Court hears objector to female bishops

Behind the scenes of the installation of Rt Revd Sarah Mullally to the See of London

At 16.00 on Thursday 8 March 2018, the Archbishop of Canterbury and the Court of the Vicar General sat at the church of St Mary-le-Bow to confirm the election of the Rt Rev Sarah Mullally to the See of London. In a move to address any potential disruption by a frequent complainant to the ordination of women as bishops, on 6 March 2018 the Vicar General’s Court of the Southern Province sat to hear his views and to issue a Direction. Following the confirmation of her election, on 12 May 2018, The Rt Revd and Rt Hon Sarah Mullally DBE was installed as the 133rd Bishop of London at St Paul’s Cathedral.


On 20 July 2016, WATCH (Women and the Church) issued a Press Release commenting on the presence of objectors at the consecration of female bishops, and hoping that at the next consecration of female bishops, “things will be arranged differently”. The Press Release, a copy of which we reproduced in an earlier post, asks for supporters of WATCH to write to Cathedral Deans, “who carry the responsibility for what happens within the buildings concerned”, and to the Archbishop.

Our initial consideration of the WATCH Press Release (160721) prompted a number of comments on the importance or otherwise of the role of the congregation’s acclamation for bishops-elect. In Acclamation, assent and disruption (160725) we gave some consideration to the legal issues underpinning this acclamation, and noted that although this rhetorical question was introduced in Common Worship in 2000, no such exchange is included in the Book of Common Prayer; and in view of Norman Doe’s comment in The Legal Framework of the Church of England, (Clarendon Press, Oxford, 1996), pages 166-7, there appears to be no legal requirement for its inclusion (other than the assent of General Synod to the format of the service). However, General Synod’s assent would now be required for its removal.

In Liturgy, Order and the Law, (1996, Clarendon Press Oxford, pages 231-2), Rupert Bursell considers a parallel situation in relation to objections to ordination to the diaconate and priesthood according to the Book of Common Prayer and the Alternative Service Book (ASB). It could be argued, therefore, that it is not illegal for an objection to be raised in response to the invitation of the Archbishop at this point in the service, although Bursell notes [page 231]:

“an objector who persists in interrupting the services once his objection is overruled is in danger of a prosecution under S2 Ecclesiastical Courts Jurisdiction Act 1860”.

We concluded:

“Nevertheless, there seems to be little justification, other than the management of expected dissent, for the cathedral authorities to facilitate the delivery of an objection as indicated in the WATCH letter, particularly at any other point in the service. However, this leaves the authorities with the dilemma of how “things will be arranged differently”, without recourse to investigating the applicability of the heavy-handed legal options we discussed earlier.

Subsequently, we noted (160809) that in response to its letter to the Archbishop of Canterbury, on 9 August 2016 WATCH posted [emphasis added]:

“The Archbishop of Canterbury has informed us that conversations are in progress with the relevant people so that, in future, objections such as that at Canterbury Cathedral in June will not be allowed. Thank you to those who have written in support of our statement.”

Vicar General’s Court

The proceedings are summarized in the recent edition of the Ecclesiastical Law Journal (ref 1). The objector, the Revd Stephen Holland would normally have lacked sufficient interest in the proceedings to stand as an opposer: he was a minister of the Westhoughton Evangelical Church and the Protestant Truth Society, a church not in communion with the Church of England; and was not resident in the Diocese of London. However, in this case special citation had been directed to the Revd Mr Holland, and on that ground alone the Vicar-General allowed him to appear.

The argument of the Mr Holland was that his belief that a woman of a role of leadership in the church was contrary to Scripture and tradition; he contended that in permitting that ministry, the Church of England had erroneously been led by the spirit of the age rather than adhering to the guidance of the Holy Spirit.

However, the Vicar-General held that the appointment of a bishop was a legal process governed by the Bishops and Priests (Consecration and Ordination of Women) Measure 2014 and Canon C 2(1). Furthermore, there was no legal or doctrinal impediment preventing the confirmation of the election of Bishop Mullally, who had, in fact, been discharging episcopal functions since her consecration to the suffragan see of Crediton.

The Vicar General concluded that Mr Holland’s arguments had no foundation in law; he dismissed his objection and directed that he be debarred from pursuing further the objection made to the court.


With regard to the various objections that have been raised to women in the episcopate, whilst all are based on the belief that there is no biblical basis for women being made bishops, the manner in which the objections were raised has been different.

In the case of Revd Paul Stewart Williamson, PiC St George’s, Hanworth Park, London, in 2015 he objected to the election of the Ven. Rachel Treweek as Bishop of Gloucester.  His objection did not relate to the suitability of the Bishop-elect for episcopal office, but the legal basis on which women might become bishops in the Church of England. The Court of the Vicar-General of the Province of Canterbury dismissed his objections.

In the case of the consecration of the Rev Libby Lane as Church of England’s first female bishop, the Rev Paul Williamson interrupted the Archbishop of York, the Most Rev and Rt Hon Dr John Sentamu, by shouting “not in the Bible”, when the Archbishop sought the acclamation of the congregation to her ordination.  Subsequently, Mr Holland has voiced objection at a number of ordinations of women as bishops.

In the case recently considered by the Vicar General, supra, Mr Holland opposed the confirmation of the election of Sarah Mullally, who had already been consecrated as a bishop. Furthermore, the order of service of her installation as Bishop of London differed from the Common Worship consecration of bishops in that the congregation was not required to voice its acclamation.

With regard to WATCH’s comments that “things will be arranged differently”, the hearing of the Vicar-General’s court in March appears to have forestalled an interruption to Bishop Sarah’s installation. However, the summary of the case suggested that Mr Holland had been debarred from pursuing further the objection made to the court, i.e. with reference to the installation, not, apparently, to the interruption of any future consecration of a woman as a bishop.

On 3 July this year, the Very Revd Vivienne Faull, currently Dean of York, will be consecrated as the 57th Bishop of Bristol at a service at St Paul’s Cathedral and installed as Bishop of Bristol at Bristol Cathedral in the autumn. By now the Church authorities are aware of “the usual suspects” who are likely to disrupt an ordination, and as such they are readily identifiable when seeking access to consecrations and installations, some of which are “ticket only events”. In theory, the means of avoiding the repeat of such an occurrence are straightforward: restricting access to the event, and avoidance of an opportunity to voice objections, such as at the acclamation.

Whilst some might perceive an interjection at these services as an inevitable part of the service, as the now “traditional” comments by Dennis Skinner are an accepted precursor to the Queen’s Speech, this is not a satisfactory approach and we doubt whether WATCH will view it from this point of view either.

Reference 1: Arlow, R “Re the Confirmation of the Election to the See of London: Court of the Vicar-General of the Province of Canterbury: Briden V-G”, [2018], Ecc LJ, 257.

Cite this article as: David Pocklington, "Court hears objector to female bishops" in Law & Religion UK, 21 May 2018,

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