With yet one further allusion to Sydney Pollack’s award-winning film, we expand our consideration of the treatment of unwanted church furniture from fonts to altars. The recently circulated Re St. George the Martyr Preston  ECC Bla 2 concerned an extensive reordering project, which in addition to the more contentious issues of the replacement of the two wooden and glazed draft lobbies, included the removal and disposal of a nave altar and the introduction of a new bespoke altar [1(4)].
Before considering the detail of the legislation, it is useful to review the history associated with altars. The overview in the Church in Wales’ document, Church in Wales, Disposal of Fonts and Altars, (3 March 2020), provides a useful summary, which in most respects, reflects that of the Church of England . This notes [emphasis added]:
“[t]hey were originally made of stone until the Reformation in the 16th century, when they were removed and replaced by wooden communion tables. Unlike most other church contents, they were are always consecrated individually, and a service of de-consecration performed before their disposal. Some stone altars were broken up and buried in the church or churchyard during the Reformation. Some were even incorporated into the building fabric of the church”.
Of the disposal options available, “destruction” is generally the route of last resort, but this course of action is unlikely to be available for items that are of historic significance. Furthermore, for the relatively few stone altars remaining in the Church of England, the “burning” option is not possible; the presence of holy relics is a further issue be addressed.
The focus of this post is the legislation relating to the disposal of altars in the Church of England  under essentially three different regimes: the faculty jurisdiction of the consistory courts for churches currently in use; pastoral schemes under the Church Buildings Council, (CBC), where churches are no longer needed for regular public worship as a consequence of parish reorganization; and the closure of church buildings no longer required as a place of worship or replacing one which is unsuitable. Disposal under a pastoral scheme is subject to the direction of a bishop, whereas closures are conducted though CBC procedures.
There are parallels with the treatment of altars within the Roman Catholic church which are subject inter alia to the 1983 Code of Canon Law (Can 1212, and 1235 to 1239), General Instruction of the Roman Missal (293 to 308), and The Order of Dedication of a Church and an Altar. These include provisions on matters such as “fixed” and “moveable” altars, their dedication and blessing (and their loss), and the inclusion of relics. The past and present positions on “altar stones” are discussed by McNamara .
The most recent case is Re St. George the Martyr Preston , in which Hodge Ch. stated:
“. …Since the altar will have been dedicated to its sacramental role in the celebration of the Eucharist, or Lord’s Supper, it should not be profaned by any secular use which might result from its sale or disposal for any non-liturgical purpose. Any disposal of the altar must therefore be undertaken with particular care. As a last resort, the altar should be [burned] or broken up and buried within the church or other consecrated grounds“.
On the disposal of artefacts, in Re St. Margaret of Scotland Southsea  ECC Por 1 Waller Ch. stated:
. On the information presently available I am satisfied that a faculty should issue for the following: […] (iv) Disposal of high altar; (v) Disposal of any altars, statues, sanctuary lamps, candle stands, vestments and other miscellaneous items which are not required by the new congregation. subject to the following conditions:
(a) All items for removal must be given suitable consideration as to their appropriate disposal or relocation and all final decisions are to be agreed with the Archdeacon”.
(b) Where the identity and whereabouts of the donor of any item (or, if deceased, any family member of the donor who may have an interest) is known, the item may only be removed and disposed of after reasonable steps have been taken to consult them.”
In Re Holy Trinity Cambridge  ECC Ely 1, a footnote to the L&RUK review in Consistory Court Judgments – October in 2016 observed:
“With regard to the (abandoned) proposal to completely remove the altar, Canon F 2 Of the holy table requires that “in every church and chapel a convenient and decent table, of wood, stone, or other suitable material, shall be provided for the celebration of the Holy Communion, and shall stand in the main body of the church or in the chancel where Morning and Evening Prayer are appointed to be said.
Any dispute as to the position where the table shall stand shall be determined by the Ordinary. In Re: St Stephen’s (1987) 3 WLR 726, (1987) 2 ALL E.R. 578, summarized here, the Court of Ecclesiastical Causes Reserved examined the scope for Canon F2 with reference to the well-known Henry Moore altar. Further consideration on the requirement regarding an altar was given in Re St. Michael Cumnor at paragraphs 12 to 14″.
The Chancellor did not set out the plans in extenso because many parts of the scheme are uncontroversial, noting “[s]ome of the more controversial plans, such as removing all the stained glass and doing away with the altar entirely have been abandoned. I am glad that they have”.
In the Court of Arches in Re St Gregory’s Tredington  Fam 236 ], Newson Ch. (sitting as Deputy Dean) made plain that there is no authority binding on chancellors requiring that if a faculty is granted for the sale of communion plate, the vessels should be “protected from profane or secular use”. However, Chancellor Hill noted that in the case of altars and fonts “the fact of their previous sacramental use will be a reason for particular care being taken when deciding on any conditions to be imposed in the event of disposal”.
Dioceses regularly review how they provide support for mission, ministry and pastoral care, and this may lead to reorganization. Under a “pastoral scheme” which is subject to the Mission and Pastoral Measure 2011 (No 3), Part 6 Vesting property &c, a bishop is required to give directions on the disposal of the font, communion table and plate used for the purpose of Holy Communion, unless otherwise specified in the Scheme.
“76 Disposal of font, communion table and plate, and other contents
(1) Where a pastoral church buildings scheme or pastoral (church buildings disposal) scheme makes provision for a church or part of a church to be demolished or appropriated to any use specified or described in the scheme the bishop shall, unless the scheme makes other provision, give directions as to how the font, communion table and plate used for the purpose of Holy Communion shall be dealt with but, if the church or part is so demolished or appropriated before any such directions are given or fully implemented, the diocesan board of finance shall, subject to any provision of the scheme, be responsible for the care, maintenance and safeguarding of any such items.
(3) Where any items are disposed of in accordance with subsection (1) or (2) the bishop shall, subject to any provision of the scheme, give directions as to how any proceeds of their sale are to be applied…”
There is a formal process for heritage matters relating to closed and closing churches, and a Statutory Advisory Committee (SAC) gives independent advice to the Church Commissioners and the Churches Conservation Trust. The SAC is a committee of the CBC and a statutory body in its own right; its constitution is set out in schedule 4 paragraphs 18-27 of the Dioceses, Pastoral and Mission Measure 2007. If a decision is made to close, the Church Commissioners and the diocese will seek a new use for the church building and a suitable buyer to take it on.
The CBC advises on the heritage implications, and the SAC identifies the features of a church which should to be preserved once worship has ended and the building has passed out of the care of the congregation. It uses the criteria and methodology for assessing significance and impact endorsed by the CBC
In relation to the font, altar, communion table and plate, it notes “[t]hese items have a sacramental purpose and are normally transferred to another church within the benefice or somewhere else in the diocese”.
The CBC has issued advice on Furnishings no longer required for worship ; however, there is no guidance specific to the disposal of altars for which the associated terminology uses “holy table” and “communion table” Likewise, the CBC Advice and Guidance for church buildings makes no reference to altars.
Although similar principles are adopted by the consistory courts and the CBC to the disposal of unwanted altars, there little guidance on how this is to be undertaken in practice and even fewer reports of any such destruction taking place. Consequently, in response to the question “They bury (and burn) altars, don’t they?”, the answer must be “possibly…”.
 For a more detailed description of the treatment of altars during the Reformation, see Robert Whiting, The Reformation of the English Parish Church, (Cambridge University Press 2010) 21-35.
 There is no reference to “altar” in Canon F 2 Of the holy table; Likewise Canon F3 Of the Communion Plate and Canon F4 Of the Communion Linen refer to the “communion table” and not to “altars”. Also, the Book of Common Prayer uses “communion table”, “the Lord’s Table” or “Holy Table”.
However, in the Faculty Jurisdiction Rules 215 as amended, there are references to “altar falls”, “altar linen” and “altar frontals”, but none for “holy tables” or “communion tables”. The equivalence of these terms was settled by the Court of Ecclesiastical Causes Reserved in In Re: St Stephen’s (1987) 3 WLR 726, (1987) 2 ALL E.R. 578, infra.
 See Denis R McNamara, Adoremus: Is a new altar supposed to have an altar stone? , (11 May 2022).
 Photographs are included in the judgment, and readers may (or may not) agree with its description by Hodge Ch. as “ghastly, poorly constructed from flimsy materials, and entirely out of keeping with the simplicity of the rest of the sanctuary area ”.
 The CBC advice on Furnishings no longer required for worship, gives specific guidance on fonts, redundant organs, and seating. There is also general advice on disposals and loans, and when to consult the CBC.