This post examines aspects of ecclesiastical law raised by the christening of Princess Charlotte of Cambridge
Baptisms were in the news last week, first with the Church of England’s publication of Christenings – a positive choice on 3 July, and then the christening of Princess Charlotte of Cambridge (as Charlotte Elizabeth Diana) at St Mary Magdalene, Sandringham on 5 July 2015. It is unusual for christening parties to bring their own water, but Princess Charlotte’s family provided both water and a font. The Daily Telegraph commented “After this heavenly christening, the Church of England should brace itself for a baptism bonanza,” and given the enthusiasm with which a number of the public seek to emulate the trends set by “the royals”, it is likely that incumbents might be requested to replicate them, and this post examines the extent to which recent events were regulated by ecclesiastical law. Before considering the “hardware and consumables” associated with the christening, however, there are other non-routine aspects the service to be addressed.
In his Legal Framework of the Church of England (1996, Clarendon Press, Oxford), Norman Doe observes that in contrast to the Roman Catholic Church, the use of canonical regulation in this area is limited and governs preparation and admission, and imposes a general duty on ordained clergy not to refuse baptism, although there is a ministerial right to delay; the celebration of baptism “is governed principally by liturgical rubrics” but can only be celebrated outside a full liturgical context “when grave cause and necessity” occur, (Canon B22(9)), see below.
Doe notes that baptism is administered validly with the application of water and recital of the words “I baptize you in the name of the Father, of the Son, and of the Holy Ghost,” the basic principles having been clarified in Kemp v Wickes. The full liturgical celebration of baptism, is regulated by other requirements, violation of which will render the baptism not invalid but irregular.
With regard to baptism in a church, it is permissible to perform baptism in the absence of the regular congregation, and although periodically debated by PCCs, this is not the option favoured by the Church of England. Canon B 21 Of Holy Baptism states:
“It is desirable that every minister having a cure of souls shall normally administer the sacrament of Holy Baptism on Sundays at public worship when the most number of people come together, that the congregation there present may witness the receiving of them that be newly baptized into Christ’s Church, and be put in remembrance of their own profession made to God in their baptism.”
However, there may be pastoral or other reasons for private baptism outwith the normal services, such as availability of godparents or security, as in the case of Princess Charlotte. Over recent years, Royal baptisms have taken place in a number of royal residences: the Church of Saint Mary Magdalene, Sandringham is where Charlotte’s late grandmother — Diana, Princess of Wales — was christened, and was chosen on account of its proximity to Anmer Hall, Prince William and Kate’s intended family home.
This raised two issues: where a child’s parents are not parishioners or on the electoral role of the parish, the minister intending to baptise the infant must seek the good will of the actual minister or incumbent of the parish in which the parents reside, Canon B 22 (5); and when a baptism is conducted by a minister other than one with a licence or permission to officiate at the church, Canon C 5 2(a) provides that:
“A minister duly ordained priest or deacon, and, where it is required under paragraph 5 of this Canon, holding a licence or permission from the archbishop of the province, may officiate in any place only after he has received authority to do so from the bishop of the diocese or other the Ordinary of the place.
(a) The minister having the cure of souls of a church or chapel … may allow a minister, concerning whom they are satisfied either by actual personal knowledge or by good and sufficient evidence that he is of good life and standing and otherwise qualified under this Canon, to minister within their church or chapel for a period of not more than seven days within three months without reference to the bishop or other Ordinary, and a minister so allowed shall be required to sign the services register when he officiates; but nothing in this sub-paragraph authorizes.”
Clearly this is much easier when then service is to be conducted by the Archbishop of Canterbury, albeit supported by the Reverend Canon Jonathan Riviere, the Rector of the Sandringham group of parishes.
It is evident from Kemp v Wickes that extra-parochial baptism is valid, but Canon B 22 (9) warns:
“The minister of every parish shall warn the people that without grave cause and necessity [i.e. circumstances addressed by Canon B 22 (6 to 8 ) they should not have their children baptized privately in their houses.”
The Book of Common Prayer contains a service for The Ministration of Private Baptism of Children in houses which commences by repeating the warning within the canon:
“The Minister of every parish shall warn the people that without great cause and necessity they procure not their children to be baptized at home in their houses. But when need shall compel them so to do, then Baptism shall be administered on this fashion … “
Whilst the rubric is not repeated in Common Worship, this is implicit in the name of the equivalent service which is entitled Emergency Baptism.
Music from royal events is quick to gain popularity for use in church services, but in relation to baptisms, that performed at Sandringham is somewhat academic. There is generally no choir or organist at private christenings, and the music at the regular Sunday services is often chosen to reflect the readings. As at all services, the choice of music rests with the minister who is required shall pay due heed to the advice and assistance of the Director or Music, organist or choirmaster, (by whatever name called), Canon B 20 Of the musicians and music of the Church.
Although the congregation themselves may only be given the opportunity to choose the hymns on a very occasional basis, there may be some scope for flexibility, depending upon the capabilities of the assistant organist and choir, and the availability of copies of the music.
The Sandringham Estate web page for St Mary Magdalene church indicates that “other notable features include a Florentine marble font, [and] a Greek 9th-century font”, (Betjeman only mentions the latter); so why the need to import the “Lily Font” and the associated Royal Ewer from the Crown Jewel Collection? This font has been used for the baptisms of most royal babies since it was commissioned by Queen Victoria in 1840 at a cost of £401 10s, as she did not wish her children to be christened the then-traditional Charles II font that had been used for his illegitimate children. There is therefore a certain irony that Princess Charlotte has links to Charles II’s children through her paternal grandmother and the Spencer family. Leaving aside this (and the aesthetics of the Lily font), its importance lies in the fact that use of the Lily Font was restricted to those styled “HRH”, the corollary to which is that there is a strong argument for its use in relation to anyone so styled.
