On 21 July 2023, the Diocese of Oxford issued the Press Release Learning Lessons Review: Revd Michael Hall, (“the Hall Review”), concerning the safeguarding case review it commissioned in April 2022 into allegations of spiritual abuse connected with St Margaret’s, Tylers Green, High Wycombe between 1981 and 2000. The review was the most recent of such “lessons learnt” reviews from the Diocese[1] and provides a present-day perspective of the Church’s approach to spiritual abuse both during and after the events at St Margaret’s.

Spiritual influence and spiritual abuse

Spiritual influence

Early L&RUK posts addressed the issue of spiritual influence in relation to elections within the UK; although regulated through a specific tranche of statutory legislation, this has its origins through “a 19th Century attempt to catch abuses of authority by members of the clergy”. The offence of “spiritual injury” concerns the conduct of individuals during elections, and is one aspect of “undue influence” now included in S115(2) Representation of the People Act 1983. The wording is virtually the same as section 2 of the Corrupt Practices Act 1883, itself taken from the Corrupt Practices Act 1854 but substituting the words “temporal or spiritual injury,” in place of ”intimidation”. The 1883 Act was therefore the first statutory provision relating to “spiritual injury”.

The Electoral Commission’s Research Paper The Regulation of the Campaign and Electoral Offences notes that there is no unanimity within the case law on these issues; furthermore, the examples of “clerical intimidation” before the courts have included instances of both direct and indirect “spiritual implications”.

Definitions of spiritual abuse

The Hall Review uses the definition of spiritual abuse employed by the Church of England in its Safeguarding e-manual [Chapter 7 – Understanding the nature of spiritual abuse] [2]:

“Spiritual abuse can be defined as, “… a form of emotional and psychological abuse. It is characterised by a systematic pattern of coercive and controlling behaviour in a religious context” (Oakley and Humphreys, 2019).

It also notes these processes are consistent with the Ann Craft Trust’s definition of grooming [3], and consistent with the Home Office definitions of controlling and coercive behaviours [4]. However, it observes:

“Spiritual Abuse is not a separate category of abuse but is a form of psychological and emotional abuse.  It is important when discussing such cases with statutory agencies to be clear that spiritual abuse is a form of psychological and emotional abuse within a religious context”.

Nevertheless, that it not a reason against using the term, but is a caveat with regard to its use in context. The Hall Review comments:

“[7.3]. Within this context [i.e. of the Home Office definitions of controlling and coercive behaviours] the use of spiritual justification through selected texts and claims of religious purity and eminence, which are factors in both spiritual abuse and some forms of radicalisation, can be understood as techniques used to exercise power, coercion and control rather than ends in themselves.

The purpose of these forms of abuse include the exercise of power and control as well as obtaining financial and material gain or attaining wider social and political ends…”.

“Financial and material gain” was a significant element in Stowe and Maids Moreton, and the abuses perpetrated by the Revd Michael Hall included the use of biblical justification for his actions and threats to withhold Holy Communion, itself an ecclesiastical offence.

In the case of the Revd Timothy Davis, “the complaint was limited to the issue of spiritual abuse to the exclusion of the allegations of bullying made by several of the witnesses”; the  “allegations about bullying were abandoned at the outset [and] were deliberately omitted because the evidence was insufficiently compelling to be taken to a Tribunal” [para. 5.6 of the Davis Review].

At the time of the Davis judgment, Christian Today reported that “The Evangelical Alliance is highly critical of the definition and claims it could lead people ‘potentially to criminalise whole religious communities with whose theology they happen to disagree’… The 18-page document [Reviewing the Discourse of ‘Spiritual Abuse’: Logical Problems & Unintended Consequences] warns that using ‘spiritual abuse’ could end up meaning that conservative Christian teaching on homosexuality, marriage and sin would count as abuse.”

Spiritual abuse –  Revd Timothy Davis

The CDM tribunal determination on the Revd Timothy Davis, issued on 28 December 2017, made an early reference to “spiritual abuse” in the context of the safeguarding aspects associated with mentoring. To date, this remains the only reported judicial consideration of “spiritual abuse” within the Church of England under the Clergy Discipline Measure. The complaint is summarized as:

“[2]. … from the end of 2011/beginning of 2012 TD began to mentor W1 with such intensity and in such a manner that he was in breach of safeguarding procedures both of the national Church but also of the parish and that this amounted to spiritual abuse and thereby he is guilty of misconduct.”

Details of the charge are reproduced in Note [5] infra.

Spiritual abuse – Stowe and Maids Moreton

The term “spiritual abuse” is used extensively in the “lessons learnt” reviews of The Rev Timothy Davis and The Revd Michael Hall. From a strictly legal point of view, it is not relevant to the abuse of vulnerable parishioners in the parishes of Stowe and Maids Moreton, although there are many parallels in the nature of the abusive relationships. This concerned the abuse and murder of Peter Farquhar and abuse of Anne Moore-Martin by Ben Field and was featured in the television programme The Sixth Commandment.

Ben Field was not a clerk in Holy Orders and therefore not subject to the Clergy Discipline Measure (S7). The post of Deputy Churchwarden is not recognized in law, and therefore not subject to the S6A Churchwardens Measure 2001. However, the Safeguarding and Clergy Discipline Measure 2016 empowers a bishop to suspend a PCC members (and others, including churchwardens) where they are satisfied of a failure to comply with a requirement imposed by the Code of Practice on the safeguarding of children and vulnerable adults.

