The CBC’s guidance stated that any loss would “be of a treasured possession, not one measured in financial terms.”  But it stated that, generally speaking, “parishes should not seek to dispose of valuable items merely because they could not afford full insurance cover.”  [42(vii)]

The Chancellor concluded, essentially for the same reasons identified by the DAC that this was one of those comparatively rare cases where it could properly be determined that the “cumulative weight of individual factors” was indeed sufficient to outweigh the strong presumption against disposal by sale.  [43]

The “regrettable reality” was, the Chancellor said, that 50 or more years ago it was the fact that the painting had begun to suffer harm by its presence in the (occasionally damp) church and that relocation had become a practical necessity. Two lengthy periods in leading galleries followed, the second ending in 2024. Neither of those galleries had expressed any wish to retain, let alone buy, the painting.  Other galleries which had been approached had responded negatively to suggested options and were reluctant to “take on” new loans at all or expend resources on paintings they felt might not sit well in their public collections.  [44]

The CBC’s guidance had made reference to “a perception that some museums are increasingly reluctant to act as repositories for treasures on loan from churches.”  [45]

The Chancellor concluded that “disposal by loan” and “disposal by limited sale” had been properly and reasonably explored, but without success and that the point of request for “disposal by outright sale” had now been reached.  [52]

The faculty sought was granted for sale by auction or private treaty by Bonhams at the best price reasonably obtainable.  [53]

Shiranikha Herbert

Update 20 May 2026, with thanks to David Turner KC. The painting was sold at Bonhams on 25 March 2026 for £267,100 inc. premium.

Here are some important law-and-religion news stories from around the web

• The Fourth Circuit ruled that Virginia may deny state scholarship funding for students pursuing vocational religious degrees, siding with the state in a challenge brought by a Liberty University student. The court held that the Supreme Court’s decision in Locke v. Davey controlled and permitted states to withhold funding for religious instruction programs. 
• The Supreme Court allowed access to the abortion pill mifepristone by mail to remain in place while litigation continues. The decision pauses a lower court ruling that would have imposed new restrictions on the drug’s distribution. 
• A group of federal employees sued Agriculture Secretary Brooke Rollins, alleging that religious messages sent through official USDA emails promoted Christianity in the workplace. The lawsuit claims the emails violated the Establishment Clause by amounting to government endorsement of religion. 
• An Iraqi court ruled in favor of a woman seeking to change her official religious designation from Islam to Christianity, a decision that could have broader implications for religious rights in the country. 
• France’s Senate rejected an assisted-dying bill this week, as Christian and pro-life groups called on lawmakers to preserve the decision. The debate has drawn continued attention from religious organizations and renewed disputes over end-of-life legislation. 

The post Around the Web appeared first on LAW AND RELIGION FORUM.

Antisemitism

On Wednesday, in the course of the Speech from the Throne at the State Opening of Parliament, His Majesty said: “My Government will take urgent action to tackle antisemitism and ensure all communities feel safe”. On the same day, in a letter to the Commons Home Affairs Committee, Sir Mark Rowley, the Metropolitan Police Commissioner, wrote:

“Over the last six weeks, Jewish Londoners have been under a sustained period of attack. This has included the attack on a Hatzola ambulance on 23 March, nine other arson/attempted arson attacks, and most significantly the terrorist attack on 29 April in Golders Green, in which two British Jews were stabbed. British Jews are not currently safe in their capital city. This is unacceptable.”

On Thursday, the Commons Home Affairs Committee held an oral evidence session on responses to antisemitism, while The Times reports that during a visit to the Sternberg Centre, also  on Thursday, the Archbishop of Canterbury said that antisemitism

“is the terrifying reality for so many Jewish communities, as we have witnessed a horrifying increase in antisemitic violence over the past few weeks, months and years. It is completely unacceptable that you live this reality every day. This is not a problem for the Jewish community to solve. It’s on all of us — every single member of our society — to call out antisemitism whenever we see it, and to oppose it without hesitation or qualification.”

Abusive conversion practices

The King’s Speech also included a promise to bring forward a draft Bill to ban abusive conversion practices [Draft Conversion Practices Bill]. The commitment to bring forward a draft bill to ban conversion practices was included in the King’s Speech in July 2024, which set out the Government’s legislative agenda and policy priorities for its first session of Parliament. However, the bill was not published before the Prorogation of Parliament at the end of April 2026, and Labour’s Manifesto did not give a specific date for its introduction.

New faith minister

The Religion Media Centre reports that Nesil Caliskan, MP for Barking, has been appointed as the Parliamentary Under-Secretary of State for Devolution, Faith and Communities at MHCLG, replacing Miatta Fahnbulleh, who resigned when calling for Keir Starmer to quit. Caliskan, 37, was elected in 2024 and has spent the past eight months serving as Comptroller of the Household, the third most senior government whip in the House of Commons. She is the ninth faith minister in ten years. Her Wiki entry says she is the first MP of Turkish-Cypriot heritage, raised in Enfield, with a background as a parliamentary researcher, local councillor and other roles in local government.

The Council of Europe and deportation

On Friday, the Committee of Ministers of the Council of Europe published the Chişinău Declaration, which is principally concerned with the issue of deportation of failed asylum seekers and foreign criminals, especially in light of Article 3 (torture and inhuman or degrading treatment) and Article 8 (private and family life). On the somewhat vexed question of the margin of appreciation, it notes at [5] that;

“In accordance with the principle of subsidiarity and the concept of the margin of appreciation, there may be a range of different but legitimate solutions when applying certain Convention provisions, each of which could be compatible with the Convention depending on the context. Where a balancing exercise has been undertaken at the national level in conformity with the criteria laid down in the Court’s jurisprudence, the Court has generally indicated that it will not substitute its own assessment for that of the domestic courts, unless there are strong reasons for doing so.”

Specifically on migration and expulsion, it says this:

“Specific migration-related issues

16. There are significant, complex, migration-related challenges in various member States which were either unforeseen at the time the Convention was drafted or have evolved significantly since then. The failure to address these challenges adequately may weaken public confidence in the Convention system.

17. The majority of migrants residing legally in the States Parties contribute positively to the receiving societies. Migrants’ fundamental rights and freedoms must be respected and protected in accordance with the principle of non-discrimination.

18. States Parties have the undeniable sovereign right to decide on and control foreign nationals’ entry into and residence in their territory. They have the right to establish their own immigration policies, potentially in the context of bilateral or regional co-operation, and pursue immigration control as a public interest. However, these rights must be exercised in accordance with the provisions of the Convention.

19. It is an obligation and a necessity for States Parties to protect their borders in compliance with Convention guarantees, which may include putting arrangements in place at their borders designed to allow access to their national territory only to persons who fulfil the relevant legal requirements.

Expulsion & extradition

20. The inability to expel or extradite an individual convicted or charged with a serious offence can lead to significant challenges for States, including in relation to their fundamental duty to guarantee the right to everyone within their jurisdiction to live in peace, freedom and security, notably by protecting public safety and national security and preventing disorder and crime.

21. The States Parties are encouraged to develop and clarify domestic frameworks ensuring the effective and context-specific application of the relevant Convention rights, including Articles 3 and 8, in cases involving expulsion and extradition.”

The Declaration is non-binding; however, Alain Berset, the Secretary-General of the Council of Europe, said that it was a “very strong … signal of firm support” for the ECHR by all 46 countries and would “help to guide our own work, as well as that of national authorities and domestic courts”. And in case you are wondering what this has to do with “religion”, the issue is whether or not it will satisfy those calling for the UK to withdraw from the Convention.  BBC report here.

Little green men?

In Re St Edward, Kempley (concerning a memorial to the late Roy Stirzaker) [2025] EEC Glo 1, Mr Stirzaker had been a Morris dancer, and his widow, the Petitioner, wanted a representation of a Green Man carved on his headstone in acknowledgement of that association [1&2]. The priest-in-charge had told her that the proposed design might fall outside the Chancellor’s guidelines, and after consulting the Archdeacon and the Registrar, he had concluded that permission could not be given “as the green man symbol is not considered a Christian symbol” [3].

Ruffell Ch decided that the point needed further research [4]. He noted that there were Green Man carvings in Gloucester Cathedral and Exeter Cathedral and that the invitation to the Coronation of Their Majesties in 2023 “contained the image of a green man” [5]. He also noted that in The Green Man/Foliate Head as a Symbol in the Context of Christian Memorialisation, Helen Hall and Javier Garcia Oliva had examined the origins and interpretation of the Green Man image in English architecture in some detail, “particularly in ecclesiastical settings” [7]. He concluded that “there is a strong body of evidence to suggest that the green man is a Christian symbol. Whilst there is evidence that some have tried to link the green man to past traditions, I am not convinced that this linking is historically accurate” [11]. He therefore granted a faculty [12]. [With thanks to Ray Hemingray.]

[Update 26 May 2026: A Guest Post “The Green Man/Foliate Head as a Symbol in the Context of Christian Memorialisation” is here.]

“Coelos ascendit hodie”

On Ascension Day, Janet Gough sought to champion a return to public view for William Hogarth’s vast Ascension triptych – proof that the English could rival the Continentals in grand-scale church history painting. Painted for St Mary Redcliffe, it now hangs hidden behind a curtain in St Nicholas, Bristol, a backdrop for the church’s drum kit and keyboard.

The painting was commissioned as a new altarpiece for St Mary Redcliffe and was Hogarth’s only commission from the Church of England, for which he was paid £525 and for which the receipt still exists. The Bristol Museum & Art Gallery “officially acquired the triptych in 1955 from the Art Collections Fund” and ”it has been on display at St Nicholas Church since the 1970s”.

Although apparently not subject to earlier judicial consideration, in view of its location in St Nicholas Church, the painting now falls within the faculty jurisdiction, and any changes to its location must be assessed by the Bristol Consistory Court. Re St Stephen Walbrook is one of the few judgments that addresses the peregrinations and disposal of large but otherwise unwanted works of art.

And finally…

The United Reformed Church, which has about 44,000 members across 1,250 congregations, has rebranded its magazine from Reform to Reformed after readers became “fed up” with being confused for Nigel Farage’s party. A huge 86% of readers of the national publication supported the change.

The magazine’s editor pointed out that the URC is not affiliated with any political party and “does not want the name of its magazine to suggest that it is”.

“3. In this Act, a protected person is a person attending a protected premises for the purpose of–

(a) accessing the treatment, information, advice or counselling there,

(b) accompanying a person described in paragraph (a), at the invitation of that person, or

(c) working in, or providing services to, the protected premises.”

In Director of Public Prosecutions v Johnston [2026] NIMag 1, Clive Johnstone, a former President of the Association of Baptist Churches in Ireland, held what he described as a “gospel outreach” in a Safe Access Zone [“SAZ”] around Causeway Hospital, Newbridge Road, Coleraine, on 7 July 2024 [1]. There was no dispute that he was within a Safe Access Zone as defined by the 2023 Act at the material time [5]. He liaised with the police in advance of the event and was warned that if the event was “conducted in the safe access zone, it will give rise to a reasonable suspicion that you have committed an offence.  Police will be required to take enforcement action” [9].

The police filmed the event. There were about nine people present, with the defendant singing and playing a ukulele and addressing the gathering through a PA system.  The defendant’s address was “of a religious nature”, and the police agreed that the term “abortion” was not used at all, “in accordance with a prior undertaking not to mention ‘abortion’ or to have any leaflets”.  Nor were there any placards [11]. In the end, however, the Inspector in charge warned the group that failure to leave the Safe Access Zone would be a breach of s.6 of the 2023 Act, and they might be prosecuted.  The others started to go, but Mr Johnston remained.  He was warned that if he did not leave the zone immediately, the police might remove him and that if he resisted, he might be prosecuted [12].

What is now s.5(2) of the 2023 Act had been the subject of a challenge in Reference by the Attorney General for Northern Ireland – Abortion Services (Safe Access Zones) (Northern Ireland) Bill [2022] UKSC 32, in which the Attorney had argued that the provision was a disproportionate interference with the freedom of conscience, speech and assembly of anti-abortion protesters and demonstrators under Articles 9, 10 and 11 ECHR [37]. The Supreme Court had dismissed the challenge, Lord Reed concluding at [156] that

“The right of women in Northern Ireland to access abortion services has now been established in law through the processes of democracy.  That legal right should not be obstructed or impaired by the accommodation of claims by opponents of the legislation based, some might think ironically, on the liberal values protected by the Convention.  A legal system which enabled those who had lost the political debate to undermine the legislation permitting abortion, by relying on freedom of conscience, freedom of expression and freedom of assembly, would in practice align the law with the values of the opponents of reform and deprive women of the protection of rights which have been legislatively enacted.”

In his judgment, DJMC King said that Mr Johnston’s rights under Articles 9, 10 and 11 ECHR were “clearly engaged”, but no-one disputed that they were qualified rights [42]. He was bound by the Supreme Court’s decision, and the purpose of the hearing was

“ to determine if the ingredients of the offence under section 5 have been established to the necessary standard, the Supreme Court having decided that a conviction following that exercise would not be a disproportionate interference with a defendant’s Convention rights” [44].

He concluded that Mr Johnston had “deliberately placed himself within the SAZ on 7 July 2024 after prolonged prior contact with the police” and “was aware that he was at risk of breaching the provisions of that Act, but he did not divert from the course he had set” [61].

The defence had also raised a devolution issue: in brief, whether the Act breached the defendant’s rights under Articles 9, 10 and 11 ECHR, singly or together with Article 14 and was therefore outside the legislative competence of the Northern Ireland Assembly [71]. He concluded that this, in effect, invited “re-litigation of matters already determined by the Supreme Court” – which he refused to do [73]. He also refused to make a referral to the Court of Appeal [75].

Mr Johnston was guilty of both charges [76].

In the Matter of a Complaint under the Clergy Discipline Measure 2003 before the Bishop’s Disciplinary for the Diocese of Derby

Determination

Two preliminary matters arose at the outset of the proceedings, viz. whether the hearing could proceed in the absence of the Respondent and whether to grant an application for the drawing of an adverse inference due to non-attendance [1].

Whether the hearing can proceed in the absence of the Respondent

The Rule 42 Clergy Discipline Rules 2005 provides the Chair with a wide discretion; it states:

“The Registrar of Tribunals or the Chair may proceed with a hearing notwithstanding the absence of the complainant or the respondent, provided the Registrar of Tribunals or the Chair is satisfied that the absent person has had notice of the hearing or that written notice of the hearing has been duly sent or delivered in accordance with Rule 101.”

There was no doubt that the Rev Karen Padley was aware of the hearing date of the proceedings [1].

“In considering whether to proceed in her absence, consideration must be given to the overriding objective to deal fairly with all parties treating each on an equal procedural footing, keeping the parties informed of the allegations and avoiding undue delay and expense…Not to proceed would simply result in further delay with no evidence that a different outcome would arise in the light of her repeated lack of response”[4].

The Chair concluded that the requirements of CDR 42 had been met; The Chair also considered that the overriding objective favours that the hearing goes ahead[5].

Application by the Designated Officer (DO) for a direction for an adverse inference

The Clergy Discipline Rules 2005 Rule 2(2), provides that “any failure to co-operate by a party may result in adverse inferences being made against that party at any stage of the proceedings” [6]. The Designated Officer sought an adverse inference finding in the light of the Respondent’s failure to engage with the process either by responding to correspondence or by attending the hearing [7]. However, whilst there had clearly been multiple failures to engage and participate, the Tribunal could not conclude that the failure was due to the Respondent’s unwillingness to submit her testimony to scrutiny nor necessarily because she did not have a case to answer. The Tribunal therefore declined to direct an adverse finding inference from the Respondent’s failure to engage with the proceedings [8].

Determination

On 30 October 2024, the Deputy President of Tribunals referred the following charges for determination to the Bishop’s Disciplinary Tribunal. The conduct of the Respondent…amounted to neglect or inefficiency in the performance of the duties of her office within s.8(1)(c) of the Clergy Discipline Measure 2003 and/or was conduct unbecoming or inappropriate to the office and work of a clerk in Holy Orders within s.8(1)(d) of the Measure in that she:

(i) Failed to respond to the complainant’s emails about making arrangements for either the respondent or the complainant to give home communion to a vulnerable person (Mrs C a longstanding worshipper who died in February 2024) thereby occasioning confusion and a risk of possible anxiety to Mrs C.

(ii) Failed persistently to communicate with, meet with or otherwise properly engage with the complainant, a clerical colleague in the same group of benefices in which they both minister together.

The Respondent Revd Karen Padley was ordained as a priest in 2001. She has been the vicar of Marlpool since 2004 and in 2016 she became priest in charge of Heanor and Langley Mill and Aldercar, Derby. The Complainant Revd Lisa Shemilt was ordained as a priest in 2006 and appointed associate minister in the benefices in 2016. They had at the outset been on good friendly terms and had worked well together professionally. From about 2020 there was a deterioration in the relationship when the Respondent failed to respond to communications from the complainant. The Complainant also attempted to communicate with the Respondent but received no response [10].

The Tribunal allowed the statements of the witnesses to stand as their evidence in chief and asked additional questions of the witnesses, [11] to [14]. The Complainant confirmed that the relationship with the Respondent had been fulsome at the start but had deteriorated from 16 March 2021. She had become extremely difficult for anyone to deal with. The communication to her had been largely through email and occasional telephone messages. She reported that it had not been a gradual deterioration, it was “like a tap being turned off”, it just stopped.

[…]

The Complainant reported on parishioners who had felt very strongly against the respondent taking funeral services; such was the strength of feeling that one family had gone elsewhere for their funeral service. The complainant stated that she was aware of the respondent exhibiting rudeness and that she could be dominant and domineering in her contact with others [12].

The Venerable Karen Hamblin also gave evidence as a witness in support of the Complainant relying on her written statement as her evidence in chief. She reported that she had previously been colleagues with the Respondent discussing matters of relevance to the diocese and to their ministries…There was anecdotal evidence that prior to Covid the respondent had not always been easy to communicate with and her response to communications had been intermittent…The respondent was looking after her father who had passed away in August 2025 [13].

In her submissions to the Tribunal, the DO relied on the evidence of the Complainant as cogent, consistent and credible. The Complainant had been concerned at the respondent’s conduct but had not herself stopped communicating with the respondent seeking to keep her informed and assisting if there were difficulties. Any anxiety on the part of the Respondent could have been avoided by a simple response [14].

Decision

The Tribunal found the facts alleged were proved. The accounts given by the Complainant and the witness have been clear, consistent and credible and remain unchallenged by the Respondent or by any other evidence. It stated:

“It is not for the panel to speculate or guess the Respondent’s position. She has had many opportunities to put forward a defence or explanation but has repeatedly failed to do so. We are satisfied that the matters raised by the Complainant occurred and that the Respondent’s failure to respond in each of the instances alleged amounted to neglect and inefficiency in the performance of her duties” [16]

It found the Respondent’s behaviour to be puzzling and in the face of many opportunities to act otherwise, to have been disappointing in one tasked with important duties in her role. Having found the matters proved the Tribunal did not move to a consideration of penalties but concluded that the Respondent should be given the opportunity to present mitigation and/or submissions regarding penalty in accordance with directions to be given following this determination [17].

Determination of the Tribunal on Penalty

The decision on penalty was deferred in order to receive submissions from the parties. In accordance with Rule 51 CDR 2005, the Panel invited The Bishop of Derby, The Rt Revd Libby Lane, to express her views as to the appropriate penalty [2]. The Respondent did not attend the hearing on 31 March 2026, and had received directions for  submissions, as she had failed to attend the hearing on 24 November 2025. The Panel was satisfied that the Respondent had decided to continue to deliberately absent herself from attendance at these proceedings, as she has done throughout [3].