Most judicial consideration of fonts in the ecclesiastical courts relates to: their location in a church; their disposal; or whether there may be more than one. However, in Re St Mary’s, Shortlands,  Rochester Const Ct, Goodman Ch. is the Chancellor considers inter alia whether a faculty is required to authorize the [continuing] use of a portable font in a church, . Noting that some portable fonts in use in the Rochester diocese are without faculty authorization, and he comments that this practice is irregular and should not be followed, .
Whilst the regular use of a portable font could not be considered de minimis and would need faculty authorization under Canon F 13, he said
“ … Of course, the very occasional use of a basin or bowl to hold the water when it is impossible or impracticable to use the authorized font would not in its nature call for a faculty in view of its transient connection with the church …” .
The royal christening could be viewed as falling within these criteria, but it seems unlikely that there would other circumstances, albeit transient, that could meet the “impossibility or impracticability” conditions. A further restriction in in Canon F 1(3) provides that “[t]he font bowl shall only be used for the water at the administration of Holy Baptism and for no other purpose whatsoever”.
Despite the centrality of water to baptism, there are few references to the its use in the canons or rubrics to the services. The Book of Common Prayer requires that for the public baptism of infants:
“At the time appointed the godfathers and godmothers and the parents or guardians with the child must be ready at the Font, and the Priest coming to the Font (which is then to be filled with pure Water,) and standing there, shall proceed as follows …”,
although Common Worship only indicates that “the ministers and candidates gather at the baptismal font”. As is customary of royal baptism, Princess Charlotte was baptized with water from the river Jordan, reportedly sent by that country’s royal court. The relatively small size of the Lily Font and Royal Ewer made this a practical possibility for either affusion or sprinkling.
For those without such contacts in the Jordanian court, “Holy Water From The Jordan River” from a number of sellers is available from Amazon UK, but a number of practical considerations would seem to preclude its use: uncertain purity, given the polluted nature of the source of the water; quite costly for relatively small quantities, 100-200ml, particularly for use in non-portable fonts. Some sources are scented “with Jerusalem Flowers”, whilst others have already been blessed by an Orthodox priest.
It is too early to know whether there will be a “baptism bonanza” as predicted by the Daily Telegraph, above, but the publication of the new Church of England web page Christenings – First Steps on an Amazing Journey was timed strategically, and is certainly in a more welcoming format than its pages on Baptisms on the main web site. Whilst it does not indicate whether a service similar to that of Princess Charlotte is possible, the FAQ’s do address some of the elements discussed above, including:
- Where can we hold the christening? You can have your baby christened at your local parish church. If you’d like to have the christening at a different church, for example, where you grew up or where you were married, talk to the vicar at that church to see what’s possible;
- Can we arrange a christening at a separate time to the Sunday service? There may be opportunities to have a service at a different time, again usually on a Sunday, but talk to the vicar and ask their advice about what is possible at your church;
- Can anyone have a christening service? Yes, so long as they have not been baptized already. The Church of England welcomes all babies, children and families for christenings – whatever shape that family takes. You do not have to be married or have been a regular churchgoer – as a parent, you do not even have to have been baptized yourself – though you could be. Everyone is welcome at their local church. Just ask your local vicar if this is something you are considering for your child.
Whilst this last point is in effect a re-statement of a priest’s legal obligations under Canon B 22(4):
“No minister shall refuse or, save for the purpose of preparing or instructing the parents or guardians or godparents, delay to baptize any infant within his cure that is brought to the church to be baptized, provided that due notice has been given and the provisions relating to godparents in these Canons are observed,”
recent events have demonstrated that in addition to parents, some clergy need to reminded of the fact.
Few will appreciate the issues of ecclesiastical legislation raised in the christening of Princess Charlotte, but apart from the font and water, many of these can be accommodated within the service of baptism to which all parishioners are entitled.
 i.e. the use of water and the invocation of the name of the Father, of the Son and of the Holy Ghost; baptism so administered, even by a layman or woman was valid; a person who was so baptized was not to be baptized again; providing the essence of baptism, according to what has generally been received among Christians as the essence of baptism, had taken place, baptisms administered in other churches will be recognized as valid for the purposes of the Church of England; baptisms administered privately are valid.
 Kemp v Wickes, (1809) 3 Phil 264 at 269, ER 1322, 1324.
 Buckingham Palace: Her Majesty the Queen in the private chapel, and Prince Charles, Princess Ann, Prince William in the Music Room; Windsor Castle private chapel, Prince Harry and Master Archie Mountbatten-Windsor; St James’ Palace private chapel.
 Hymns: “Praise to the Lord, The Almighty” and “Come Down, O Love Divine”; Anthem: “I Will Sing With The Spirit” and “God Be In My Head,” both by John Rutter; Organ, processional, R. Vaughan Williams’ Prelude on “Rhosymedre”, and recessional G. F. Handel’s Overture and Allegro from Concerto VIII in A.
 The two pieces by Rutter cost £1.85 and £1.60 per copy, and a large choir will generally purchase 40 to 50 copies. Photocopying is not an option.
 Summary at  7 Ecc LJ 363.