Spiritual abuse – Revd Michael Hall

In January 2020, a former member of the congregation of St Margaret’s, Tylers Green, High Wycombe took their own life. On learning of the death, the current vicar raised serious concerns with the diocesan safeguarding team about the past behaviour of the previous incumbent, Revd Michael Hall, towards members of the congregation including the deceased.

“During the time of Reverend Hall’s ministry, the term spiritual abuse was not in general use. Some of the congregation and victims/ survivors of Reverend Hall’s abuse did not recognise they were being abused. For some victims/survivors, it has only been more recently that they acknowledged they suffered what is now termed spiritual abuse”. [6.7]

This Learning Lessons Review (LLR) by Elaine and Patrick Hopkinson examines inter alia: how spiritual abuse was manifested and the emerging picture of the character and ministry of Revd Hall; understanding the nature of spiritual abuse and its recognition amongst congregations; people made vulnerable through spiritual abuse; and cultural factors and spiritual abuse. Chapter headings of the Hall Review are here.

As well as spiritually abusing the PCC and the congregation, there were examples of Reverend Hall acting in inappropriate, overbearing, threatening and intimidating ways towards representatives of the diocese, including senior clergy, the local parish and district councils and to the police [4.13].

In relation to the recognition amongst congregations of spiritual abuse, the Review comments:

“[8.5] Now there appears to be a greater awareness of spiritual abuse. The Diocese of Oxford has introduced complaints, safeguarding and bullying and harassment procedures since Reverend Hall’s ministry, but the challenge remains that it takes someone to recognise spiritual abuse and to complain or whistleblow. This may not happen if everyone is being seduced by a seemingly all-knowing and powerful figure, as they were by Reverend Hall. For all the reasons already discussed people may not recognise they are being abused. If churchwardens, the PCC and many of the congregation support an abusive vicar, as they did with Reverend Hall, there is a risk that abuse will not be reported.

[8.6] There is, therefore, a need for interventions which raise awareness of spiritual abuse, not just with clergy, PCCs, and other lay volunteers, but also with congregations, whose members may experience spiritual abuse currently or in the future. Awareness raising needs to include matters of grooming, seduction, power, dependency and manipulation.”

It further states:

“[16.3] The nature of the allegations against Reverend Hall were such that it would have been appropriate to have commenced disciplinary action against him. At the time of his ministry there was a system for clergy discipline operating under the Ecclesiastical Jurisdiction Measure 1963. This was, however, complex, elaborate, expensive and slow and was consequently seldom invoked”.

The Review notes that further work still needs to be done on recognising and responding to spiritual abuse; this includes raising awareness of spiritual abuse in church communities, in particular recognising its characteristics, which include psychological and emotional abuse, grooming, seduction, manipulation, the use of power and the creation of dependency. It makes 13 recommendations [6].

Reflecting on the Stowe and Maids Moreton review, the Hall Review comments:

“The review found that there were missed opportunities when concerns were raised about Ben Field during the discernment process which could have triggered greater challenge of his application for Ordination. The Director of Ordinands (DDO) made some cautious remarks about Ben Field’s personality, but it appears these were not picked up. There are similarities here with Reverend Hall in that on application to St Margaret’s Church, concerns raised in a reference written by a bishop in his existing diocese were not explored” [9.7].

“At the time systems in place did not require rigorous communication between people involved in providing psychological support or supervising applicants on placement. During sessions with Ben Field the Spiritual Director became concerned, but these were “confidential” in terms the processes that existed at the time. Ben Field refused to discuss with the Stowe Church Vicar some concerns raised by a parishioner about his sexual behaviour. This was a potential warning sign but at the time it was considered relatively immaterial” [9.8].

It indicates that following the Stowe and Maids Moreton case improvements were made, including the development of a more formal referral and reporting mechanism within the Diocese of Oxford when someone preparing for their discernment process is considered to require psychological assessment or therapeutic support, improved communication between the DDO and Diocesan Safeguarding Adviser and the introduction of the “traffic lights” system. Consequently there is a much greater likelihood now than there was in the late 1950s that a candidate of Reverend Hall’s character would be identified as a cause of concern through the discernment and training processes. Nevertheless,

“The candidate’s final report at the end of the training period will state whether they are suitable to be ordained. This is put as a recommendation to the sponsoring bishop. However, bishops may not accept recommendations from the discernment and training processes. There is no system of accountability and consequence for this. According to the Diocese of Oxford it would be very unlikely for a bishop not to accept the recommendations from these processes. However, as a further safeguard, the diocese may wish to consider making a recommendation to the national church for systems of greater accountability in case any future bishop should be minded (even with good reason) to override discernment and training recommendations” [9.10].

Comment

There have been significant changes in the legal landscape since the Reverend Peter Hall retired from St Margaret’s Church in April 2002; Common tenure was introduced in the Ecclesiastical Offices (Terms of Service) Measure 2009 and the associated Ministerial Development Review (MDR) were implemented in 2011; the Clergy Disciplinary Measure (CDM) 2003 came into force in 2006. However, despite the improvements in safeguarding and understanding of “spiritual/clergy abuse”, more work is necessary, and the Clergy Conduct Measure – the replacement of the Clergy Discipline Measure – is unlikely to be in place before July 2024.

The Update, circulated with the papers for the Group of Sessions for the meeting of General Synod at Church House on 23 to 27 February 2024, gave the draft revised timetable for this work as:

Report Stage and Revision in Synod July 2024; Final Drafting and Final Approval in Synod February 2025; Parliamentary Process and Royal Assent Spring 2025; Implementation Period & Training Spring – Winter 2025; the New Measure coming into operation, early 2026. 

Notes

[1] The Learning Reviews undertaken by the Diocese of Oxford are: