Is a diocesan bishop a “qualifications body”?: Ganga v Chelmsford DBF

In the course of its judgment in Pemberton v Inwood [2015] ET 2600962/2014 the Employment Tribunal referred to another recent case, Ganga v Chelmsford Diocesan Board of Finance & Anor [2015] ET 3200933/2013, in relation to the status of a diocesan bishop as a “qualifications body” for the purposes of a Permission to Officiate or of a licence/authorisation under the Extra-Parochial Ministry Measure 1967.

The ET in Pemberton agreed that, constitutionally, it was the bishop of the diocese in which a priest worked or wished to work who, under Canon C 8, was the person who, inter alia, licensed or refused to license “and no other” [99]; it also observed that Ganga was the first case to address the issue of whether or not the Church was a “qualifying body” [119]. In the circumstances, therefore, we thought that a note on Ganga would be helpful.  Continue reading