The Panel considered the Clergy Discipline Commission’s March 2023 Guidance on Penalties in particular Paragraph 3 which deals with misconduct in public ministry and the trust placed in the clergy by members of the Church and by the wider community[5]. It found that the Respondent’s misconduct was a deliberate and damaging failure to comply with the high standards of Christian behaviour set out in the Ordinal required of clergy [6].

Approach to Penalty

In deciding upon the appropriate Penalty, the Panel considered all the material that has been placed before it[7]; it adopted a staged approach to penalty, applying the Clergy Discipline Commission’s ‘Guidance on Penalties’, and conscious of the need to act fairly, justly, and proportionately[8], and also considered Paragraph 6 of the Guidance which provides that any penalty should be proportionate to the misconduct involved[9].

Stage 1 – Harm and Culpability: The Panel considered that the caused to the Complainant was severe as set out in harm the Victim Impact Statement. But the harm was caused more widely to the congregation, as was clear from the examples instanced in the first hearing and to the public in terms of confidence in the Church and damage to the reputation of the Church.

The Respondent’s actions took place suddenly and in such a way as to seriously disturb and undermine the Complainant’s own duties and responsibilities and in a way which disregarded the trust the congregation placed in Church leaders. Culpability was high as there was deliberate and utter failure to engage with the Complainant despite all efforts to reach out to her[10].

Stage 2 – Aggravating and Mitigating factors: The Panel considered as aggravating factors that the conduct was persistent and prolonged…The extent of her ministry, encompassing 3 benefices, would result in her conduct being widely felt…Over this
prolonged period of non-contact and attempts to reach her, she did not take the opportunity to reflect upon and/or alter her conduct in any way[11].

In so far as mitigating factors are concerned the Panel could not find any were present. The Panel was aware that the misconduct found took place during the Covid pandemic and that at some time the Respondent’s father was said to have been unwell. But none of these facts, nor any others, were submitted by the Respondent as grounds of mitigation. It is not for the Panel to speculate as to what may or may not have been a relevant mitigating factor[12].

Stage 3 – Penalty: In determining the appropriate penalty, the Panel was conscious of the necessity that any penalty imposed should be proportionate to the seriousness of the misconduct found proved. The Panel considered the penalty in reverse order of seriousness. Having concluded that the threshold for prohibition from ministry had been crossed, and that none of the lesser penalties would be sufficient, the Panel considered whether there was a realistic prospect that the Respondent could be rehabilitated into public ministry if provided with the appropriate training and support[16].

Notwithstanding that the Respondent had not engaged, had not shown remorse or indicated any explanation for her behaviour and had declined to participate in or engage with these proceedings, in the Panel’s view, there was a prospect of rehabilitation if the Respondent chooses to engage. Rehabilitation could enable her to return to ministry and would also ensure protection from repetition of such misconduct in the future. In coming to that conclusion the Panel drew re-assurance from the fact that following limited prohibition there is a formal process of assessment prior to any return to ministry[17].

The Panel’s view, which was shared by the Designated Officer, was that the length of the prohibition should be 3 years after which there would be no automatic right to return to ministry. Pastoral colleagues, congregations and the public would be protected as re-admission will involve a process of independent assessment undertaken for, and to advise, the Bishop[18].

Accordingly, the Panel unanimously concluded that the only appropriate penalty in all the circumstances of this case, was one of removal from the offices of Incumbent of the benefice of Marlpool, priest in charge of the benefice of Heanor and priest in charge of the benefice of Langley Mill with Aldercar, all in the diocese of Derby with immediate effect and that the Reverend Karen Padley is prohibited from the exercise of any of the functions of her Holy Orders for 3 years from 31 March 2026 [20].

Comment

The Clergy Discipline Measure 2003 became fully effective on 1 January 2006,  since when Tribunals have addressed approximately 50 referrals. The relatively few that have proceeded without the participation of the Respondent will be reviewed in a subsequent post. That of Rev Karen Padley is unusual in that it was conducted despite complete absence of involvement, and demonstrates how the the current CDM procedure attempts to address the interests of all parties, even those who do not participate.

[1] “She has been kept informed and given information by the Registrar of Tribunals; She has been sent correspondence including by personal service, attempts have been made to contact her by telephone and she has not responded; She was warned in correspondence that the case could proceed in her absence if she continued not to engage; She was informed that if she did not have legal representation she could apply for ecclesiastical legal aid to support legal costs incurred in the proceedings; She has not responded to any correspondence, she has not challenged any evidence and has not produced any evidence in support of her case; She is not of course required to instruct a solicitor, she is entitled to represent herself, but she has not taken either course”. [3].

On 4 May 2026, The Marlpudlian – “The website for All Saints Church and the wider community” – posted “A Big Change at All Saints” in which it informed parishioners that “As of Tuesday 31st March 2026, the Revd Karen Padley is  no longer the vicar of All Saints church, nor is she priest-in-charge of the churches of St Lawrence Heanor, St Andrew’s Langley Mill and St John’s Aldercar”. It stated:

“Revd Karen Padley has been removed from office as Priest in Charge of St Lawrence Heanor, St Andrew Langley Mill, and St John Aldercar, and Vicar of All Saints Marlpool, by an Independent Tribunal established under the Clergy Discipline Measure 2003, and is prohibited from ministering as a priest in the Church of England for three years.

The result of this is that these parishes are now in vacancy. During this time the responsibility for the continuation of ministry is assumed by the Churchwardens and the Area Dean, together with the assisting clergy of the parishes, who will be fully supported by the Acting Archdeacon of East Derbyshire and colleagues in the Parish Support Team.

The Diocese of Derby has offered pastoral and practical support …at this time.”

No further details (have) been made available to us at this time However, for the avoidance of any misunderstanding or erroneous assumptions it can be stated that: This decision was NOT as the result of any safeguarding issue or financial impropriety on the part of [the former incumbent]” (emboldening and capitalization in original).

Legal Issues

The subsequent post Non-involvement with CDM proceeding (II) addresses the Tribunals considerations, which observed (at [16] of the Determination) “We have found the Respondent’s (i.e. the former incumbent’s) behaviour to be puzzling and in the face of many opportunities to act otherwise, to have been disappointing in one tasked with important duties in her role“. This post will cover whether the hearing could proceed in the absence of the former incumbent and whether to grant an application for the drawing of an adverse inference due to non-attendance.

Comment

The Marlpudlian article acknowledged the associated disquiet which is often generated in events such as this. It stated:

“As you can appreciate, this sudden removal of our vicar came as something as a shock to the All Saints congregation. To date, nothing beyond the above statement has been published so unsurprisingly rumours abound. Until the ruling is published on the Church of England website[1] there is nothing we can add to the above statement”.

[1] The timeline of events is uncertain. The Determination and  Penalty are dated 7 January 2026 and 31 March 2026, respectively, although this does not necessarily reflect when the documents were placed in the public domain; they were not included in the L&RUK monthly reviews up to and including April 2026. The Marlpudlian article is dated 4 May 2026 although it commences with “As of Tuesday 31st March 2026…”.

The independent review into antisemitism in schools and colleges, chaired by Sir David Bell, has launched a call for evidence. It seeks views from people with relevant lived experience, knowledge or expertise of antisemitism in schools and colleges and will inform practical recommendations for the Department for Education and sector leaders on how effectively to prevent, identify and respond to antisemitism and other forms of hatred and prejudice.

You can submit evidence here. The call for evidence ends on 1 July.

Isle of Man: Assisted Dying Bill

As an update to our earlier post, we note that Manx Radio has now reported that the Ministry of Justice has decided that it is unable to recommend the Isle of Man’s Assisted Dying Bill for Royal Assent and that the Isle of Man Government has received a letter to that effect from the Secretary of State for Justice following departmental scrutiny of the legislation.

The Ministry of Justice had sought clarification of the arrangements for monitoring assisted deaths, safeguards against coercion and ensuring that individuals have capacity to make decisions and has concluded that, though the Manx Government has provided comprehensive assurances and commitments that would mitigate the legal risk significantly, they do not form part of the Bill. It is therefore the view of the UK Government that those matters must be addressed in order for the Bill to comply with the European Convention on Human Rights.

According to the reports, Tynwald is to debate a number of amendments to the Assisted Dying Bill in June, in the hope of bringing it into compliance with the ECHR.

Abortion services and safe access zones again

The BBC reports that Clive Johnstone, a former President of the Association of Baptist Churches in Ireland, has been found guilty by Coleraine Magistrates’ Court of breaching abortion buffer zone laws by preaching near a hospital. He was convicted under the Abortion Services (Safe Access Zones) Act (Northern Ireland) 2023 of doing an act in a safe access zone with the intent of, or being reckless as to whether it had, the effect of influencing a protected person attending the premises. He was also found guilty of failing to comply with a direction to leave a safe access zone. He was fined £450 for both offences.

BAILII has published the judgment here: we hope to produce a note later in the week. [With thanks to Sahida Khanom and David Lamming.]

The Council of Europe and religious discrimination

On 21 April, the Parliamentary Assembly of the Council of Europe adopted Resolution 2647 (2026), Countering discrimination based on religion and protecting freedom of religion or belief in Europe. Inter alia, it calls on member states to collect data on intolerance and discrimination on the grounds of religion, to provide religious literacy training for public officials, law enforcement officers and the judiciary, to provide schoolteachers with training and guidance on religion based on a pluralist and inclusive approach, and to strengthen co-operation with media organisations to promote fair and accurate representation of religious beliefs. 

Ian Huntley: funeral arrangements

Although we have never reviewed the funeral arrangements for Ian Huntley, “the Soham Murderer“, his murder at maximum security HMP Frankland appears to have generated appreciable interest in our post concerning the scattering of Ian Brady’s ashes, for which many of the principles related to the funeral arrangements (possession of the body, the need for secrecy) appear to be similar. (See also Peter Collier’s comment below).

For closure on this story, which otherwise would have fallen outwith our ambit, we can report that on 9 May 2026, the Independent carried the story Soham murderer Ian Huntley cremated in £265 eco-friendly coffin as taxpayers pick up funeral tab. For the curious, the article gives details of the arrangements. 

(AI) Claudia

Evolutionary biologist and atheist writer Richard Dawkins has stirred debate over artificial intelligence after saying recent conversations with AI chatbot Claudia left him convinced they may possess some form of consciousness, even if they are unaware of it themselves. However, Prof Jonathan Birch, director at the London School of Economics’ Centre for Animal Sentience, has said that AI consciousness is “an illusion” and “there is no one there”, just a string of data-processing events that often occur in geographically different locations. In light of our recent experience with AI, we would concur with Professor Birch. At its present state of development, the strength of AI lies in its ability to access and synthesize existing material, and rephrase a wide range available knowledge

Quick links

• Hansard Society: The assisted dying bill: How could the Parliament Act be used?: the Hansard Society adds a note as follows: “Together, the 1911 and 1949 Acts are often referred to as the ‘Parliament Acts’. For clarity, however, this paper treats them collectively as a single framework, referring to them in the singular as the Parliament Act”, Page 9, para. 2. [But I can’t think why that would add clarity: FC.]
• Metropolitan Police: Met announces new dedicated Community Protection Team as further antisemitic hate crime arrests made this weekend.
• South Wales Police: Anthony Pierce: Appeal for victims to come forward, (7 May 2026).

Independent safeguarding audit of the Diocese of London published

Overview of main findings

The London audit identifies progress in safeguarding arrangements across the Diocese. It notes that an “overwhelming majority” of respondents from the London Diocesan Fund workforce, parishes and wider worshipping community reported improvements, and said that the importance of safeguarding is now better recognised. INEQE found that a safeguarding culture is becoming “embedded” across the Diocese, with respondents describing a growing sense of confidence in reporting concerns.

The audit also identifies clear areas where further work is needed. It notes that some victims and survivors do not experience safeguarding as sufficiently person-centred or trauma-informed, and emphasises the importance of ensuring that learning from training is consistently applied in practice. The audit concludes that, while the Diocese is well-led and progress has been made, further investment will be required to ensure safeguarding arrangements are robust and sustainable across the Diocese.

The London College of Bishops have issued a joint statement responding to the recommendations of the report. 

[…]

Background

In August 2023, the INEQE Safeguarding Group was appointed by the Archbishops’ Council to carry out the next round of independent external audits of Church of England dioceses and cathedrals. The purpose of these audits is to ensure that dioceses, cathedrals and palaces are doing all they can to create environments where everyone feels safe, valued and respected.

The independent audit programme will run for five years, from 2023 to 2028, with audits commencing in January 2024. Audits are now conducted in dioceses and cathedrals at the same time, having previously been carried out separately.

As part of the Diocese of London audit, INEQE:

• collated and analysed 330 documents

• held nine focus groups and 70 engagement sessions involving 154 people, including church officers (staff and volunteers), external partners, victims and survivors

• received 2,390 anonymous survey responses from victims and survivors, children and young people, worshippers and church workers

Further information about safeguarding at the Diocese of London, including how to raise a concern or access support, is available on the Diocese’s safeguarding page.

Background

Talmud Torah is a primary school for Charedi boys which serves the large community in Stamford Hill. For Charedis, sending their children to a Charedi school is a religious obligation [5]. It was not disputed that there was a significant shortage of school places in the area for Charedi children [6]; however, the site had been changed to use as a school without planning permission, and Hackney LBC had refused an application for retrospective planning permission [7]. An appeal to the Secretary of State via a Planning Inspector had failed, and one reason for its failure had been noise from the school and the consequent disturbance to local residents [7].

The application was made on four grounds:

1. that the Inspector acted contrary to section 6(1) Human Rights Act 1998 because the decision disproportionately infringed the Claimants’ Convention rights, particularly under Articles 8 (private and family life), 9 (religion), 14 (discrimination) and Article 2 Protocol 1 (education);
2. that the Inspector had erred in law by excluding from her assessment the Council’s duty under the Education Act 1996 to provide sufficient school places and the question of whether or not Policies LP24 and LP8 of the Local Plan were out-of-date.
3. that in considering the children’s Convention rights, the Inspector had failed to have regard to an obviously material consideration and to give adequate reasons in relation to her conclusions, and/or that her conclusions were irrational.
4. that she had erred in law by departing from the expert evidence on noise and/or national planning policy on noise without having cogent and compelling reasons for doing so, and/or by failing to give adequate reasons in relation to her conclusions on noise, and/or by failing to act fairly in her approach to the Appellant’s expert evidence and/or by reaching an irrational conclusion [3].

The judgment

Lieven J dismissed the application.

As to Grounds 1 and 3, the contention had been that, because the alleged discrimination was on the basis of religion, the test was manifestly without reasonable foundation. However, for the Inspector to have allowed the appeal would have involved a significant interference with the residents’ Article 8 rights. The balance between the rights of the Claimants and of the local residents was a matter for the Inspector, and “no argument about the approach to proportionality by the Court could lead to a different conclusion”. Given the Inspector’s findings, there was plainly a reasonable foundation for her conclusion and Grounds 1 and 3 therefore failed [38].

As to Ground 2, “it is not for the Inspector to make legal rulings on whether the Local Education Authority … is in breach of a duty to provide sufficient school places. That would be a matter for the Administrative Court of the High Court in a judicial review.” The duty was laid on the LEA, not on the Planning Authority [42], and because it was a target duty, any finding of a breach would be hard to establish [43]. The Inspector had, in fact, taken account of the unmet need for school places and had concluded that the development was acceptable in principle – but having done so, she had had to weigh that against the harm to local residents [44].

As to Ground 4, she had been fully entitled to place great weight on the evidence of the residents and to conclude that, in the light of their evidence, the impact of the increased noise would be intolerable [49].

Permission refused [51].

[With thanks to David Lamming for drawing the case to our attention.]

Independent audit report of the National Safeguarding Team

05/05/2026

The first independent audit of the Church of England’s National Safeguarding Team (NST) has been published today. The audit was carried out by the INEQE Safeguarding Group and commissioned by the Archbishops’ Council, following a recommendation from the National Director of Safeguarding. It assesses the work of the NST against the National Safeguarding Standards. The report highlights areas of good practice as well as identifying 66 recommendations for further improvement. Some of these relate to the wider Church’s safeguarding structures, while others are specific to the NST.

You can read the full report here.

Areas of good practice

The audit recognises that the NST has undergone significant transformation in recent years and is now a professional national function focused on improving safeguarding practice across the Church of England.

It highlights a strong internal culture, supported by confident leadership and a senior team with a wide range of expertise. Staff reported feeling able to raise concerns and contribute to ongoing development.

The report recognises the significance of the development of the National Safeguarding Standards. These now shape policy, training, supervision and day-to-day practice in churches and cathedrals:

“The National Safeguarding Standards establish a critical framework that constitutes good safeguarding practice. The NST defined and built this collective understanding to support parishes, dioceses, and cathedrals locally in developing a consistent, high-quality approach to safeguarding practice and culture.”

The audit also commends the NST’s shift towards safeguarding based on evidence and information, and it states that the casework team’s triage system functions well.

“The audit saw evidence of good practice by the NST, with caseworkers effectively receiving referrals, collating information and analysing cases. There was evidence of escalation to senior managers as appropriate, swift triage and allocations being accompanied by a written brief from the casework manager.”

Recommendations and next steps

The audit identifies several areas where further work is needed to strengthen safeguarding arrangements. These include:

• improving communication around survivor participation;
• strengthening feedback mechanisms with dioceses and cathedrals;
• clarifying the circumstances in which the National Director of Safeguarding can intervene in local cases;
• developing specialist HR safeguarding expertise;
• ensuring resilience and contingency planning for case management systems;
• further developing national safeguarding training and learning infrastructure.

The NST will now consider the recommendations in detail and set out how these will be taken forward.

[…]

About the audit

The audit included:

• 68 engagement sessions involving 96 individuals;
• analysis of 950 documents;
• 222 survey responses from victims and survivors, NST staff, and those working across dioceses and cathedrals;
• seven focus groups and a confidential contact process.

Support information

If you or anyone you are in contact with is affected by the publication of this report and would like to talk to someone independently, please call the Safe Spaces helpline on 0300 303 1056 or visit safespacesenglandandwales.org.uk.

Alternatively, you may wish to contact the National Safeguarding Team at safeguarding@churchofengland.org.

Comment

There is further information in the Church Times article(£) “NST audit makes recommendations to expand Church’s national safeguarding capacity“. It observes: “No costing or calculations on staffing are included”, verb. sap.

In Re Ormskirk Parish Churchyard [2026] ECC Liv 2, Mr and Mrs Newsome petitioned for a faculty to exhume the remains of their son Adam, who had died of cancer in 2007, aged 19. Their intention was to rebury him in West Lancashire Cemetery [1 & 3]. Their reasons for making the application were that the churchyard and the church grounds had become

“a gathering place for youths indulging in antisocial behaviour, and perhaps more concerning drug abuse. There is anecdotal evidence that needles and other drug paraphernalia have been found lying in and around the gravestones in the churchyard” [5],

This caused them considerable distress, and Mrs Newsome found that visiting her son’s grave made her feel “intimidated and unsafe” [7]. The Newsomes said that it was also becoming increasingly difficult to maintain the grave to an acceptable standard [8].

The judgment

HHJ Wood KC, Ch noted that the principles that he had to apply to questions of exhumation and reburial were set out in two judgments of the Court of Arches and the Chancery Court of York: Re Blagdon Cemetery [2002] 4 All ER 482 and Re Christchurch Alsager [1999] Fam 142, and a consistory court would only grant a faculty for an exhumation in exceptional circumstances and for good and proper reasons:

“A change of mind or a general desire that family members be buried together is usually insufficient, and a delay caused by the passage of time will make it less likely that such exhumation will be allowed, without very compelling reasons” [11].

Moreover,

“… the importance of the permanence of Christian burial cannot be understated. The peaceful rest of the departed is to be of paramount importance. Further, a consistory court should not be swayed out of the undoubted sympathy which is held for the family of those who have passed away and the additional grief which might be caused by the refusal of an application for exhumation” [12].

In essence, the justification for the application was the distress caused to Mr and Mrs Newsome by the allegedly poorly maintained churchyard and the antisocial behaviour that they encountered when they visited their son’s grave, and the Chancellor had not been able to identify any previous case in which a consistory court had found antisocial behaviour to be a good and proper reason for departing from the principle of the permanence of Christian burial [14]. Further, if he were to order an exhumation in this particular case, it might set a precedent that would make it difficult to refuse any other exhumation application made in similar circumstances [14]. With regret, he refused the application [15].

“[T]he first modern ABC to meet a Pope wasn’t Michael Ramsey. To adapt a well-known saying, Geoffrey Fisher did some of the things that Michael Ramsey did, earlier and in gaiters“: Andrew Connell.

“One person’s filibuster is another’s detailed scrutiny of sloppy and hastily assembled legislation”: Prof. Mark Taubert.

Abortion buffer zones in Scotland

There have been various reports that the case against Rose Docherty, who was arrested and charged under the Abortion Services (Safe Access Zones) (Scotland) Act 2024 after holding up a placard outside Glasgow’s Queen Elizabeth University Hospital saying “Coercion is a crime, here to talk, only if you want”, has been dropped.  According to various  media reports, Sheriff Reid ruled that the prosecution had “failed to disclose an offence known to the law of Scotland” because Crown Office had not led any evidence that she had influenced anyone seeking abortion services on the day in question. He therefore deserted the trial diet pro loco et tempore – which means that the proceedings against her were discontinued but can be resurrected if further evidence comes to light. It had been argued on her behalf that the charges violated her Article 10 right to freedom of expression.

According to a report in the Daily Record, a spokesman for the Crown Office and Procurator Fiscal Service said that “COPFS notes the decision of the Court and will consider it carefully”.

Counter-terrorism security and the heritage sector

Historic England has announced a webinar series looking at the application of counter-terrorism security measures at heritage sites. The first webinar, on Wednesday 10 June at 13:00, will cover the Terrorism (Protection of Premises) Act 2025 and how it applies to the heritage sector. The webinar, supported by the National Counter-Terrorism Security Office, will also look at the current terrorism threat in the UK, how and where incidents might happen, and the types of threats that heritage sites may need to protect against. Register here: Microsoft Virtual Events Powered by Teams. We understand that the webinar is to be recorded for subsequent viewing.

Weddings law reform

On Tuesday, Alex Davies-Jones, a junior minister in the MoJ, confirmed that the Government intends to consult on reforming weddings law in England & Wales, but the timing of the consultation has evidently not been decided yet.

Religious discrimination and the Lib Dems

The Liberal Democrats have admitted breaching the human rights of a former BBC journalist, David Campanale, after he was deselected as their parliamentary candidate for Sutton and Cheam in the 2024 general election because of his overtly Christian views. The Lib Dems argued that during the selection process he had not disclosed his previous membership of the Christian People’s Alliance, which opposed same-sex marriage and called for repeal of the Abortion Act 1967. According to the reports, the party also argued in its defence submission that it was a “statement of fact” that the “party of past prominent Liberal Democrats with Christian beliefs, such as Shirley Williams and Charles Kennedy, was over”.

The party admitted unlawful religious discrimination, presumably in breach of Article 9 ECHR.

Edward Colston: the future of All Saints church

Earlier this year, we reported that the Diocese of Bristol had announced the completion of the first stage of a consultation to determine the future of All Saints Church, Corn Street, Bristol. Formerly known as All Hallows, the church is thought to contain the tomb of the slave trader Edward Colston and a memorial to him by Flemish sculptor John Michael Rysbrack. The church was closed to the public in 1984 and used as an education and resource centre for the Diocese of Bristol until 2015. 

The Diocese has now issued a Press Release (27 April 2026) indicating the completion of the first Phase and giving details of the next phase, including how the general public can take part. The second and final stage will bring together a range of groups through a series of meetings, including three open focus groups for which any member of the public may sign up. 

Each session will include facilitated discussion exploring the perspectives and proposals that emerged from Stage One. All participants will be able to share their views in a safe, open and respectful environment. If building works permit and the site is safe to access, participants will also be offered the opportunity to join a guided visit to All Saints on a separate date. If an in‑person visit is not possible, a virtual tour will be offered instead. Further details are included in the Press Release. 

Quick links

• Eva Maria Bredler, Verfassungsblog: The Human Trick – Scholarship from Somewhere: on the place of AI in legal research.​
  

   

Church in Wales

The powers of sentence open to Disciplinary Tribunals in the Church in Wales are set out at Paragraph 18 of Chapter IX of the Constitution of the Church in Wales. These range from the most minor, an absolute discharge, to the most serious, the deposition from Holy Orders and expulsion from the office of a Cleric in the Church in Wales.

Four of the recent determinations[3] cite the decision of the Provincial Court of the Church in Wales in the matter of the Reverend Clifford Smith Williams, for which the judgment was handed down on 1 November 1997[4]. Contemporary reports note that Williams was the first priest in the Church of Wales to be stripped of his office, on account of a six-year adulterous affair, that he had lied under oath and had not once expressed any regret or remorse.

Recent determinations

The Church in Wales website includes links to recent Decisions and Penalties for which the President of the Tribunal has ordered details to be published. However, these range from a single paragraph to 12 pages in length. With the exception of The Rev Ryan Forey, all of these current Determinations concern clergy who have been deposed from Holy Orders and expelled them from the office of Cleric in the Church in Wales. These decisions are summarized below.

Anthony Pierce – February 2026. Decision

On February 7th 2025, Anthony Pierce, the former Bishop of Swansea and Brecon from 1999 until 2008, appeared at Swansea Crown Court and admitted five counts of indecent assault on a male child under the age of 16. The offences dated from between 1985 and 1990, when Mr Pierce was a parish priest in West Cross, Swansea.

This was the first occasion on which the Church in Wales found itself in the circumstance of deposing a Bishop from their Orders. Section 42 of Chapter IX of the Constitution envisages the duty falling to the Bishop of the Diocese where the cleric holds, or last held, office. It does not make separate provision for Bishops, although a Bishop clearly falls within the Constitutional definition of a Cleric. However, the Tribunal was mindful that powers of deprivation of Bishops (and other disciplinary sanctions) were vested in the Metropolitan prior to disestablishment [5]. “For the avoidance of doubt and uncertainty”, the Tribunal stated it believed the appropriate way forward was for the Archbishop and the Diocesan Bishop jointly to execute a deed of deposition.

The Tribunal directed the then Archbishop of Wales, jointly with the Diocesan Bishop of Swansea and Brecon, to depose the Right Reverend Anthony Edward Pierce from Holy Orders and to expel him from the office of Cleric in the Church in Wales [21], and noted the effects of a deed of deposition:

[22]. … Section 42 (3) of Chapter IX of the Constitution state that the effects of a deed of deposition are the same as a deed of relinquishment. Such effects are set out in the Canon to amend the Canon Law Relating to Clerical Disabilities dated 19 April 1990. The effects include [emphasis in original]:

(a) he or she shall be incapable of officiating or acting in any manner as a cleric of the Church in Wales, and of taking or holding any preferment therein, and shall cease to enjoy all rights, privileges, advantages, and exemptions attached to the office of cleric in the Church in Wales;

 (b) every licence, office, and place held by him or her for which it is by law an indispensable qualification that the holder thereof should be a cleric of the Church in Wales shall be ipso facto determined and void;

[23]. In essence, the individual is returned to the status of a lay person in the eyes of the Church in Wales with effect from the date of the deposition. A deposition does not call into question the validity and lawfulness of Episcopal actions previously undertaken by a deposed Bishop (such as Confirmations and Ordinations).

The Church in Wales issued a statement which made it clear that when the offences were reported to the church’s safeguarding team in 2023, they were passed directly to police, while the church also immediately began an internal investigation into the background to the case. Proceedings relating to the former Bishop have been covered in a number of posts [6].

Samuel Erlandson – February 2026, Decision; 3pp

On 29 April 2025 the Bishop of St Asaph referred to the Disciplinary Tribunal of the Church in Wales the matter of Reverend Samuel Erlandson, a Clerk in Holy Orders; the grounds for the referral were that Mr Erlandson had, between 19 June 2024 and 22 November 2024, engaged in conduct giving just cause for scandal or offence contrary to Chapter IX, Paragraph 9(c) of the Constitution of the Church in Wales [1].

On 23 November 2024, the Respondent pleaded guilty to 3 offences of possessing indecent images and was sentenced by the Llandudno Magistrates Court to 32 weeks imprisonment, suspended for 18 months together with ancillary requirements; He was placed on the Sex Offenders Register for 10 years [2]. The convictions relate to a period between 19 June 2024 and 22 November 2024 and the making indecent images of children and the possession of extreme pornographic images [3].

The Reference from the Bishop enclosed the relevant certification of conviction from the civil authorities, and under S(4) Chapter IX of the Constitution the preliminary stage of the Tribunal Proceedings was dispensed with and the matter set down for full hearing on 3 November 2025 [4].

On 28 November 2024, the Church issued a Statement which indicated that immediately following his arrest, Mr Erlandson’s permission to officiate as a cleric was removed, prior to consideration by the Church in Wales Disciplinary Tribunal.

In accordance with Rule 31 of the Tribunal’s Rules, a certificate of conviction for a criminal offence from a secular court is treated as conclusive proof that the acts therein specified were committed by the person named in the certificate. The burden on the Proctor is therefore to prove that the conduct set out in the certificate gives just cause for scandal or offence [5]. Following the decision in the matter of the Reverend Clifford Smith Williams, supra, the Provincial Court decided that for an offence alleging just cause for scandal or offence to be proved, the Tribunal must be satisfied of three matters [8]. It had to be satisfied that:

• there was a course of conduct knowingly entered upon by the Respondent;
• the course of conduct must, in the eyes of the Church, be judged to be inherently wrong; and
• the course of conduct must bring such discredit upon the Respondent and the Church that, in the eyes of a person of reasonably robust persuasion, such a person would describe it as scandalous or offensive.

The Panel found find the charge proved [10] and was unanimous that only the most serious sanctions available to the Tribunal would be appropriate in a case of this nature [12].

 Andrew Robinson – February 2026; 3pp

In the case of The Reverend Andrew Robinson, despite his retirement in 2014, the Tribunal retained jurisdiction over him under Section 9 of Chapter IX of the Constitution, because he held a permission to officiate in his retirement, including during the time of the conduct giving rise to the complaint [8].

A Statement from the Church in Wales reported that at the Merthyr Tydfil Magistrates Court, Robinson admitted to offences relating to indecent images of children: 13 cases of possession/making category A images of children: 20 cases of Possession/making category B images of children; 196 cases of Possession/making category C images of children; and 327 cases of Possession/making prohibited images of children.

He was sentenced to a 12 week custodial sentence, suspended for 2 years. He is also subject to a Sexual Harm Prevention order for 2 years. His PTO was immediately withdrawn once police brought their investigation to the attention of the Church in Wales Safeguarding Team in January 2024 prior to consideration by the Church in Wales Disciplinary Tribunal.

Ryan Forey – August 2025. Decision; 12pp

The following summary of the case was posted by 4-5 Gray’s Inn Square, the Chambers of Peter Saville who acted as Proctor for the Church in Wales.

“A monition with conditions for his future ministry was imposed by the tribunal after Mr Forey entered admissions to all charges. The misconduct found by the tribunal included payments of charitable funds to Mr Forey and his household as the chair of charitable trustees of St Teilos Church (Aka “Citizen Church”) Cardiff; the lack of GDPR and safeguarding compliance of an app launched by Citizen Church and championed by Mr Forey, and the formation of a Church outside the Church in Wales whilst Mr Forey was still licensed in his role as vicar of Citizen.

The Judgment is notable for its highly unusual factual matrix in the disciplinary prosecution in the the Ecclesiastical Courts and for including charges brought under paragraph 9(d) of Chapter IX, Paragraph of the Constitution of the Church in Wales – wilful disobedience to or breach of the provisions of the Constitution or of the Statement of Terms of Service published pursuant to the Clergy Terms of Service Canon 2010.”

The determination Disciplinary Tribunal, Church in Wales: Rev Ryan Forey concerns three distinct elements,  Annex B, relating to: financial issues; the management of safeguarding matters; and establishing a church outside the Church in Wales (known as Be Church, Cardiff) and held or accepted the position of pastor without the consent of his Bishop. The Tribunal imposed a monition with a number of conditions that must be satisfied before consideration can be given to putting the Respondent in charge of a church organisation with ultimate responsibility.

Jason Kennett-Orpwood – October 2024, Details of Penalty.

“The Disciplinary Tribunal of the Church in Wales has directed that the Reverend Jason Kennett-Orpwood be deposed from Holy Orders and expelled from the office of Cleric in the Church in Wales, following a hearing on 30 October 2024. Mr Kennett-Orpwood, who has not been in active ministry since 1999, admitted a charge of conduct giving just cause for scandal or offence following a criminal conviction at Llandudno Magistrates’ Court on 2 August 2023”.

“Mae Tribiwnlys Disgyblu’r Eglwys yng Nghymru wedi gorchymyn i’r Parchedig Jason Kennett-Orpwood gael ei ddiarddel o’r Urddau Sanctaidd a’i ddiarddel o swydd  Clerigwr yn yr Eglwys yng Nghymru, yn dilyn gwrandawiad ar 30 Hydref 2024. Fe  wnaeth Mr Kennett-Orpwood, sydd heb fod mewn gweinidogaeth weithredol ers 1999, gyfaddef cyhuddiad o ymddygiad gan roi achos cyfiawn am sgandal neu drosedd yn dilyn euogfarn droseddol yn Llys Ynadon Llandudno ar 2 Awst 2023”.

Further information is on the National Sex Offenders Register (NSOR) here which includes a link to a media report.

Nigel Cahill – August/October 2021. Details of Penalty; 1 page. 

IN THE DISCIPLINARY TRIBUNAL OF THE CHURCH IN WALES: RE THE REVEREND NIGEL CAHILL

Following a hearing which took place on 5 August 2021, the Disciplinary Tribunal of the Church in Wales ordered that the Reverend Nigel Cahill, formerly Rector in the Rectorial Benefice of Aberavon, be deposed from Holy Orders and expelled from the office of Cleric  in the Church in Wales. The Tribunal found a charge of ‘conduct giving just cause for scandal or offence’ proved, following his conviction for two offences of making indecent images of  children contrary to the Protection of Children Act 1978.

11th August 2021

JMH Powell QC

President, Church in Wales Disciplinary Tribunal

NOTIFICATION OF DEPOSITION FROM HOLY ORDERS: RE NIGEL CAHILL

No appeal to the sentence imposed by the Disciplinary Tribunal of the Church in Wales was lodged within the time limits prescribed in the Constitution of the Church in Wales. The Bishop of Llandaff therefore executed a deed deposing Nigel Cahill from Holy Orders on 23 September 2021. The deed of deposition was enrolled in the Registry of the Archbishop of Wales on 4 October 2021.

6th October 2021

M J Chinery

Deputy Registrar to the Archbishop of Wales

Nigel Cahill: Notification of Deposition from Holy Orders

Comment

The Crown Prosecution Office provides guidance, inter alia, on Indecent and Prohibited Images of Children. The offence of making computer-generated indecent images involves creating or distributing images that simulate sexual activity, often involving children or individuals who appear to be children. These images are considered illegal under the Protection of Children Act 1978 and the Criminal Justice and Immigration Act 2008. The law criminalises the possession, distribution, and creation of such images to protect children from exploitation and abuse. Offenders can face severe penalties, including imprisonment, fines, and registration as sex offenders. The legal system prioritizes the safeguarding of children, and prosecuting those involved in the creation, possession, or distribution of such material.

[1] An overview of the term “defrocking” is given by Wikipedia. It is not used Anglican Canon Law, and “laicization” is often, but incorrectly, associated Roman Catholic Canon Law. However, “deposition from Holy Orders” does not make for a snappily-titled headline, and within this post the term “Deposition” will be used.

[2] In his post What’s with all this “defrocking” lingo? Dr Ed Peters comments: “Since the advent of the Johanno-Pauline Code in 1983, the correct phrase to denote the most severe expiatory penalty the Church can impose on a deacon, priest, or bishop is “dismissal from the clerical state” (1983 CIC 1336.1, n. 5). Even the term “laicization”, used for a while after Vatican II to soften the harsh rendering of Latin’s degradatio as “degradation”, is generally avoided today as it seems to imply that the lay state itself is some sort of punishment”.

[3] Anthony Pierce – February 2026, Decision; Samuel Erlandson – February 2026, Decision; Andrew Robinson – February 2026, Decision; Ryan Forey – August 2025. Decision; Jason Kennett-Orpwood – October 2024, Details of Penalty; Nigel Cahill – August/October 2021. Details of Penalty. 

[4] See Thomas Glyn Watkin, Welsh Church Courts and the Rule of Law, Ecclesiastical Law Journal [2000] 5 (27) 460-469. Reference 19 states “As the Welsh bishops are not corporations sole, the case was technically between the Right Reverend Barry Morgan and the Reverend Clifford Williams, [1998] EWCA Civ J1023. It was held, in civil law, that in disciplinary cases, the authority of the courts of the Church in Wales, as a voluntary association, is based on consensual submission to their jurisdiction; they are private bodies and not susceptible to judicial review”. The provincial bodies have no interest other than in providing the judicial mechanisms for its resolution.

[5] Reference (1) of the Decision states: See Halsbury’s Laws of England (1st edition, 1910), Ecclesiastical volume, para 726.

[6] Safeguarding in the Church in Wales: Anthony Pierce, (27 February 2025); Church in Wales statement on Anthony Pierce sentence, (12 March 2025); Anthony Pierce Review published, (26 February 2026); Anthony Pierce, judgment, (17 November 2025).

Revised: 2 May 2026 at 12:18.

Summaries to the four consistory court judgments reviewed during April 2026 are listed below, with links to the L&RUK review. These included[*] Reordering, extensions and other building works, Net zero issues and Churchyards and burials. This monthly review also includes: CDM Decisions and Safeguarding; Privy Council Business; CFCE Determinations; and Links to other posts relating to ecclesiastical law.

An index to these and earlier judgments in here.

Procedural

Reordering, extensions and other building works

• • Substantial reordering
  • Removal and replacement of pews

Substantial reordering

Re St. Andrew Hove [2026] ECC Chi 1 The petition proposed major reordering works at St Andrew Hove, a significant Grade II* listed church. The proposals included replacing pews with chairs, installing kitchen and toilet facilities, improving accessibility, creating office space, introducing solar panels, and undertaking external works[1]. Although unopposed, several heritage bodies (including SPAB, Historic England, and the Victorian Society) raised concerns, particularly about mezzanine structures, internal “pods,” and seating changes[3,4]. The Chancellor applied the Duffield framework, recognising a presumption against change and requiring clear justification for harm to the building’s significance.

He found that, despite some fairly significant harm, the proposals would deliver substantial benefits by improving usability, accessibility, and sustainability, and were the product of careful consultation and revision. However, he was not satisfied that raising the chancel platform to the proposed height was necessary[7]. Accordingly, a faculty was granted subject to revision of the chancel platform height. [Re St. Andrew Hove [2026] ECC Chi 1] [Top of section] [Top of post].

Re St. Andrew Bishopstone [2026] ECC Chi 2 The petition proposed works to St. Andrew Bishopstone, a Grade I listed Saxon-origin church. The proposals involved a north aisle extension to provide a vestry, accessible lavatory, flower area, and a tea point. The Diocesan Advisory Committee and key heritage bodies (including Historic England) supported or did not object, and planning permission had been granted[2]. The Society for the Protection of Ancient Buildings (SPAB) raised concerns about the extension’s location, preferring a detached structure, but acknowledged no ideal alternative existed[3].

Applying the Duffield framework, the Chancellor accepted the proposal would cause some harm to the church’s historic fabric, but found this harm limited and justified by strong pastoral and practical needs. Alternatives had been thoroughly explored and reasonably rejected. The SPAB’s objections were given weight but treated as an outlier among consultees. Accordingly, a faculty was granted. The court also noted concerns about fossil-fuel heating and required the parish to pursue its commitment toward net zero[7]. [Re St. Andrew Bishopstone [2026] ECC Chi 2] [Top of section] [Top of post].

Removal and replacement of pews

Re St. Leonard Grendon Underwood [2026] ECC Oxf 4 The petition from the Grade II* listed church sought approval for the disposal of 35 deteriorating plastic chairs and the purchase 35 additional upholstered stacking chairs matching 25 already in use. Applying the Duffield guidelines, the Chancellor assessed harm to the church’s significance and whether it was justified by public benefit. He found that while removing the plastic chairs was clearly beneficial and caused no harm, introducing more upholstered chairs would cause low to moderate harm to the church’s character and would conflict with Church Buildings Council (CBC) guidance favouring unupholstered wooden seating.

The parish’s arguments (cost, flexibility, lightness, and suitability for mission) were insufficient to justify departing from that guidance, especially as similar benefits could be achieved with compliant alternatives. The existing upholstered chairs, which had been introduced unlawfully, could not set a precedent. The Chancellor granted a faculty for disposal of the plastic chairs, but refused to allow the proposed replacements, unless redesigned in accordance with CBC guidance. The court indicated willingness to approve compliant alternatives and stressed vigilance by archdeacons over unauthorized changes in churches. [Re St. Leonard Grendon Underwood [2026] ECC Oxf 4] [Post] [Top of section] [Top of post].

Net zero issues

See Re St. Andrew Bishopstone.

[Top of post]

Churchyards and burials

• Designation of closed churchyard
• Trees

Designation of closed churchyard

See Privy Council Business.

[Back] [Top]

Trees

Re St. Mary the Virgin Denham [2026] ECC Oxf 5 The petitioners sought to fell a single mature, healthy lime tree in the middle of the churchyard of St. Mary the Virgin, Denham, a Grade I listed church. This stands just to the north of an ancient yew tree  in the old churchyard. The parish want to fell this lime tree, grind out the stump, and re-grass the area. The felling is to be undertaken in the autumn, after the normal nesting season (from March to August), and is expected to take 2-3 days [1].

Buckinghamshire Council, the local planning authority, has considered this proposal and has confirmed that it does not intend to make any tree preservation order in relation to this lime tree. Subject to faculty approval, the parish may therefore carry out the felling, provided this is done within the period of two years before 27 January 2027 [3].

The proposal, which was unopposed, aimed to improve visibility of an ancient yew tree and enhance the aesthetics, biodiversity, and usability of the churchyard [5]. The DAC does not object to the felling of this lime tree, subject to the usual provisos relating to tree works, and to the usual archaeological conditions concerning human remains. The NOA states: “A number of lime trees were planted around the newer section of the graveyard when it was extended and it is one of these which they wish to fell. Although the loss of a healthy tree which will be contributing to the biodiversity, carbon sequestration and visual amenity of the churchyard is not encouraged, there seems to be strong community and congregation support for the proposal and there is no lack of alternative habitat for wildlife in the churchyard”[6].

Citing its recent decision Re All Saints Emberton [2025] ECC Oxf 9 the court emphasised the careful scrutiny that it will give to any application to permit the felling of a mature, healthy tree. This is because this court is mindful of the Fifth Mark of Mission — to safeguard the integrity of God’s marvellous creation. It is for this reason that the court is producing this short written judgment, rather than providing summary reasons for its decision [7].

The Chancellor found that removing the lime tree would cause no harm to the church’s significance or to biodiversity, given the presence of other trees and habitats. The parish had provided a clear and convincing justification, particularly the improved setting and visibility of the ancient yew tree and overall enhancement of the churchyard’s ambience. The Chancellor granted a faculty, subject to conditions including timing outside nesting season, compliance with tree-work standards, archaeological safeguards, consultation on replacement planting, and ecological measures such as retaining some timber for habitat [9]. [Re St. Mary the Virgin Denham [2026] ECC Oxf 5] [Top of section] [Top of page].

Note: the Ancient Yew Group has three categories of yew, according to their age – “notable” (300 to 700 years old); “veteran” (500 to 1200 years old); and “ancient” (at least 800 years old). The overlap between the categories reflects the fact that the age of particular trees is often being reassessed, usually upwards. See Re St. Philip and St. James Whittington [2017] Ecc Wor 1. 

[Top of section] [Top of page].

Privy Council Business

1 April 2026

• Burial Act 1853 (Notice): Order giving notice of the discontinuance of burials in:
• Burial Act 1853 (Final) Order prohibiting further burials in: St Mary’s Church (Annex) Churchyard, Chithurst, West Sussex; St Paul’s Church Churchyard (Extension), Coven, Wolverhampton, West Midlands; All Saints Churchyard, Elsham, Brigg, North Lincolnshire.

CDM Decisions and Safeguarding

Anthony Pierce – February 2026, Decision; Samuel Erlandson – February 2026, Decision; Andrew Robinson – February 2026, Decision; Ryan Forey – August 2025. Decision; Jason Kennett-Orpwood – October 2024, Details of Penalty; Nigel Cahill – August/October 2021. Details of Penalty.

See: “Defrocking” in UK Anglican churches: Church in Wales, (1 May 2026).

CFCE Determinations

The dates of the Cathedrals Fabric Commission for England may be found by scrolling down to the bottom of the page Cathedrals Fabric Commission.  The programme for 2026 is here and the next meeting will be on Thursday 7 May 2026. The last set of published minutes is for the meeting on Thursday 22 October 2025

Links to other posts

Recent summaries of specific issues that have been considered in the consistory courts include:

General/Miscellaneous

• Memorialization of Thomas Corker in Falmouth church (update), (23 April 2026).
• Musical chairs” in Buckingham Archdeaconry, (14 April 2026).

[Top]

Last revised: 30 April 2026 at 13:50.

[*] This is an approximate classification based upon the  main issues considered by the court. Determinations relating to reordering and building works will often address other aspects of the Petition.

Notes on the conventions used for the navigation between cases reviewed in this post are summarized here.

Pleased to post below a link to the Mattone Center’s annual review for 2025-2026. Among the highlights: media productions, including podcasts and a video series on landmark cases in religious freedom; events, including international conferences and moot courts; and faculty scholarship. Thanks to everyone who has supported our activities–looking forward to next year!

https://t.e2ma.net/webview/imanfk/e675ed3ee68b1bd00f92234f8db7e2b3

The post 2025-2026 Year in Review appeared first on LAW AND RELIGION FORUM.

Background

In R v Skinner [2026] EWCR 4, Mr Skinner was a devout Christian strongly opposed to abortion. He sent two identical letters, attached to e-mails, to Temporary Inspector Fern Graham of the Dorset Police and to the Office of the Dorset Police and Crime Commissioner (which was opened by a female office administrator) headed “Reporting mass murder in Ophir Road” – a reference to the British Pregnancy Advisory Service’s clinic in Ophir Road, Bournemouth, which offers pregnancy termination. The letters included what were said to be photographs of aborted foetuses and comments about “brutal killings taking place in Bournemouth” and “terror and torture” suffered by foetuses in the process of termination [1-4]. (He also sent them to the Chief Constable and to local councillors, but those were not the subject of a criminal complaint [7].) He was convicted in respect of the e-mails to Inspector Graham and the Police and Crime Commissioner for improper use of the public electronic communications network, contrary to s.127(1) of the Communications Act 2003 [9 & 10]. He appealed.

The law

Saini J noted that the Divisional Court had recently set out the scope of s.127(1) and its interaction with the ECHR at para [111] of Cobban & Anor v Director of Public Prosecutions [2024] EWHC 1908 (Admin) at [12]. In summary [17]:

‘(1) The object of section 127(1)(a) is to prohibit the use of a service provided and funded by the public for the benefit of the public for the transmission of communications which contravene the basic standards of our society. It is the use of the public network which is the core of the offence;

 (2) Whether a message sent over an electronic communications network is “grossly offensive” within section 127(1)(a) is a question of fact to be answered objectively by reference to its contents and context, and not its actual effect. In determining whether a message is “grossly offensive” the tribunal of fact must ask whether its contents are liable to cause gross offence to those to whom it relates, or whether reasonable persons in our society would find it grossly offensive. That test requires the application of the standards of an open, just, multiracial and multifaith society;

(3) There is binding authority in the form of R v Collins [2006] UKHL 40 to the effect that the ingredients of the offence under section 127(1)(a) are as follows:

1. The actus reus of the offence comprises three elements, namely: (a) sending a message; (b) of the proscribed “grossly offensive” character; and (c) by way of a public electronic communications network. Provided that all three elements are proved, the actus reus is complete at the time of the sending. It makes no difference whether the relevant message is received or read;

2. As regards the mens rea of the offence, the defendant must have intended his message to be grossly offensive to those to whom it related, or be aware that it may be taken to be so;

(4) However, before a defendant can be convicted for sending a message prosecuted under this section, the court must also be satisfied that the conviction is a proportionate interference with such Convention rights as apply.’

The judgment

It was common ground that Mr Skinner had sent the letters over a public communications network for the purposes of section 127(1); the issue was whether the communications were “grossly offensive” and whether the mens rea had been proved [18].

The Court was not satisfied that the conviction was a proportionate interference with Mr Skinner’s Convention right to freedom of speech under Article 10 [34]:

• The views expressed in the letters, as supported by the images, were political speech entitled to the highest form of protection. The abortion debate raised important matters of public interest where strong views were legitimately held and expressed, often in forceful terms, by persons on each side of the argument and ‘great caution is required before a state can restrict the expression of political standpoints’ [35];
• An individual had the right to use images as a form of speech in a way which would shock and offend ‘and indeed it is of often the power of an image which carries the message in its strongest terms’ [36]; and
• The intended recipients of the letters were public officials. Inspector Fern could be expected to have ‘a higher tolerance as a police official’, and Mr Skinner had no way of knowing that anyone other than the Police and Crime Commissioner would open the correspondence, which was marked for his attention [37].

The Court was in no doubt that those who viewed the Images had found them deeply distressing, but they were ‘part and parcel of a debate on an important matter of public interest, where there are strongly held views both for and against abortion’ [41]. Appeal allowed [42].

New Safeguarding Authority Design Consultation 

We are seeking feedback on the design of a proposed new safeguarding organisation. The consultation is now open and will run until 11pm on 17th May 2026. 

In a joint message for the consultation, the Independent Executive Chair, Dame Christine Ryan, and the Deputy Lead Bishop for Safeguarding, Bishop Joanne Grenfell, write:

“Following General Synod’s overwhelming support for our strategic plans to rebuild trust and deliver professional, independent safeguarding across the Church, the work to translate that vision into a detailed, structured programme of change is well underway.

“At the heart of these reforms is the creation of a new national safeguarding organisation that will operate independently of Church hierarchy, governed by a majority-independent Board. This consultation seeks your views on the detailed design of this organisation, referred to in the consultation as the “Authority”.

“Whether you are a survivor, a parish volunteer, a safeguarding professional, a Church officer, or a member of the wider public, your perspective will help us refine these proposals. Your feedback and viewpoints are essential and will help ensure the proposals are robust, sustainable, and fit for purpose.”

How to take part

Everyone is welcome to submit a response via the online form linked below, and all of the information you need to respond can be found in the Explanatory Document which explains in more detail the design proposals on which we are seeking feedback and views.

A Privacy Notice has been prepared for the purposes of this consultation, linked below.

• Explanatory Document
• Online consultation form
• Consultation Privacy Notice

Upcoming information briefings

To support engagement with the consultation process, the Safeguarding Structures Reform programme team has scheduled a number of information briefings. The goal of the briefings is to ensure everyone who wishes to submit a response has the clarity they need to engage fully with the consultation exercise. However, you do not need to attend a briefing in order to respond.

Contact the team

If you have any questions regarding the consultation exercise or the process, please contact the Safeguarding Structures Reform team safestructures@churchofengland.org.

With thanks to Thinking Anglicans for alerting us to this consultation exercise; also the Church Times article(£) Safeguarding body consults on new national organisation which gives further background information.

As regular readers will know, preventing a lawful and decent burial of a dead body is an offence at common law in England and Wales and in Northern Ireland, and there have been a few serious recent examples of convictions. Robert Bush, of Legacy Independent Funeral Directors in Hull, is currently awaiting sentencing after admitting to hoarding 30 bodies and a significant quantity of human ashes and to running his business fraudulently. In February, Richard Elkin and Hayley Bell, who ran Elkin and Bell Funerals in Gosport, Hampshire, were jailed for four years after keeping 46 bodies in unrefrigerated conditions.

In 2020, the Competition and Markets Authority recommended establishing an inspection and registration body to monitor funeral directors’ standards of transportation and care for the dead, alongside measures to increase price transparency for funerals (which, I suspect, might have been the CMA’s principal concern). The result of the recent convictions has been to renewed calls for the regulation of funeral directors, and the Chief Executive of the National Association of Funeral Directors, which subjects its members to unannounced inspections and sets guidelines for handling bodies, has voiced support for regulation.

It now appears that regulation might be in the offing. Last week, the BBC reported that the Secretary of State for Health and Social Care, Wes Streeting, had taken the matter on board; he is quoted as saying:

“We will be taking a lead in the Department of Health and Social Care of working across government to make sure we’ve got effective funeral legislation in place.”

Whether it will be through targeted legislation or by including it in a broader health policy bill remains to be seen, and I suspect there will be a consultation before any final policy announcements are made.

As to the related issue of offences against dead bodies, in answer to a question in the House of Lords on 22 April, the Parliamentary Under-Secretary of State at the MoJ, Baroness Levitt, noted that there is a separate Law Commission project looking at offences against the deceased, and that the Government

“will consider all the recommendations issued recently by the Law Commission and the various workstreams to see what is the most practical approach to publishing our response, including timing, to make sure that we do not do things piecemeal in a way that, in the end, makes things worse rather than better.”

Yet more watching this space…

.

The external sign was swiftly removed and the incident reported to the police. An anonymous spokesperson for the community group stated “[w]e installed the blue sign to coincide with the enthronement of the new Bishop of Truro – the Rt Revd David Williams, and to appeal to him to proactively address the harm the Falmouth Slave Trader Memorial continues to cause.” It appears as though this community group was also the instigator of the earlier brass plaque.

On Saturday 18 April 2026, the Falmouth Packet reported that a small group of protesters (and “a significant police presence”) gathered outside King Charles the Martyr Church during the installation of its new parish priest. The service formally welcomed the Rev Dr Adam Dunning to the church and was attended by a large congregation. Despite the demonstration outside, proceedings inside went ahead without disruption.

The following joint statement issued by the Diocese and the Church summarized the earlier Heritage Impact Report, Monument of Thomas Corker[2], and said:

“The Diocese of Truro and King Charles the Martyr Church continue to work with Black  Voices Cornwall and local historians; and have sought funding from the Racial Justice unit of the national church to progress the agreed work on the Thomas Corker Memorial as previously shared.

Whilst the PCC voted to remove the monument, there continues to be no viable storage facility. Therefore, an interim plan was developed. This involves contextualising the monument in situ.  A content warning will be displayed, along with opportunities for visitors and those unable to enter the building to provide feedback.  Opportunities for education and training are being sought during this period.

 “The new Rector of Falmouth, The Reverend Dr Adam Dunning, is fully committed to working with all parties concerned about the future of the Corker memorial. He will be seeking an outcome that is equitable, appropriate and healing for all of us who feel strongly about the injustice, evil and sin which the memorial represents.”

There is nothing that can repay the damage the transatlantic slave trade caused, and we have to acknowledge that. We now need to find a different way to tell the truth about the past and pay attention to injustice in the present.

[1] At the time of writing, the brass plaque features in a photograph on the TripAdvisor Falmouth page, which suggests that the Slave Trader Memorial is the second most popular historical site in Falmouth, Pendennis Castle being the first.

[2] The 39-page report, (March 2025), was written by Dr Alice Kinghorn whose specialist area of research is the Church of England’s involvement in African chattel enslavement. The four Chapters cover: Motivation for Change and Summary of Actions so Far; The Church in its Environment; Thomas Corker and the Corker Memorial in Context; Current Proposal – Relocating the Memorial in an Educational Setting. 

It makes the suggestion that the memorial could be relocated to the rear of the church in an exhibition and educational space, using a freestanding display case to offer longevity to the decision (and to eliminate the need to remove multiple monuments). This report, in conjunction with the Monument Condition Assessment, illustrates that the Corker memorial is ‘truncated’, and has likely been moved within the church before, and thus any negative heritage impact on KCM is less significant.

With thanks to Rebecca Evans, Diocese of Truro, for the provision of material.

In this episode of Legal Spirits, I speak with Andrea Pin about his new book, Dignity in Judgment, and the role of human dignity in contemporary constitutional law. We explore competing understandings of dignity—a secular, autonomy-based view and a more communal conception influenced by religious traditions—and consider how courts choose between them. Along the way, we discuss why the secular view appears to dominate in practice and how judicial formation shapes the meaning of dignity in constitutional adjudication.

The post Legal Spirits 077: Dignity in Judgment appeared first on LAW AND RELIGION FORUM.

Here are some important law-and-religion news stories from around the web:

• Bishop James Massa, chairman of the U.S. Conference of Catholic Bishops’ Committee on Doctrine, responded to Vice President Vance’s recent criticism of Pope Leo XIV’s Palm Sunday Homily, emphasizing that “When Pope Leo XIV speaks as supreme pastor of the universal Church, he is not merely offering opinions on theology, he is preaching the Gospel and exercising his ministry as the Vicar of Christ.”
• This week, the Justice Department Office of Legal Policy’s Weaponization Working Group published a 37-page report which concluded, in part, that “the Biden DOJ ‘engaged in biased enforcement of the FACE Act’ and ‘pursued more severe charges and significantly harsher sentences for peaceful pro-life defendants than violent pro-abortion defendants.'”
• In a press release following the final hearing of the President’s Religious Liberty Commission, Chairman Dan Patrick rejected the notion that the First Amendment requires a total separation of church and state.
• Ohio Attorney General David Yost has filed suit seeking to prevent Hebrew Union College (HUC) from closing its 150-year-old Cincinnati rabbinical school.
• The Dominican Sisters of Hawthorne and Rosary Hill Home, a hospice care facility in New York, filed suit in a New York federal district court challenging New York’s requirements for care of transgender patients.
• On April 14th, a settlement was reached between the Coast Guard and three Coast Guard members who had brought a class action after they were denied religious exemptions from the military’s COVID vaccine mandate. Among other things, the Agreement requires the Coast Guard to remove references in personnel records of service members’ decision to remain unvaccinated.

The post Around the Web appeared first on LAW AND RELIGION FORUM.

From which point, events went further downhill for the “Christian Nationalism” of the Republicans. On which we make no comment other than to refer readers to Harold Macmillan’s dictum: “There are three bodies no sensible man directly challenges: the Roman Catholic Church, the Brigade of Guards and the National Union of Mineworkers”.

Lord High Commissioner to the General Assembly

On Wednesday, the Government announced that the King has approved the reappointment of Lady Elish Angiolini LT DBE KC as HM’s Lord High Commissioner to the General Assembly of the Church of Scotland.

Places of Worship Renewal Fund: England

In answer to an Oral Question from Peter Prinsley (Bury St Edmunds and Stowmarket, Lab), the Second Church Estates Commissioner, Marsha De Cordova, said this:

“The new places of worship renewal fund will be managed by Historic England on behalf of the Department for Culture, Media and Sport. The fund totals £92 million over four years and will support capital repairs to listed places of worship. Priority will be given to buildings in areas of high deprivation or community need. Applications are expected to start with an expression of interest, followed by a full application, with efforts made to minimise administrative burdens on smaller parishes…

… We are still waiting for the Government to publish more detail on this vital scheme. As I said in my meeting with the Minister, I urge the Government to get on and publish that detail at pace so that we can give our churches certainty” [emphasis added].

And so does everyone else.

Places of Worship Renewal Fund: Northern Ireland

In answer to a Written Question from Robert Swann (South Antrim, UUP) asking how much funding has been allocated through the Places of Worship Renewal Fund to places of worship in Northern Ireland, Ian Murray, Minister of State at DCMS, said this:

“The Places of Worship Renewal Fund is England only as Heritage is a devolved policy area. The Northern Ireland Government received Barnett consequentials at the Spending Review, taking into account any changes to DCMS’ overall settlement. It is for the Northern Ireland government to consider whether to set up new arrangements should they so wish.

We are working closely with other funders in the sector to ensure that opportunities for funding places of worship throughout the UK are maximised. The National Lottery Heritage Fund already offers grants for places of worship across all the UK and is currently investing £100m over 3 years through National Lottery Heritage Grants and a strategic initiative designed to provide targeted support to build capacity.”

In other words, “Ask the Northern Ireland Executive”.

Same-sex marriage and the Church in Wales

On Thursday, the Governing Body of the Church in Wales voted to make permanent its liturgy for the blessing of same-sex marriages and civil partnerships, which had been trialled for the past five years, by incorporating it into the Church’s Book of Common Prayer.

The voting on the motion, which required a two-thirds majority, was Bishops, unanimous, Clergy 32-7, with 5 abstentions, and Laity 48-8, with 2 abstentions.

Assisted dying: Isle of Man

On 17 April 2026, Manx Radio reported “UK Government ‘unable to recommend Assisted Dying Bill for Royal Assent’ at this time“. Tynwald became the first parliament in the British Isles to pass assisted dying legislation, approving the Bill in March 2025. As a Crown Dependency, for primary legislation on the Isle of Man to get Royal Assent and therefore become law, the Lord Chancellor, David Lammy, is required to make a recommendation that it should do so.

The Ministry of Justice had sought clarity on the arrangements for monitoring assisted deaths, safeguards against coercion and ensuring that individuals have capacity to make decisions. It says that while the Manx Government provided comprehensive assurances and commitments that would mitigate the legal risk significantly, these do not form part of the bill. It is therefore the UK Government’s view that these matters must be addressed in order for the bill to comply with the European Convention on Human Rights.

While the Ministry is unable to recommend the bill for Royal Assent at this time, it says that this should not be interpreted as disallowing Royal Assent, but rather reflects the need to ensure that the legislation contains the necessary protections.

St George’s Day, 23 April

In an article in the Church Times, Martyn Snow, Bishop of Leicester, said that English churches should fly the flag of St George and the patron saint’s day used to foster a healthy kind of patriotism. Various urban myths have developed about the flying of flags from churches, which is unsurprising given the lack of consistency in the available advice. This was reviewed in our post Flags and flagpoles: Church of England (2022), which notes that the CofE ChurchCare (2021) states that “The Earl Marshal’s Warrant (of 1938) had the approval of the Archbishops of the day, but it does not make it compulsory for the flag to be flown. Unfortunately, other extant CofE guidance is contradictory.

Bitesize Ecclesiastical Law

 Upcoming sessions in the Ecclesiastical Law Society series:

• Bitesize Ecclesiastical Law #15 on “What is an Archbishop?” with Louise Connacher, Registrar of the Province and Diocese of York and the Diocese of Sodor and Man, 21 April, 5.30-6.00 pm.
• Bitesize Ecclesiastical Law #16 “What is a licence?” with Kirsty Duxbury, Diocesan Registrar, Anthony Collins Solicitors, 12 May, 5.30-6.00 pm.
• Bitesize Ecclesiastical Law #17 “What is the General Synod?” with Jenny Jacobs, Clerk to the Synod, 16 June 5.30-6.00 pm.

And finally…

Our LLM colleague and friend, Bishop Paul Colton, of Cork, Cloyne and Ross, is formally retiring this weekend. In 2025, he said that his last public service in the diocese would be on Saturday, 18 April 2026, at which time he would lay down his crozier in Saint Fin Barre’s Cathedral, Cork. The twenty–seventh anniversary of Paul’s election was on 25 March 2026, when he embarked on his twenty–eighth year. a longer tenure as Church of Ireland Bishop of Cork, Cloyne and Ross than anyone else since the first Reformation bishop died in 1617, and the second longest ever. For several years he has been the longest-serving Anglican diocesan bishop still in office in Great Britain and Ireland.

The Bill, which follows a period of reflection and listening across the Church, seeks to make this provision permanent. If approved, it would provide an authorised liturgical form for such services within the Church’s Prayer Book.

On 16 April 2026, the Governing Body voted to make permanent provision for same-sex blessings. The announcement is reproduced below.

Church in Wales Governing Body votes to make permanent provision for same-sex blessings

Provincial news Posted: 16 April 2026

The Church in Wales Governing Body has today voted to make permanent provision for church blessings for couples in same-sex Civil Marriages and Civil Partnerships.

Five years ago, after deciding that it was “pastorally unsustainable” for the Church to make no formal provision for those in committed same-sex relationships. the Governing Body approved a service of blessing for an experimental five-year period, which is due to come to an end in September this year.

Yesterday and today, at its meeting in Llandudno, the Governing Body debated a motion to make the provision permanent by incorporating a rite for the blessing of same-sex marriages and partnerships into the Book of Common Prayer.

The measure needed a two thirds majority of each of the Orders which comprise the Governing Body: Bishops, Clergy and Laity.  All five Bishops voted in favour. The clergy voted 32 – 7 in favour, with 5 abstentions, and the laity 48 – 8 in favour, with 2 abstentions.

You can read the proposed liturgy here, and the amendments proposed by members of the Governing Body here.

The Church in Wales does still not have provision to marry same-sex couples. However, in November 2025, after several months of careful listening exercises, the Bishops of the Church issued a pastoral letter noting that the process had shown a majority “in favour of the view that the time is right to offer equal marriage.”

Further proposals will duly be brought forward in April 2027 to allow the law of the state and of the Church to be changed to permit equal marriage in the Church in Wales.

Speaking about today’s vote, the Most Revd Cherry Vann, Archbishop of Wales, said: “I want to thank everyone for the ways in which this debate was conducted – calmly, and with mutual respect. The Bench of Bishops and I recognise that this is an issue about which people hold strong convictions. We want everybody to be able to hold their views with integrity whilst not losing sight of the image of God that resides in all of us. We want to build a church that can make space for each other whatever our different perspectives.”

The discussion and vote was held on the second day of the Governing Body meeting at Venue Cymru in Llandudno. The livestream is available to watch online here.

Materials

Report of the Select Committee on the Bill to Incorporate into the Book of Common Prayer An Order of Service of Blessing following a Civil Partnership or Marriage of Two People of the Same Sex, (March 2026).

The Governing Body of the Church in Wales is meeting at Venue Cymru, Llandudno, on April 15 and 16. Today, 15 April 2026, the following notice was issued.

Vacancy in the See of Bangor

The Electoral College is reviewing expressions of interest and will meet from 16-18 June 2026 at Holy Trinity Church, Llandudno to elect the next Bishop of Bangor.

Documents relating to the vacancy are available here:

• Diocesan profile
• Provincial statement

If you wish to be considered for this role, or wish to suggest a person for consideration, please contact the Secretary to the Electoral College by email at electoralcollege@churchinwales.org.uk.

The closing date for expressions of interest and suggestions is 12pm on Wednesday 29 April 2026.

Human dignity is ubiquitous in contemporary constitutional law, yet its meaning varies across jurisdictions and even among judges. In a new essay at Emory’s Canopy Forum, I review my friend Andrea Pin’s new book, Dignity in Judgment, which challenges the conventional view that dignity is solely a secular, autonomy-based concept and highlights its religious and communal roots. While I agree with Andrea that dignity has multiple intellectual sources, I argue that courts today overwhelmingly rely on a secular understanding in practice. This convergence, I suggest, reflects the intellectual formation and shared legal culture of judges, who interpret dignity through familiar frameworks shaped by modern constitutionalism.

I’ll be interviewing Andrea about his book in an upcoming Legal Spirits podcast, so please stay tuned! Meanwhle, you can read the full review here.

The post Dignity and the Judges appeared first on LAW AND RELIGION FORUM.

As far as the parish could ascertain, the chair purchase [of the 25 existing upholstered chairs] did not have faculty permission (apparently because of the erroneous belief that this was unnecessary since  the chairs are not fixed to any part of the fabric of the church). Some old, plastic, bucket chairs are stored in a shed in the church grounds and are brought out for larger weddings, funerals, and services, such as the Crib Service at Christmas. With a view to disposing of them, the parish submitted a grant application to fund the purchase of additional chairs of the type they already have. A grant was awarded by the Diocesan Development Fund to purchase the additional chairs, and it was intended that these would be stored, either in the vestry or at the rear of the church, when not in use[14].

The parish is working on a project to improve the use of the Edwardian vestry which requires the parish to empty the shed of the plastic chairs, and to move stored items from the vestry into the shed. The parish would be able to store the newly purchased chairs in the vestry, and also to make use of them to facilitate the conversion of the vestry into a space for meetings and small groups…This work depends upon being able to dispose of the old plastic chairs, and to create space within the shed[15].

In his Analysis and Conclusions [22] to [38], Hodge Ch. noted that the parish had provided a clear and convincing justification for the disposal of the 35 existing plastic, bucket chairs which were in various states of disrepair and desperately needed to be replaced. The CBC was clearly right in its view that the replacement of these chairs would be beneficial to the historic character of the church building: “they should never have been introduced into this church in the first place. They are wholly unsuitable for a Grade II* listed, historic church building” [24].

He unhesitatingly granted a faculty for their disposal. However,

“[25]. …the real question on this petition was what should replace these bucket chairs: Should the parish be permitted to introduce more of the existing, upholstered, stackable chairs, further reinforcing their presence within this church, contrary to CBC guidance? Or should they be replaced (if at all) with a new style of chair which conforms to such guidance?”

[26]. In answering this question, the court must recognise that it cannot compel the removal of the existing chairs. Although they were introduced into the church unlawfully, this was more than a decade ago; and the time has long elapsed since the court could make any restoration order requiring their removal: see s. 72(5) of the Ecclesiastical Jurisdiction and Care of Churches Measure 2018. This case demonstrates the need for the archdeacon, when conducting his regular visitation of each church within the archdeaconry, to be vigilant about identifying any changes that have been made to the church’s fabric and contents since the last visitation, and inquiring as to the nature of any requisite lawful authority for such change…

[…]

[29]. I find that there is a degree of tension in the CBC’s approach, which is not easy to reconcile with the petition that is actually before the court. The CBC has an understandable wish to see a single style of chair introduced into this historic church, so as to give the interior a unified appearance. However, the parish are not seeking, by this petition, any authority to dispose of their 25 existing upholstered, stackable chairs. Thus, the adoption of a single style of chair would seem to involve the acceptance of upholstered seating, contrary to the CBC’s published guidance, and the CBC’s strong suggestion that the parish should consider an alternative replacement chair in line with that guidance.

[31]. I confess that at times my mind has wavered about the outcome of this petition. However, I have reached the clear conclusion that I should refuse the petitioner’s request to replace the 35 plastic bucket chairs with an additional 35 stacking chairs, of the same design as the 25 existing chairs which have been used in the church since 2013 or thereabouts. My reasons are as follows.

[32]. First, I am satisfied that the presence of the existing chairs has caused a degree of harm to the significance of this fine, medieval village church as a Grade II* listed building of special architectural and historic interest. The introduction of any significant number of additional chairs of the same design and style would add to that degree of harm. The parish’s choice of chair departs from the CBC’s published guidance on seating in churches. That guidance is a matter of substance, and not mere form […]

[33]. Second, the burden rests on the petitioners to demonstrate a sufficiently good reason for introducing these particular chairs into this listed church building[…] I agree with the DAC that the parish have provided no clear or convincing justification for the limited harm that would be caused by the introduction of their preferred design and style of chair[…]

[35]. Third…I am satisfied that the same, or substantially the same, benefits could be obtained by the introduction of another form of seating which would cause less harm to the character and special significance of this Grade II* listed historic church building.

[36]. Fourth, I appreciate that the point can be made that, strictly, any new seating will not form a permanent addition to the fabric of this church building. But that is to ignore the realities of the position. If the quality and design of the existing 25 chairs is permitted to dictate, or even to influence, the form of any new seating, similar considerations will apply when any future decision comes to be made about the replacement of the existing 25 chairs.

Since they will be 13 years older than the new chairs, it is likely that they will need to be replaced first. The likelihood is that it will then be said that their replacements should replicate the quality, and design, of the remaining chairs. These chairs will therefore become permanently embedded within this church, perpetuating the inappropriate quality and design of the existing seating for future generations. It is at this point that the second of the principal reasons provided by the DAC for refusing to recommend the parish’s new seating proposal becomes of relevance. The existing, upholstered chairs in the church were never authorised under faculty, and so they cannot provide any precedent for the introduction of additional, unsuitable matching chairs.

[37]. For all these reasons, I find that the petitioners have not discharged the burden that rests upon them of demonstrating a sufficiently good reason for introducing these particular chairs into this listed church building…Whilst I will grant a faculty for the disposal of all 35 plastic, bucket chairs, I refuse to grant a faculty for the purchase of an additional 35 stacking chairs of the same design as the church’s 25 existing, upholstered chairs.

[38].  Should the parish wish to amend their petition so as to seek a faculty for the purchase of up to 35 additional stackable chairs of a quality and design that complies with the CBC guidance note on church seating, then I would be prepared to dispense with the display of any further public notices (since no objections were formally raised to the parish’s present, and more drastic, seating proposal) and to grant such a faculty…

Comment

The CBC Guidance Note Seating is here, which was issued by the Church Buildings Council under S55(1)(d) of the Dioceses, Mission and Pastoral Measure 2007.

Here are some important law-and-religion news stories from around the web:

• Vice President J.D. Vance spoke regarding growing tension between the U.S. military and religious leaders and the pushback against current US military operations in Iran.
• In Perry v. Marteney, the 4th Circuit Court of Appeals upheld a law in West Virginia that required vaccinations for public school students without religious exemptions.
• in Singh v. Second Judicial District Court of the State of Nevada, a case regarding the transfer of a Sikh Temple into a trust, the court held that the ‘neutral principles exception’ to the ecclesiastical abstention doctrine can apply outside of church property cases.
• In Maniar v. Noem, a D.C. District Court dismissed a suit brought by a Pakistani-American couple who claimed that being placed on a Screening List at the airport violated their free exercise rights.
• In Johnson v. Fleming a Virginia federal district court dismissed Free Exercise claims regarding religious exclusions from a state tuition program.

The post Around the Web appeared first on LAW AND RELIGION FORUM.

Places of Worship Renewal Fund: update

Historic England, which will be administering the scheme in England, has published a notice about the new Places of Worship Renewal Fund in which it says that “Detailed guidance, including the remit of the fund and all eligibility criteria, is currently being prepared and will be published here in due course. This will include information on how to apply”. In other words, continue watching this space.

Terrorism (Protection of Premises) Act 2025: implementation

On Tuesday, the Chief Executive of the Security Industry Authority (SIA), Michelle Russell, issued a statement marking the one-year anniversary of Royal Assent to the Act. The statement says that, over the past year, the SIA has worked closely with the Home Office and other partners on the preparatory foundations that need to be in place before it is “able to create a regulatory function that is credible and effective”. In the coming year, the SIA will be issuing its statutory guidance, recruiting staff, and building a dedicated online notification portal for premises and events to use.

(The statement begins, “One year ago today, the Terrorism (Protection of Premises) Act 2025 known as Martyn’s Law…” – to which the only reply can be “No: it’s known as the Terrorism (Protection of Premises) Act 2025”.)

Woman charged over baptism death

The Crown Prosecution Service reports that a woman has been charged with gross negligence manslaughter following a baptism ceremony in Birmingham in 2023 in which the man being baptised drowned. Malcolm McHaffie, Head of the CPS Special Crime Division, said:

“We have decided to prosecute Cheryl Bartley, 48, with one count of gross negligence manslaughter in relation to her role as a pastor during a baptism. She will appear at Birmingham Magistrates’ Court on Thursday, 14 May 2026.”

West Midlands Police cautioned:

“We remind all concerned that criminal proceedings against this defendant are active and that she has the right to a fair trial. It is vital that there should be no reporting, commentary or sharing of information online which could in any way prejudice these proceedings.”

Artificial Stupidity strikes again

In Your Home Partners v Kellichan and Another [2026] SC KDY 34, the claimants sought an order from the Kirkcaldy Sheriff Court requiring the respondents to pay £5,000 in rent arrears [1]. Sheriff MacRitchie initially rejected the claim on the grounds that it was a matter for the First-tier Tribunal (Housing and Property Chamber) [3].

Zilch to do with “religion”: the interest for this blog is that the claimants then made further submissions disputing the point about jurisdiction, arguing that it was indeed a matter for the Sheriff Court and lodging various decided cases in support of their contention, together with what they said were extracts from the “Small Claims (Scotland) Rules – Section 41a” and the “Interest on Debts (Scotland) Act 1985 – Section 1”.

The problem with that submission, however, as Sheriff MacRitchie pointed out at [13], was that the alleged Rules and Act “simply do not exist”. To which the claimants replied that

“they had obtained these case references and the purported statutes and relative statutory extracts using online Artificial Intelligence in good faith, and that they had not knowingly lodged these references to non-existent decisions, rules and a statute” [17].

Luckily for them, His Lordship decided that, on balance, it was cock-up rather than conspiracy and that he would not initiate proceedings for contempt of court [22].

Further comment by us would be otiose, but Elaine Elder and Hannah Campbell discuss the decision more fully in Scottish Legal News, here.

Chapels Wales Project

Working in partnership with denominations, congregations, heritage organisations, and local communities, the Capeli Cymru project has been established to develop innovative and practical strategies to safeguard chapel heritage across Wales. A  national chapel survey has been designed to map “active, closed, and converted chapels across Wales, capturing data on their sustainability, architectural value, and status of nationally protected assets”. Links are here (general public) and here, (congregation members).

Quick links

• Bernard Capp, The Conversation: Hands off my hat! The hidden power of headwear and ‘hatiquette’ in early modern England: well worth a read, but we couldn’t help thinking that nominative determinism is alive and well…
• The Church Times reports, rather belatedly, on the conference of BPUR International at the House of Commons on 26 March, sponsored by the UK All-Party Parliamentary Group for Freedom of Religion or Belief, which issued a “Westminster Declaration on Preventing the Political Abuse of Religion”.
  

And finally…I

Wikipedia includes a dynamic listing of common initialisms relating to LGBTQ (lesbian, gay, bisexual, transgender, and queer) people and the LGBTQ community. Currently absent from the list is MMIWG2SLGBTQQIA+, the recent use of which by Canadian MP Leah Gazan (Winnipeg Centre, NDP) “has sparked a frenzy online” (Newsweek, 9 April 2026). The acronym stands for: Missing and Murdered Indigenous Women, Girls, and Two‑Spirit, Lesbian, Gay, Bisexual, Transgender, Queer, Questioning, Intersex, and Asexual people.

The Newsweek article states, “the full acronym has been used for years in Canadian government, advocacy, and community contexts to emphasise intersectionality, and is intentionally lengthy in order to name everyone who has historically been left out of national conversations about violence, justice, and safety”.

And finally…II

A Copilot search on the organisation Westminster Declaration, stated [emphasis added]:

“… is a title that has been used for two quite different documents in recent years. Your question most likely refers to the 2023 Westminster Declaration, a high‑profile international statement on free speech and censorship. But there is also a 2025 Westminster Declaration rooted in Christian public ethics. Both matter, but they serve very different constituencies and purposes“…

This exercise proved instructive: for users of AI, the importance of human interpretation of the results of AI and the value in seeking out the original source documents; and for “think-tanks” and others seeking to influence debate, the year-on-year use of a strapline or title may lead to confusion unless qualified. The belated response of the Church Times is perhaps understandable.

L&RUK analysis

• ChatGPT, Copilot, and L&RUK, (8 April 2026).
• AI and L&RUK readership, (2 April 2026).
• A further examination of AI in legal blogging, (26 March 2026).
• A brief experiment in legal blogging using AI, (23 January 2023).
• Legal research, blogging and AI, (22 January 2023).

L&RUK use of AI

• Westminster Declaration, (12 April 2026).
• Artificial Stupidity strikes again, (12 April 2026).

Other Examples

• OUP: Author use of Artificial Intelligence (AI), (6 April 2026).
• Judicial Appointments Committee, (29 March 2026).
• Law Commission: AI and the Law A Discussion Paper, (July 2025).
• European Commission: Regulation 2024/1689, Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008.
• Might a computer algorithm replace the ECtHR? (23 January 2017).

Last updated: 20 April 2026 at 16:17. 19:48.

Since A brief experiment in legal blogging using AI in 2023, a number of aspects of Artificial Intelligence (AI) have been explored on L&RUK. Recently, A further examination of AI in legal blogging looked at developments in the use of AI in sourcing to material for use on this blog, and AI and L&RUK readership considered referrals to the blog from search engines, visitors and other referral bodies (websites, AI &c).

For the present post, we asked both Copilot and to ChatGTP to provide an answer to the question: To what extent do search engines identify Law and Religion UK as a source of information (on law and religion)?[1]. The responses were followed up by additional considerations on the future role of AI in “specialist blogs”[2].

Copilot

Copilot states that search engines determine the “authority” of a blog through a mix of indexing, backlinks, citations, and topical relevance. It notes that L&RUK is fully indexed and is treated as a legitimate information source; the site is crawled and indexed by search engines, with posts appearing in search results for UK law‑and‑religion topics. Its listing in curated legal directories, such as Access to Law, signals reliability to search engines. Furthermore, its cataloguing by the IALS Digital Resources collection is considered to be “a strong academic endorsement”.

Copilot observes the importance of these inclusions – “search engines use such curated references as quality signals. [L&RUK] is recognised as a specialist, authoritative niche blog“. This reinforced the blog’s authority within its domain, even if it is not a general‑purpose news source. The areas in which search engines tend to identify Law & Religion UK are: ecclesiastical law; religion‑law interactions; burial/cremation law; church governance; human rights issues involving religion. However, it is not treated like a mainstream news outlet, so it will not appear for broad legal or political queries.

Furthermore, “[i]ts authors’ reputations strengthen its search credibility. Search engines factor in author expertise. The site’s main contributors…are recognized in academic and professional contexts, which boosts perceived trustworthiness”. In summary, L&RUK is deemed to have high authority within its niche, with search engines treating it as a reputable, expert‑driven source for UK law‑and‑religion issues.

ChatGPT

The response from ChatGPT was similar to that from Copilot, although it did identify additional specific issues. It noted that the available evidence suggested search engines were the dominant pathway through which users reach Law & Religion UK, (as  noted in in our earlier post), but this did not necessarily mean that the site was strongly “identified” or branded as a primary authority by those engines in the same way as major academic publishers or institutional databases.

However, it demonstrates that search engines consistently identify the site in response to user queries, making them the primary mechanism of discovery. There are two different senses of “identification”:

(a) Technical discoverability — High. Search engines are:

• clearly index a large volume of the blog’s content;
• routinely return the site in search results; and
• drive the overwhelming majority of visits.

Importantly, “this suggests strong SEO visibility and topical relevance, especially for niche queries in UK law-and-religion issues”.

(b) Authority recognition — Moderate / niche. The same evidence also indicated:

• The blog functions as a specialist, issue-driven resource, often accessed via specific queries rather than brand searches;
• Its readership is heavily UK-based (~85%), reinforcing its jurisdiction-specific niche;
• It is classified externally (e.g. by the Institute of Advanced Legal Studies) as a blog resource rather than a formal academic database or journal.

This implies that search engines are likely to treat it as a relevant expert blog for particular topics although not necessarily as a canonical authority such as Westlaw, LexisNexis, or major journals. Interestingly, on the nature of its search visibility, the pattern of usage suggests that:

• Users often arrive via long-tail or issue-specific searches (e.g. case law, ecclesiastical law topics);
• Older posts continue to receive traffic, indicating persistent indexing and retrieval across time.

Thus, “search engines are not just identifying the homepage—they are deep-indexing individual posts as answers to specific legal-religious queries”. Support for this observation has been the recent spike in page-reads of the post on the offence of Preventing lawful and decent burial, 11 March 2024, prompted by the case of Robert Bush, funeral director at Legacy Independent Funeral Directors in Hull, (which we referred to on 19 October 2025).

There has also been a continuing interest in the 2017 post on scattering Ian Brady’s ashes, which appears to have been prompted by uncertainties in the funeral arrangements for Ian Huntley, (the analysis of which we have not covered). However, the same interest does not appear to have been shown in case of the exhumation of Dr David Kelly, the former Iraq weapons inspector who took his own life near his home in Longworth, Oxfordshire, in 2003.

ChatGPT’s overall assessment is that “To a very great extent, search engines identify and surface Law & Religion UK as a source of information—indeed, they are its primary gateway for users. This identification is “strong in visibility and retrieval (high discoverability)” although “[m]ore limited in terms of perceived authority or brand prominence (niche authority rather than dominant source)”.

Future role of AI in L&RUK

At its present state of development, the strength of AI lies in its ability to access and synthesize existing material, and rephrase a wide range available knowledge; in contrast, specialist blogs can give added value through insights which not easily replicated: original analysis; first-hand experience (e.g. interpretation of recent judgments or new/prospective legislation, or commentary on emerging or ambiguous situations.

Furthermore, specialist blogs located at the interface of two disciplines, such as law and religion, occupy a specific niche which it is difficult to replicate, at present. However, this advantage may narrow over time with further developments in AI and its increasing use by experts with “hybrid applications” of AI and expert use becoming common.

It is widely acknowledged that there has been a rapid expansion in the rate of development and use of AI technology. Within the EU, Regulation 2024/1689, adopted on 13 June 2024, established a comprehensive legal framework for artificial intelligence within the European Community. In July 2025, the Law Commission published the discussion paper AI and the law, in which it considers the nature of AI, how might AI issues arise, and the need for clarification on the fundamental issue of legal personality.

The emergence and development of Artificial Intelligence (AI), and Generative AI (Gen AI) in particular, have created both opportunities and challenges for authors, researchers, and publishers. Oxford University Press (OUP) and other publishers have formulated guidelines on the responsible, appropriate, and transparent use of Gen AI by authors and editors in its research publishing.

Whilst AI has the potential of summarizing lengthy judgments &c, or exploring areas for which we have limited expertise, the material so generated is unlikely to be used in the absence of references/links to primary sources. To date, the direct use of AI by L&RUK has been limited and this is clearly identifiable from the context of the text; however, it is possible that indirectly, the many referrals to the site via search engines will have been influenced by the search engine’s own AI.

[1] …noting that “Copilot…gives a response more tailored to a user working with Microsoft 365 (i.e. dp) and their perceived areas of interest”.

[2] A “specialist blog” is a blog that focuses on a specific niche, topic, or area of expertise, rather than covering a wide range of general subjects. Key features are: Narrow focus: It concentrates on one subject; Expert-level content: Posts are often more detailed, informed, and targeted toward people interested in that field; Defined audience: It attracts readers who share a particular interest or need; Authority building: The goal is often to become a trusted source.

Background

In 2011, the authorities investigated a man, K.A, for allegedly distributing pornographic material and violating privacy after he published intimate photos involving a well-known actress, A.S – an incident that sparked widespread public debate about the balance between protecting private life and regulating pornographic content [5]. There was intense media coverage, including unconfirmed speculation that A.S. belonged to Armenia’s biggest “sect”: Word of Life [6]. The newspaper Iravunk Hetaqnnutyun then published an article linking the scandal to Word of Life, claiming that A.S. was a member and accusing her of serious misconduct and alleging “that she had engaged in lewd acts with her own child” [6]. It also stated that Word of Life was a “sectarian union”, and that it exerted influence in certain circles involving television companies and public officials [6]. A similar article appeared shortly after in another newspaper, reinforcing these claims and suggesting that the Word of Life promoted questionable values. A.S. publicly denied ever being affiliated with the organisation [8], but despite that, further publications continued to target the applicants, using inflammatory language and encouraging public opposition to them. Finally, in November 2011, the applicants sued Iravunk Media Ltd, the publisher of the Iravunk Hetaqnnutyun and Argumenti Nedeli v Armenii newspapers, for defamation [10].

In July 2012, the District Court dismissed the claims, ruling that the publications had not contained defamatory or insulting statements and that were protected by the publisher’s right to freedom of expression, which allowed journalists to use exaggerated and provocative language. Further, the applicants had failed to prove defamatory intent on the part of the respondent. The District Court held in particular

“… that the articles and images were published only after the scandalous events involving the actress [A.S.], in which her name was linked to the [applicant] organisation, which was regarded as a sectarian organisation and was subjected to criticism. From the moment [the applicants] entered the arena of open public debate they needed to show a certain amount of tolerance towards criticism, which, taken as a whole, has [had] the nature of an open debate pursuing the aim of instilling society with certain religious ideas or of [preventing it from] deviating from the religious beliefs of the Armenian Apostolic Church, rather than the aim of insulting or defaming someone” [16].

On 8 November 2012, the Civil Court of Appeal dismissed their appeal and upheld the judgment of the District Court. As regards the applicants’ complaints about the use of the word “sect”, the Court of Appeal stated, in particular:

“… having examined the arguments raised in the appeal regarding the word ‘sect’ and its interpretations, ;;; even in their appeal the [applicants] did not deny the fact that their activity deviated from the beliefs of the Armenian Apostolic Church” [15].

In December 2012, the applicants appealed to the Court of Cassation but, in doing so, confused the dates of the two judgments, and in January 2013, the Court declared the appeal inadmissible on the ground that the judgment of the District Court was not amenable to appeal in cassation proceedings. In February 2013, the applicants resubmitted their appeal of December 2012, having amended the last paragraph to refer to the correct decision – that of the Civil Court of Appeal on 8 November 2012 – but the second application was ruled inadmissible as out of time [19-22].

Before the Fifth Section, the applicants contended that the Court of Cassation’s decision to declare their appeal on points of law inadmissible had breached their right of access to a court as provided in Article 6 ECHR [28] and that the District Court had violated the State’s duty of neutrality and impartiality in religious matters, contrary to Article 9, because of certain findings that it had reached when assessing the use of the words “sect” and “sectarian” in the newspaper articles [40].

The judgment

On the first ground, the Fifth Section held that the Court of Cassation must have known that the wording of the concluding part of the applicants’ appeal was the result of a typographical error or some similar oversight, and though it could have given the applicants an opportunity to correct their mistake it had chosen not to do so without giving any reasoning for its choice and had declared the appeal inadmissible without giving the applicants any further chance to remedy the situation. As a result of the Court of Cassation’s strict application of the procedural rules, their appeal on points of law was not examined on the merits [37]. Though the limitation applied by the Court of Cassation pursued the legitimate aim of ensuring the proper administration of justice, it had demonstrated “excessive formalism” by applying the rules in a particularly strict manner that disproportionately and unjustifiably restricted the applicants’ right of access to the court [38]. There had therefore been a violation of Article 6 § 1 [39].

As to the second ground, the Fifth Section said that its judgment was concerned solely with the applicants’ complaint that,

“… when performing the balancing exercise between the competing rights, the District Court itself committed certain acts which breached the guarantees of Article 9 … in particular, … the District Court’s finding that their religious activity deviated from the belief system of the Armenian Apostolic Church, the dominant church in Armenia, and that consequently it was acceptable to call the applicant organisation a ‘sect'”

and that, by doing so, the District Court had assessed the legitimacy of their faith and thereby breached the State’s duty of neutrality and impartiality in religious matters under Article 9 [51].

The Court reiterated that, provided that religious or philosophical views attained a certain level of cogency, seriousness, cohesion and importance, the State’s duty of neutrality and impartiality was ‘incompatible with any power on the State’s part to assess the legitimacy of religious beliefs or the ways in which those beliefs are expressed’ [52]. While the Court had no reason to doubt that the applicants’ beliefs passed that threshold, the domestic courts had not been in breach of their duties under Article 9;

“… it cannot be said that the domestic courts interfered with the applicants’ Article 9 rights. It is notable that the domestic courts did not themselves use the word “sect” in respect of the applicant organisation, or characterise it as such. Nor did the scope of their examination ever embrace any issue concerning the legitimacy of the applicants’ faith … the Court cannot agree with the applicants’ argument that, by stating that their religious beliefs differed from those of the Armenian Apostolic Church, the domestic courts delved into an assessment of the legitimacy of the applicants’ faith. In sum, no issue arises under Article 9 with respect to the complaint concerning the alleged breach of the State’s duty of neutrality and impartiality, as argued by the applicants” [53].

In brief, there had been a violation of Article 6, but there had been no violation of Article 9.

The Guardian reports that Robert Bush, funeral director at Legacy Independent Funeral Directors in Hull, has admitted giving families the wrong ashes, lying to them, stealing from them and stealing from charities. He pleaded guilty at Hull Crown Court to 30 counts of preventing a lawful and decent burial, and one of theft from twelve charities, including the Salvation Army and Macmillan Cancer Support, after 30 bodies and a quantity of ashes were found at the funeral home in 2024.

He had previously pleaded guilty to dozens of counts of fraud at a hearing in October and had been charged with 67 offences in total. He was granted bail pending a pre-sentence report, but Hilliard J said that “everybody accepts a custodial sentence is inevitable in this case”.

The Institute of Cemetery and Crematorium Management renewed its call for statutory regulation of the funeral industry in England and Wales where, unlike in Scotland, there is currently no universal system of inspection or enforcement across the industry. As we have previously noted, in October 2024 a statutory inquiry chaired by Sir Jonathan Michael recommended that the Government “should establish an independent statutory regulatory regime for funeral directors in England as a matter of urgency in order to safeguard the security and dignity of the deceased”.

Disclosure and Barring Service: faith groups

The Disclosure and Barring Service (DBS) is expanding its Faith in Safeguarding campaign nationally to raise awareness of the legal duty to refer – the process that organisations must follow by law when there are safeguarding concerns about individuals in regulated activity. According to the DBS, faith organisations are currently among the lower-referring sectors for barring referrals, and it suspects that many faith organisations may be unaware of their legal obligations under the Safeguarding Vulnerable Groups Act 2006. It is currently running a series of free, in-person pop-up clinics across England, offering practical guidance tailored to faith settings. Further details here.

Consultation on amending the Charities Act (Northern Ireland) 2008

The Northern Ireland Department for Communities has opened a consultation on amending the Charities Act (Northern Ireland) 2008. The consultation document, which includes a draft Bill, is the result of a review of the operation of the 2008 Act carried out in 2021. In the meantime, the Department held a separate consultation on the advisability of repealing the uncommenced section 167 of the Act (which would require institutions which are not charities under the law of Northern Ireland but which operate for charitable purposes in or from Northern Ireland to register there), and concluded that its repeal would avoid duplication of regulatory oversight and the imposition of disproportionate burdens on charities.

This latest consultation looks at:

• broadening the bodies with whom the Charity Commission for Northern Ireland can share information to include “persons discharging functions of a public nature”;
• the possibility of giving the Commission, and possibly its officials, an official warning power;
• expanding the scope of the power to remove trustees to include those trustees who have resigned from office;
• giving the Commission the power to issue directions to trustees not to undertake certain actions;
• extending automatic disqualification as a trustee following an inquiry to cover employment in such roles as an officer, agent or employee of a charity;
• changes to the requirement to prepare accounts;
• relaxing the audit/independent examination requirement for small charities; and
• “template reporting”.

The consultation closes on 24 April.

Quick links

• Thérèse Rankin, Bates Wells: Could withdrawing a job offer because of an applicant’s social media posts be discriminatory? Lessons from Ngole v Touchstone Leeds.

And a Happy Easter to all our readers!

In this short take, Mark Movsesian looks at the Supreme Court’s 8-1 decision this week in Chiles v. Salazar, involving a Christian therapist who challenged Colorado’s ban on so-called conversion therapy for minors. Formally, Chiles is not a free exercise case. But religion is clearly in the background—a reminder that law-and-religion controversies are often worked out through the First Amendment’s speech protections. Listen in!

The post Legal Spirits 076: A Short Take on Chiles v. Salazar appeared first on LAW AND RELIGION FORUM.

Background

WordPress provides its users with information on site traffic through a number of pre-set options[1] including: “Last 7 Days”; “Last 30 Days”; “Last 12 Months”; “Last 3 Years”. It also has details for: “Today”; “Month to date”; and “Year to Date”, which are useful in tracking the development of specific issues, but are of less value for comparative purposes. With L&RUK’s worldwide readership, the “Today” results are influenced by the time zone and different responses over the 24 hour period post-publication.

Likewise ” *** to date” information is of limited value when seeking comparisons on due to possible variations in the length of the time period chosen. Consequently, this present analysis uses information for the “Last 7 Days”; “Last 30 Days”; “Last 12 Months”; and “Last 3 Years”.

Referrals

“Referrals” are made to the blog from two distinct sources: from search engines[2] and through other web links[3]. Search engines are associated with 26.8% to 37.8% of the total number of page views, and of these, the majority are from either Google, (82.34% to 86.28%) with a significant, but smaller number from Bing, (10.4% to 14.0%). Of the remaining referrals through other links, the majority are either from X, or Facebook, with very few via ChatGPT[4].

There are also ~1,160 subscribers who receive email notification of each new post as it is published, although these are not identified separately.

Location

In the context of the blog’s strapline “Issues of law and religion in the United Kingdom – with occasional forays further afield”, it is hardly surprising thar the majority of readers are from the UK. There were 79.5% over the past three years, falling to 68.9% over the 12 months period when there was a significant readership in the the United States (17.1%)  and China (12.5%). Recent UK readership is 71.41% (30d) and 71.69% (7d)[5].

Comment

Search Engines play a significant part in identifying L&RUK to potential users, and as noted earlier, they now rely on AI at almost every stage of the search process—from understanding the query, to ranking results, to generating summaries. Thus whilst the general trend of an increased use of AI is not reflected directly in the above analysis, there is likely to be an indirect effect though the Search Engine searches.

[1] A bespoke option is also available.

[2] Google; Bing; Duck Duck Go; Yahoo; ecosia; and others.

[3] X; Gmail; ChatGPT; Facebook; Inner Temple; Thinking Anglicans; Beaker Folk of Husborne Crawley; Edgepilot; Notebook; and others.  

[4] X, 1.05% to 6.46%; Gmail, 0.91% to 1.87%; ChatGPT, 0.28% to 1.1%; and Facebook, 0.7% to 3.28%.

[5] However, comparing the subject matter of “top ten” posts for this 12 month period, there appeared to be little that would be of specific interest on China or the US.

Update: 4 April 2026 at 14:22. See Comments, below, on information from Copilot: viz. “The spike in 2026 Chinese page‑reads is almost certainly caused by AI‑related automated traffic—crawlers, LLM training systems, or AI‑driven referrals—rather than a sudden surge of human readers in China”.

Comment

The above posts are listed in descending order of number of page-views. These results are appear to be atypical, possibly a consequence of fewer percentage of page reads from the UK, and the greater percentage of the total page views in the “top ten” posts, supra. The following general observations may be made:

• Parochial Fees are a regular feature, and are based upon the Consumer Prices Index (CPI) for August which is reported by ONS in September, and eventually announced by the Church of England in December.
• Two of the above posts relate to events which, to us, were clearly “non-starters”: the substantial increase in burial fees; and the “poisoned chalice” appointment of an interim Bishop to the Diocese of Bangor, (not literally, obvs).
• There was significant opposition to an increase in burial fees, and General Synod voted overwhelmingly against the proposal. Whilst the proposal for an Interim Bishop of Bangor was prima facie a logical approach to the current impasse, the tightly drawn requirements and the associated circumstances militated again the appointment.
• Continuing interest in the post on the scattering of Ian Brady’s ashes appears to have been generated by the death of Ian Huntley at the maximum security HMP Frankland. After a trial at the Old Bailey in 2003, he was jailed for life with a recommended minimum term of 40 years for the “Soham murders”. However, apart from a passing reference to a Sun newspaper headline in February 2013, we have not covered the Soham case, although many of the principles related to the funeral arrangements (possession of the body, the need for secrecy) were similar.

[1]  i.e. those other than the “Home Page”, “Archives”, and “Index”. However, for the present analysis, these categories did not fall within the “top 10”.

[2] 20% for January to April in 2025 and ~12% for posts from 1 August 2024 to 4 July 2025.

Updated: 1 April 2026 at 13:28..

Summaries to the nine consistory court judgments reviewed during March are listed below, with links to the L&RUK review. These included [*]:

• Procedural
• Reordering, extensions and other building works
• Exhumation
• Churchyards and burials

This monthly review also includes: CDM Decisions and Safeguarding; Reports from the Independent Reviewer; Privy Council Business; Other legal issues; Visitations; CFCE Determinations; and Links to other posts relating to ecclesiastical law.

An index to these and earlier judgments in here.

Procedural

Re St. Gabriel Toxteth [2026] ECC Liv 1 The Parochial Church Council wished to enter into a lease/hire agreement with the Ethiopian Orthodox Teklehaymanot Church (EOTC), which had already been using the church for worship and community events, with a view to eventual purchase by EOTC at a cost of £175,000. The arrangement formed part of a broader diocesan reorganisation under the “Fit for Mission” initiative, which merged the parishes of St Gabriel’s and St Cleopas due to declining congregations and the higher maintenance costs of St Gabriel’s [5].

Several former members of St Gabriel’s congregation and local residents objected, arguing that the church had not been properly closed under the Mission and Pastoral Measure 2011 and criticising the transparency of the decision-making process. Some expressed concern that the agreement would effectively end Anglican use of the building [6] to [13].

The Chancellor held that these objections related to parish reorganisation and potential closure—matters outside the faculty jurisdiction [16]. His role was limited to considering the effect of the proposed agreement on the church building’s heritage and proper use. As the hire agreement posed no risk to the building’s fabric or heritage and would place the current occupation on a proper legal footing, the faculty was granted. [Re St. Gabriel Toxteth [2026] ECC Liv 1] [top of section] [top]

Reordering, extensions and other building works

• Substantial reordering
• Removal and replacement of pews

[top]

Substantial reordering

Re St. Thomas Stourbridge [2026] ECC Wor 1 The faculty petition proposed a major reordering of St Thomas’ Church, Stourbridge, a Grade I listed Georgian church designated as a diocesan “renewal church” supported by national mission funding. The proposals included removal of most 18th-century box pews, installation of new flooring, heating, lighting, audio-visual facilities, a servery, flexible seating, and relocation (not removal) of the font. Applying the Duffield framework, the Chancellor found that removing the historic pews would cause serious harm to the building’s architectural and historic significance, given their rarity and integral role in the Georgian interior. However, the court accepted clear and convincing justification: the reordering was necessary to achieve liturgical flexibility, accessibility (especially for wheelchair users), and expanded community and missional use essential to the church’s long-term viability. Alternatives involving only partial pew removal would not meet these needs. The public benefits—sustaining an active worshipping community and securing the building’s future—were held to outweigh the heritage harm. Most works were therefore permitted, subject to detailed conditions (including retention of eight pews, preservation of graffiti, reuse of materials, and DAC approval of final specifications). Permission to remove and replace the font was refused, but relocation within the church was allowed. [Re St. Thomas Stourbridge [2026] ECC Wor 1] [Top of section] [Top of post].

Re St. John Knotty Ash [2025] ECC Liv 3 There was an unopposed faculty petition for reordering works at St. John the Evangelist, Knotty Ash, a Grade II listed church. The proposals—supported by the DAC, PCC, and congregation—aimed to improve accessibility and inclusivity, particularly for children and neurodiverse individuals. Key changes included: creating a sensory space in an existing meeting room; relocating and expanding the children’s area into the north aisle by repositioning (not removing) pews; and installing movable TV screens with live-feed capability to improve visibility and sound access. These responded to identified barriers such as poor audio clarity, limited visibility, and lack of inclusive space. Applying the Duffield framework, the Deputy Chancellor found that the proposals would cause negligible harm to the church’s architectural or historic significance. The works were reversible, did not affect key historic features, and preserved the interior’s character. He concluded that the significant public benefits—enhanced accessibility, participation, and mission—clearly outweighed any minimal impact. As funding was secured and justification strong, the faculty was granted. [Re St. John Knotty Ash [2025] ECC Liv 3] [Top of section] [Top of post].

Re St. Paul Wooburn [2026] ECC Oxf 3 The petitioners sought permission to remove 31 Victorian nave pews installed during William Butterfield’s 1856–57 restoration, replace them with 150 stackable “Icon 40” chairs, and dispose of various surplus twentieth-century furnishings (including a metal altar rail, kneelers, lectern, and a Lady Altar). The Victorian Society objected in consultation, arguing that the pews formed part of Butterfield’s significant ensemble of furnishings and that their removal would harm the building’s architectural integrity. Historic England and the Diocesan Advisory Committee supported the proposal, considering the pews relatively undistinguished and accepting the parish’s case that flexible seating was needed for worship, mission, accessibility, and community activities. Applying the Duffield guidelines for listed churches, the Chancellor held that removing most pews would cause moderate but not serious harm to the church’s significance. However, the parish had demonstrated a clear and convincing justification: flexible space would better support worship, events, and mission. Alternatives such as shortening or moving pews were rejected as impractical. Balancing harm against public benefit, the Chancellor granted the faculty, subject to conditions regarding disposal of the Lady Altar and consultation about retaining some pews around the church perimeter. [Re St. Paul Wooburn [2026] ECC Oxf 3] [Top of section] [Top of post]

Re St. Thomas Stanhope [2026] ECC Dur 1 The Parochial Church Council sought approval to make the church more flexible, accessible, and suitable for worship, community use, and visitors. Key proposals included removing most pews and replacing them with stackable chairs, installing storage cabinets and improved heating, creating a curved dais with a lift at the east end of the nave, adding an access ramp at the south porch, and altering the positions or use of three fonts[4,5].

Eighteen objections were received, mainly opposing pew removal, font changes, cost, and concerns about altering the church’s character [14]. One objector was resident in London and moved away from Stanhope as long ago as 1964. Isles Ch. was not satisfied that this person is an ‘interested person’ within the meaning of rule 10.1 of the Faculty Jurisdiction Rules 2015 (‘the Rules’), but in any event she raises nothing new that is not covered by some of the other objectors.

An objection was from Stanhope Parish Council which alleged that Councillors believed there had been very little consultation on the proposed plans, and in particular the Parish Council had not been consulted. However, the PCC response indicated that this assertion was untrue; the PCC had held a public meeting so that the proposals could be discussed, and some members of the Parish Council were present. Furthermore, the Chancellor noted that under the Rules there is no obligation on the PCC to consult the Parish Council [15].

Heritage bodies largely supported the scheme, noting the pews had relatively low historical significance and that the proposals balanced heritage with contemporary needs.

Applying the legal test for works affecting listed churches, i.e. the familiar principles and questions set out by the Court of Arches in the case of Re St Alkmund, Duffield 2013 Fam 158, and Re St John the Baptist, Penshurst (2015), the Chancellor found that removing the pews would cause only low harm, outweighed by benefits such as flexibility, accessibility, and mission opportunities. Some proposals were modified: the Frosterley marble font must remain in place with its cover, the Crawleyside font must remain inside the church, and the Saxon font may be made movable. [Re St. Thomas Stanhope [2026] ECC Dur 1] [Post] [Top of section] [Top of post].

Exhumation

• Other

Other

Re Newbold Verdon Cemetery [2026] ECC Lei 1 The Chancellor granted a faculty permitting the exhumation of Derek Harold Wilkinson’s cremated remains from Newbold Verdon Cemetery so that they could be reinterred with those of his late wife, Rosemary Wilkinson, in the same grave. Mr Wilkinson was buried in 2019 in his parents’ grave with his wife’s consent.

After Mrs Wilkinson’s death in 2025, their son discovered a 2016 signed letter expressing his parents’ joint wish that their cremated remains be kept until they could be reunited and interred together in the cemetery’s Garden of Remembrance [4]. The court accepted that Mrs Wilkinson’s early dementia at the time of her husband’s burial may explain why those wishes were not followed.

Applying Re Blagdon Cemetery and In re Christ Church, Alsager, Gyane Ch. held that the combination of the couple’s clear prior written wishes, Mrs Wilkinson’s cognitive decline, prompt action upon discovery of the letter, unanimous family support, and the limited disturbance involved constituted exceptional circumstances justifying departure from the presumption of permanence in Christian burial. [Re Newbold Verdon Cemetery [2026] ECC Lei 1] [Top of section] [Top of post].

Re Ormskirk Parish Churchyard [2026] ECC Liv 2 Mr and Mrs Newsome petitioned for a faculty permitting the exhumation of their son Adam’s remains, buried in 2007 at Ormskirk Parish Churchyard, and re-interment in West Lancashire Cemetery[9]. Adam died aged 19 after suffering from cancer. The petitioners argued that the churchyard environment had deteriorated. They reported antisocial behaviour, drug paraphernalia, and intimidation from groups of youths, which made visiting the grave distressing and unsafe. They also described maintenance issues, including a sunken and waterlogged grave, and wished ultimately to be buried together with their son in a new family plot elsewhere.

The Chancellor applied the established principles governing exhumation, particularly those in Re Blagdon Cemetery and Re Christchurch Alsager, which emphasise the presumption of permanence of Christian burial and require exceptional circumstances to justify exhumation[12]. Although expressing sympathy for the family, the Chancellor held that distress caused by antisocial behaviour or dissatisfaction with the churchyard environment does not constitute exceptional circumstances.

Granting the petition could create a precedent for similar applications. Accordingly, the petition for exhumation was refused, though the court suggested that improvements to churchyard management might address the concerns raised[16]. [Re Ormskirk Parish Churchyard [2026] ECC Liv 2] [Top of section] [Top of post].

Churchyards and burials

• Development of churchyard
• Designation of closed churchyard
• Churchyard Regulations

Development of churchyard

Re Malmesbury Abbey [2026] ECC Bri 1 The Deputy Chancellor granted a faculty to authorise the digging of five trial investigation pits within the curtilage of Malmesbury Abbey, to inform improvements to the churchyard, including the proposed erection of a statue to commemorate King Athelstan, who is believed to be buried within the Abbey. [Re Malmesbury Abbey [2026] ECC Bri 1] [Top of section] [Top of post]

Designation of closed churchyard

See Privy Council Business.

[Back] [Top]

Churchyard Regulations

Re Tolleshunt Knights Cemetery [2026] ECC Chd 1 The petitioner, the daughter and an executor of her late father, wished to erect a memorial to her father in the churchyard[2]. The memorial had already been manufactured without prior approval and did not fully comply with diocesan churchyard regulations. Although the shape of the memorial was a technical departure from the regulations, the Chancellor regarded this as a minor issue that would not, by itself, have prevented permission being granted.

The principal difficulty arose from an objection by the petitioner’s mother to the inscription, specifically the phrase “A dear husband,” which she contended did not reflect the deceased’s own manner of expression.

The Petitioner indicated that she has taken legal advice, and has been told, incorrectly, that she and her brother have the “right”, as their father’s executors, to decide on the inscription on his gravestone[8]. The Chancellor emphasised that executors have no legal right to determine the design of a memorial in consecrated ground; any memorial requires ecclesiastical permission.

The Chancellor exercised her discretion, noting family disagreement, the absence of malice by the petitioner, the fact that the wording was not intrinsically objectionable, and that the stone had already been made, making replacement wasteful and costly. Balancing these factors, she granted the faculty and allowed the memorial to be installed. [Re Tolleshunt Knights Cemetery [2026] ECC Chd 1] [Top of section] [Top of post].

Fonts

See Re St. Thomas Stourbridge.

Privy Council Business

12 March 2026

• Burial Act 1853 (Notice) An Order giving notice of the discontinuance of burials in St Peters Churchyard, Clayworth, Retford, Nottinghamshire.

CDM Decisions and Safeguarding

CDM Decisions

Re: the Most Revd & Right Hon Sarah Mullally, Archbishop of Canterbury (February 2026) Review Decision pursuant to section 13(3); President’s Decision on Publication (March 2026).

Church in Wales

Details of any decisions or sentences of the Disciplinary Tribunal of the Church in Wales, where the President of the Tribunal has ordered that details be published on the Church in Wales website.

• Anthony Pierce – February 2026. Decision (3pp, and reported here).
• Samuel Erlandson – February 2026. Decision (3pp).
• Andrew Robinson – February 2026. Decision (3pp).
• Ryan Forey – August 2025. Decision (12 pp, reported here).
• Jason Kennett-Orpwood – October 2024. Details of Penalty (2 paras in E, W).
• Nigel Cahill – August/October 2021. Details of Penalty (2 paras in E, W).

Reports from the Independent Reviewer

Individual Reports from the Independent Reviewer are to be found at House of Bishops’ Declaration on the Ministry of Bishops and Priests (Independent Reviewer), scroll down.

CFCE Determinations

The dates of the Cathedrals Fabric Commission for England may be found by scrolling down to the bottom of the page Cathedrals Fabric Commission.  The programme for 2026 is here and the next meeting will be on Thursday 7 May 2026.

The last published minutes are for Thursday 22 October 2025.

Links to other posts

Recent summaries of specific issues that have been considered in the consistory courts include:

General/Miscellaneous

• Law Commission report on reform of burial and cremation law, (20 March 2026).
• Regulating the funerals industry?, (11 March 2026).
• “Defrocking” in the Church of England, (9 March 2026).
• Deposition of a Bishop from Holy Orders, (2 March 2026).

[Top]

Updated: 31 March 2026 at 08:49.

[*] This is an approximate classification based upon the  main issues considered by the court. Determinations relating to reordering and building works will often address other aspects of the Petition.

Notes on the conventions used for the navigation between cases reviewed in this post are summarized here.

Here are some important law-and-religion news stories from around the web:

• The Supreme Court revived a lawsuit by a Mississippi street preacher who claims that his arrest for demonstrating near an amphitheater violated his free speech and religious liberty rights. 
• A federal judge ordered immigration officials to allow clergy and religious workers access to detained migrants in Minneapolis, ruling that denying pastoral visits likely violated religious liberty protections. 
• The United States Conference of Catholic Bishops filed amicus briefs with the Supreme Court arguing that turning away migrants at the border is unlawful and inconsistent with the nation’s moral obligations. 
• Members of Congress introduced legislation that would protect the tax-exempt status of churches and religious organizations from being revoked based on their views or speech. 
• India’s Maharashtra legislature passed a new anti-conversion law this week requiring advance notice before religious conversions and imposing criminal penalties for conversions obtained through coercion, fraud, or marriage. The law has drawn criticism from religious minority groups.

The post Around the Web appeared first on LAW AND RELIGION FORUM.

In R (CKS & Ors) v Secretary of State for Education [2026] EWHC 741, the claimants were three children (their parents acting as litigation friends) who were members of the Charedi Jewish community and attended private Charedi schools. They challenged the Department of Education’s Universal Infant Free School Meals policy (“UIFSM”), which requires state-funded schools to provide a free school meal to all state-funded school pupils in Reception and Key Stage 1 without any means test – but does not apply to pupils in private schools [1 & 2].

The arguments 

The grounds of challenge were as follows [3]:

• that the refusal was discriminatory on grounds of the claimants’ religion or race, contrary to Article 14 ECHR read with Articles 8, 9 and A2P1 (Ground 1),
• that it breached the Public Sector Equality Duty in s.149 Equality Act 2010 (Ground 2), and
• that it failed adequately and rationally to take into account the position of Charedi children (Ground 3).

The claimants argued that the principle in Thlimennos v Greece 34369/97 [2000] ECHR 162 was engaged, that:

“The right not to be discriminated against in the enjoyment of the rights guaranteed under the Convention is also violated when States without an objective and reasonable justification fail to treat differently persons whose situations are significantly different” [38],

and that they were in a “relevantly different” position from other private school pupils and should not be treated in the same way [137], largely because the Charedi community experienced high levels of economic deprivation.

The judgment

All grounds of challenge were rejected. While Mansfield J accepted that there was clear evidence demonstrating the deprivation of the Charedi community and that it was is in a different financial position from most other families who used private schools,

“… deprivation is not itself an aspect of race or religion. The simple fact that Charedi children are treated differently to other private school pupils does not indicate discriminatory treatment on grounds of race or religion” [137].

If he had accepted that the claimants had no choice but to attend an independent school, “then the relevant comparator for Thlimmenos purposes would be private school children who do have the choice to attend state schools” and “there was simply no evidence as to the composition of the comparator group” [137].

As to the alleged breach of the Public Sector Equality Duty, “there were powerful reasons to continue to provide UIFSM only to state-funded schools” [150].

As to Ground 3, the Minister had been

“… entitled to regard Charedi parents as exercising a choice and entitled to have regard to that choice in making her decision about the request to extend UIFSM. There was no flaw in the Defendant’s reasoning. It was not irrational of the Defendant to have taken that view” [152].

Application dismissed [154].

Overseas marriages

On Tuesday, in answer to a written question from Richard Holden (Basildon and Billericay, Con) asking the Secretary of State for Justice, if he will make it his policy not to recognise overseas marriages that would be illegal under UK law, Jake Richards, Parliamentary Under-Secretary of State at the MoJ, said this:

”There are no plans to change the law that an overseas marriage is normally recognised in England and Wales if it complied with the requirements for the form of the ceremony where it took place (meaning by whom, where, when and how it was conducted) and if both parties had capacity to marry according to the law of their domicile.”

One cannot help wondering what occasioned the question in the first place.

Finland, religion, free speech and homosexuality

The Helsinki Times reports that, by three votes to two, the Supreme Court of Finland has convicted and fined Päivi Räsänen, a Christian Democrat member of the Finnish Parliament, and Juhana Pohjola, a bishop of the small Evangelical Lutheran Mission Diocese of Finland, for hate speech. The charge related to a pamphlet published by the Mission Diocese that described homosexuality as a disorder in psychosexual development and rejected the view that it was a natural variation of human sexuality. The judgment requires the removal of specific passages, but allows the rest of the pamphlet to remain available.

According to the report, the Court said the case did not centre on religious confession and found that the disputed passages reflected social and medical claims rather than expressions tied to religious doctrine, adding that freedom of religion did not protect statements unrelated to religion when assessing criminal liability. However, Ms Räsänen was cleared of charges linked to a social media post in which she cited the Bible.

EU Special Envoy for Freedom of Religion or Belief

Mairead McGuinness, a former European Commissioner for financial services and Fine Gael’s candidate in Ireland’s 2025 presidential election, has been appointed EU Special Envoy for the Promotion of Freedom of Religion or Belief outside the EU.

Assisted dying claims debunked

A summary of posts on X headed Prue Leith’s Assisted Dying Claims Debunked by Lords Records commented:

“Leith accused Archbishop Sarah Mullally and six others of filibustering the Terminally Ill Adults (End of Life) Bill, but Mullally tabled zero amendments and the changes came from over 50 peers. The bill, which passed the Commons in June 2025 by 315-291, lets terminally ill adults in England and Wales request aid to end their lives under safeguards like dual doctor approval. Now in its 11th committee day, supporters call delays a filibuster while opponents stress vital scrutiny amid time pressures before summer recess”.

On Friday, the BBC reported that both those promoting the bill and those opposed to it had now concluded that it would not become law in the current session of Parliament.

Artificial intelligence

Further to our Wednesday post, A further examination of AI in legal blogging,  Legal Cheek reported that the Judicial Appointments Commission confirmed this week that judge hopefuls may use AI when drafting and reviewing self-assessment or individual skill and ability examples, so long as they remain “fully responsible for the accuracy and truthfulness of all material submitted.”

Acceptable uses include running self-written drafts through AI to improve grammar, clarity and structure, using it to identify key themes or strengths in content already written, and checking whether a draft flows and holds together. Candidates may also use AI to summarise long documents they have personally authored. However, “[AI] must not create substantive content or replace or inaccurately overstate personal experience.”

However, there are two sides to every job application, and one is reminded of a classic Beaker Folk article “If Clergy Ads Told the Full Story”, the assertions in which received a degree of episcopal acknowledgement.

Quick links

• Bible Society: not really “law”, but its report, The Quiet Revival, based on YouGov data and now known to be faulty, has been removed and reissued here; the Society claims, however, that “this faulty survey sample does not undermine the reality of a significant trend in which many people – especially young people – are finding renewed relevance in the Bible and Christianity in Britain today”.
• Jessica Murphy, BBC News: How a ban on religious symbols has triggered a Canadian constitutional debate: on the continuing controversy surrounding Québec’s Loi sur la laïcité de l’État.

Background

Prompted by an observation on the now extensive use of AI by many search engines[1], we examined some recent reviews on this use and as a stand-alone investigative tool[2]. Search engines now rely on AI at almost every stage of the search process—from understanding the query, to ranking results, to generating summaries. Around half of Google searches already include AI‑generated summaries, and this is expected to rise to over 75% by 2028 [3]. Furthermore, search engines no longer match keywords—they interpret meaning, intent, and context using large language models (LLMs). For example, they now understanding conversational questions (“Why is my broadband slow today?”), interpreting ambiguous queries; and personalising results based on past behaviour. This development is important as few have been aware of how AI has been shaping their internet searches.

With regard to the stand-alone use of AI search tools, a Which? survey undertaken in 2025 found an AI usage of 75% among 18–34s, but only 24% among over‑65s[4]. 51% of UK adults use AI search tools (ChatGPT, Gemini, Copilot, &c) in their personal lives; and ChatGPT is the most used AI search tool, with 47% of adults having tried it. Microsoft’s Copilot accounted for 34 % in this survey, but there are important differences between ChatGPT and Copilot, v infra.

ChatGPT vs Microsoft Copilot

ChatGPT is a “general‑purpose conversational AI built by OpenAI, which is optimized for creativity, reasoning, brainstorming, coding, and Q&A”. Microsoft Copilot is “a productivity‑focused AI embedded across Microsoft 365, Windows, Edge, and GitHub, designed to understand documents, emails, meetings, and organisational data”. Analysts expect the two to coexist rather than replace each other; many organisations deploy Copilot for productivity and ChatGPT for creativity and problem‑solving [5], [6], [7].

Copyright 

The use of AI inevitably raises the question of copyright of the material generated. Unlike the United States, the UK is unusual in having a statutory category for “computer‑generated works” under s9 Copyright, Designs and Patents Act 1988 (CDPA), which allows authorship to be assigned by legal fiction where no human creator exists—enabling such works to meet the basic conditions for protection.

9 Authorship of work.

[…]

(3) In the case of a literary, dramatic, musical or artistic work which is computer-generated, the author shall be taken to be the person by whom the arrangements necessary for the creation of the work are undertaken.

Syn Ong notes[8]: “despite being on the statute books for over three decades, Section 9(3) CDPA has received remarkably little judicial interpretation. In fact, with only two cases of note, there is a limit to how much doctrinal clarity one can extract from the case law”.

Conclusions

There have been important changes in the use of Artificial Intelligence since our first posts in 2023. Nevertheless, the conclusions we reached then, notably the careful formulation of the questions when seeking information via AI, remain unchanged. On the choice between ChatGBT and Copilot, it is evident that the latter gives a response more tailored to a user who is working with Microsoft 365 and their perceived areas of interest.

With the increased application of AI for internet searches, the use/links to primary sources become even more important. Also, the 4,000 plus posts on this blog are a potential resource for others to access.

[1] In this and subsequent posts, we follow the OUP guidelines on AI; these state:

“We use ‘AI’ to mean applications, tools, and programmes using Gen AI. Gen AI is a type of artificial intelligence which can be used to create new content (for example text, images, videos, or music) based on user inputs or ‘prompts’.

Large Language Models (LLMs) are a type of Generative AI. For example, ChatGPT is a large language model from OpenAI that uses deep learning to generate human-like responses in natural language based on information requested by a user in a prompt”.

[2] Microsoft Copilot was asked three questions: “How extensively do modern search engines use AI?”, “ChatGPT vs Microsoft Copilot?” and “Who owns the copyright of AI output?” These provided an overview, and links to references used, see [2] to [6].

[3] McKinsey & Company: New front door to the internet: Winning in the age of AI search,16 October 2025.

[4] Which? survey, 2025:Consumer use and attitudes towards AI search tools; Yonder, on behalf of Which?, conducted an online survey of 4,189 nationally representative adults aged 18+ between 10th and 14th September 2025.

[5] Institution Labs: ChatGPT vs. Copilot: An Enterprise Feature Comparison (2025), (updated 20 March 2026).

[6] United Nations University (UNU), Japan. Why Users Still Prefer ChatGPT Over Microsoft Copilot in 2025: The Technical Reality, (21 October 2025).

[7] Flexmind: ChatGPT vs Microsoft Copilot: Key Differences You Need to Know in 2026, (17 September 2025).

[8] Syn Ong, Authors’ Alliance: The UK’s Curious Case of Copyright for AI-Generated Works: What Section 9(3), (19 May 2015).

Updated 6 April 2026 at 09:05. This included the renumbering of all the references. 

Earlier this month, the Mattone Center Student Fellows had the privilege of traveling to Rome to participate in the ninth International Moot Court Competition in Law and Religion, held on March 13 and 14 at the St. John’s University Rome campus. The competition brought together teams from law schools from the United States and Europe, including teams from Italy, Poland, and Ukraine–about 100 participants in all. This marked the first time St. John’s has hosted the competition. Judge Mary Kay Vyskocil ’83, a member of the Mattone Center’s board, served as one of the judges at the competition.

The competition problem centered on a hypothetical dispute between a religious school, Thomas More School, and the government of the State of Utopia, which had enacted an “Equality in Education Act” alleged to infringe upon the school’s right to freely exercise its religious beliefs. The fellows were divided into two teams: Kalina Mesrobian ’26 and Stacey Kaliabakos ’27 represented the school, while Vincent D’Avanzo ’27 and Isabel Lane ’27 argued on behalf of the government. 

Being able to represent St. John’s in an international competition was an exciting and rewarding experience for our fellows. The fellows were were very fortunate to receive guidance from Center Director Mark Movsesian, St. John’s Law School Professor Robert Ruescher, and St. John’s Law alumnus James Herschlein, chair of the Litigation practice group at Arnold & Porter, who generously served as their coach and traveled to Rome to support the team in person. Their mentorship played a substantial role in helping our fellows grow their advocacy skills and confidence as they headed into the competition. 

Beyond the “courtroom,” the experience in Rome was truly unforgettable. Our fellows had the opportunity to form friendships with students from different countries, schools, and legal traditions, showing them how the answers to questions at the intersection of law and religion can vary across the globe. They were also able to explore some of Rome’s most iconic sites, including the Vatican Museums, the Galleria Borghese, the Pantheon, the Trevi Fountain, the Spanish Steps, and the Colosseum. 

Participating in this competition was a unique experience that strengthened the fellows’ legal skills, as well as their sense of community within the international legal world.

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Here are some important law-and-religion news stories from around the web:

• In Stinson et al v. Fayetteville School District No. 1, et al, regarding an Arkansas law that would require elementary schools to hang the Ten Commandments in classrooms, the Court granted a preliminary injunction enjoining certain school districts from complying with the law. 
•  In Chaudry v. Thorsen, an Illinois District Court rejected any Establishment Clause claims against a high school teacher brought by the parents of a student, wherein the teacher provided resources to the student who was seeking to convert from Islam to Christianity. 
• In a case in front of the Court of Justice of the European Union, the Court held that a German Catholic Organization could not dismiss one of its employees on the grounds of leaving the Catholic church.  
• Earlier this week, the President’s Religious Liberty Commission held a hearing on the topic of religious liberty in the healthcare industry, discussing topics such as vaccine mandates and potential threats to religious liberties in the medical field. 
• In Arizona Mining Reform Coalition v. U.S. Forest Service, the 9^th Circuit again upheld a transfer of land, which includes ceremonial religious grounds of the Apache tribe, to a Copper Mining company. 

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On Tuesday, the Scottish Parliament rejected the Assisted Dying for Terminally Ill Adults (Scotland) Bill, which had been introduced by Liam McArthur (Orkney, Lib Dem), by 69 votes to 57. The draft report of the debate is here.

Places of Worship Renewal Fund

Further details are emerging – slowly – about how the Places of Worship Renewal Fund will work. In answer to a written question from Lee Pitcher (Doncaster East and the Isle of Axholme, Lab) on the future ability of places of worship (in England)  to reclaim VAT on repairs and maintenance works, Ian Murray, Minister of State at DCMS, said this:

“The Department has not made an assessment of the ability of places of worship to reclaim VAT following the ending of the Listed Places of Worship Grant Scheme.

The Places of Worship Renewal Fund will have a budget of £23 million per year. The Places of Worship Renewal Fund will award grants for projects to cover capital works, rather than just the VAT element of a project, as is the case with the Listed Places of Worship Grant Scheme. In some cases, the amount granted could be greater than just the VAT element currently funded” [emphasis added].

For Women Scotland Ltd, Northern Ireland and the CJEU

Readers may recall that the Equality Commission for Northern Ireland applied to the High Court for leave to seek judicial review for clarification of how the Supreme Court’s interpretation of the Equality Act 2010 in For Women Scotland Ltd v The Scottish Ministers [2025] UKSC 16 in relation to Great Britain – basically, that the terms “man”, “woman” and “sex” in the Act must be interpreted as referring to biological sex – should be applied in the different legal context of Northern Ireland, where the Act does not apply.

Irish Legal News reports that last week the CJEU ruled in Shipova [2026] EUECJ C-43/24 [in French], a case about a Bulgarian trans woman living in Italy, that EU member states cannot refuse legal gender recognition to trans citizens who have exercised their right to free movement. The Court said at [54] that

“… tolerating discrimination based on the difference between biological sex and gender identity would amount to disregarding, in the case of transgender persons, the respect for dignity and freedom to which they are entitled and which the Court must protect.”

So far as we are aware, the application for judicial review in Northern Ireland is still pending.

Funeral arrangements and parental disagreement

The Independent reports a particularly sad case of parental conflict over funeral arrangements for a 17-year-old boy, Gabrielle Barbus, who died by suicide in December. The father, Mr Stefan Barbus, an Orthodox Christian, and the mother, Ms Georgia Opritescu, had divorced when Gabrielle was two. Mr Barbus wanted to bury Gabrielle, while Ms Opritescu wanted to cremate him and scatter his ashes in the Devon countryside. Mr Barbus argued that Gabrielle had been baptised as an Orthodox Christian, that burial respected the sanctity of the human body and soul, and that cremation was not acceptable because it destroyed the body and was irreversible, while Ms Opritescu said that her son had not grown up in a religious household and that she wanted him to be free and returned to nature by his ashes being scattered, not confined in a coffin or an urn in the ground.

According to the report, HHJ Klein found for Ms Opritescu on the basis that Gabrielle had had a closer relationship with his mother than with his father, and that, because of that closeness, it was more likely that he would have wished to honour his mother’s wishes.

We hope to publish a formal note if the text of the judgment becomes available.

Human rights in the UK

On Thursday, the Equality and Human Rights Commission, the Scottish Human Rights Commission and the Northern Ireland Human Rights Commission issued a Joint statement on the application of the European Convention on Human Rights, occasioned, it would appear, by the call last year from 27 Council of Europe member states, including the UK, to “re-balance” and “clarify” individual rights and state responsibilities in relation to migration.

The statement urges the UK Government “to commit to no reduction in rights protections. The principle of universality is fundamental to human rights: rights that can be removed from some people are no longer rights for everyone”.

Cardinal Becciu again

Readers may remember that Cardinal Becciu was stripped of his privileges as a cardinal by Pope Francis in 2020 and convicted of financial fraud by a Vatican court in 2023. He appealed, and Associated Press reports that the Vatican appeals tribunal has ruled that the original trial was defective and has ordered a retrial, beginning on 22 June.

And finally…

On Tuesday, Nick Timothy, currently the Shadow Lord Chancellor, posted on TwiX a complaint about Muslims engaging in mass prayer at an event in Trafalgar Square:

“Too many are too polite to say this. But mass ritual prayer in public places is an act of domination. The adhan – which declares there is no god but Allah and Muhammad is his messenger – is, when called in a public place, a declaration of domination. Perform these rituals in mosques if you wish. But they are not welcome in our public places and shared institutions. And given their explicit repudiation of Christianity they certainly do not belong in our churches and cathedrals. I am not suggesting everybody at Trafalgar Square last night is an Islamist. But the domination of public places is straight from the Islamist playbook.

To which Dominic Grieve, the former Conservative Attorney General, who subsequently quit the party over Brexit, posted this in reply:

“This is a very odd post from a Conservative who says he believes in freedom of expression under law and is a principal spokesman of the Free Speech Union. I appreciate that he does not like Islam and there is no reason why he should. As a Christian it is not my faith. But the use of Trafalgar Square (with permission) for religious events, Christian and other, goes back a long way. There have been prayers and hymns, chants and religious events performed there in the past. If such an event ‘shouldn’t happen again’ it raises the question of whether this is to apply to all religious events or just to Muslim ones. If to all, then we are moving like France to imposing secularism as a norm and it is contrary to our national tradition and does not seem to have helped develop social cohesion there. If just to Muslims, then it is an act of discrimination against them without any lawful basis. To achieve it you would have to enact discriminatory legislation targeted at Muslims. Is this what Nick Timothy is advocating?”

Good question… The Guardian reports some political reactions here; the Bishop of Willesden, Lusa Nsenga-Ngoy, the Church of England’s lead bishop for interfaith engagement, comments here; and the Bishop of Kirkstall, Arun Arora, comments here. 

Here is an interesting looking book from Oxford that explores religious freedom from the perspective of sociology: “A Sociology of Religious Freedom,” by Professors Olga Breskaya and Giuseppe Giordan of the University of Padua and James Richardson of the University of Nevada. I’m looking forward to reading the sections on defining religious freedom, in particular. Here’s the description of the book from the Oxford website:

In recent years, the relevance of religious freedom has spread well beyond academia, becoming a reference point for international relations, multi-level policy development, as well as interfaith negotiations. Meanwhile, scholarship on religious freedom has flourished on the boundaries of sociology, law, comparative politics, history, and theology. This book presents a systematic sociological analysis of religious freedom, bringing together classical sociological theories and empirical perspectives developed during the last three decades. It addresses three major questions involved in any sociology of religious freedom. First: considering its complex and controversial nature, how can religious freedom be defined? Second: what are the recurrent sociological conditions and relevant social perceptions that will foster an understanding of religious freedom in varying political, legal, and socioreligious contexts? And third, what are the mechanisms of social implementation of religious freedom that contribute to making it a fundamental value in a society? Olga Breskaya, Giuseppe Giordan, and James T. Richardson suggest that a sociological definition of religious freedom requires us to take into account historical, philosophical, legal, religious, and political considerations of a given society-and that the social dimensions of religious freedom are as important as the legal ones.

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Last week, the Mattone Center Fellows competed in the 9th edition of the International Moot Court Competition in Law and Religion at the St. John’s campus in Rome. We are very proud of Kalina, Stacey, Vincent, and Isabel for their performances and hard work. Thank you also to Jim Herschlein for coaching our team and Judge Vyskocil, Judge Forrest, and Dr. Jeremy Gunn for judging the tournament. This was a truly special opportunity that the Center and its Fellows will never forget. 

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Here are some important law-and-religion news stories from around the web:

• The Supreme Court has blocked a California policy that requires public schools to facilitate students’ gender transitions and keep it secret from parents.
• In Childs v. Webster, the 7th Circuit held that there was not a violation of a Muslim inmate’s free exercise rights under RLUIPA or the 1st Amendment when his prison refused to distribute corrected prayer-time schedules to Muslim inmates.
• In State of Washington v. Corporation of the Catholic Archbishop of Seattle, a Washington state appellate court allowed enforcement of a subpoena issued by the state Attorney General’s Office seeking from the Catholic Archdiocese evidence relating to clergy sexual abuse.
• The U.S. Commission on International Religious Freedom (USCIRF) declared that the State Department has failed to comply with the International Religious Freedom Act (IRFA).
• The Military Religious Freedom Foundation reported that it has received numerous complaints from military personnel that their commanders are describing the military operations against Iran in Christian eschatological terms.
• Indiana Governor Mike Bruan signed House Enrolled Act 1389 which prohibits governmental discrimination in adoption and foster care matters.
• An investigation into the Catholic Diocese of Providence, Rhode Island, shows that an estimated 75 priests have abused more than 300 children since 1950.

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