Randall v Trent College

The Revd Dr Bernard Randall, an Anglican priest, was employed as the College’s Chaplain. In May 2019, he delivered two sermons to the pupils about “competing ideologies”, which led to his summary dismissal on 30 August 2019. On appeal, he was reinstated, subject to compliance with various management instructions, but he was made redundant. In Mr B Randall v Trent College Ltd & Ors [2023] UKET 2600288/2020, he claimed harassment, direct discrimination on grounds of religion or belief, victimisation and unfair dismissal – and was unsuccessful. We reported the judgment here.

It has now been reported that HHJ James Tayler has ruled that the previous decision was unsafe and has remitted the case to the Employment Tribunal for a rehearing. His judgment is not yet available; if and when it is, we will publish a note.

Mandatory reporting of child sexual abuse

The Explanatory Notes to the Crime and Policing Bill include the following on mandatory reporting:

“Duty to report child sex offences

67. In its final report to the Government (October 2022), the Independent Inquiry into Child Sexual Abuse recommended the introduction of a ‘mandatory reporting’ regime for child sexual abuse in England. Work which had been undertaken to implement this recommendation fell in May 2024 upon dissolution of Parliament ahead of a General Election. On 6 January 2025, the Home Secretary announced that the Government would introduce mandatory reporting of child sexual abuse in England through the Crime and Policing Bill.

68. Chapter 2 of Part 5 gives effect to the mandatory reporting duty. It places a requirement on adults engaged in certain roles in England to report promptly to the police or local authority when they are made aware of child sexual abuse; either by being told about it by a child or perpetrator or witnessing the abuse themselves. If they fail to do so, they may be referred to their professional regulator (where applicable) or the Disclosure and Barring Service, who will consider their suitability to continue working in regulated activity with children. Clause 52 also creates a new criminal offence of preventing or deterring a person from complying with their reporting duty.”

Church of Scotland (Lord High Commissioner) Bill

On Tuesday, the Church of Scotland (Lord High Commissioner) Bill completed its Commons stages in double-quick time, without amendment. It now goes to the Lords. (And see Eliot Wilson’s comment piece below.)

The Charity Commission and freedom of expression

In answer to a written question from Lord Moylan (Con), “To ask His Majesty’s Government, following the recent case of Gary Mond, what steps they are taking to ensure that the Charity Commission is respecting the right to free speech”, Baroness Twycross, Parliamentary Under-Secretary of State at DCMS, replied as follows:

“The Charity Commission’s role as the independent regulator of charities in England and Wales is to ensure that charity trustees comply with their duties as set out in charity law. The Charity Commission has published guidance for trustees on the use of social media( and managing the risks for charities. The Charity Commission notes the Tribunal’s judgment in this recent case and is considering what lessons can be applied to future casework.”

We noted the Mond case (in which the Charity Commission lost) here. 

Anglican Canon Law webinar

The International Consortium for Law and Religion Studies (ICLARS), an international network of scholars and experts on law and religion, has announced a webinar which will be hosted by the Ecclesiastical Law Society. It will address Anglican Canon Law, “a topic which is frequently misunderstood and misrepresented, de-mythologising its nature, sources and functioning”, and will explore the structure of the Anglican Communion as a loose federation of autonomous national or regional Churches, the so-called Instruments of Unity which seek to hold the uneasy tension between member Provinces, and the lack of any global juridical or enforcement provisions. 

The webinar will be chaired by  Professor Mark Hill KC, and will examine lawmaking in the Anglican Communion, particularly the creation and amendment of Constitutions and Canons, and tell the story of the drafting of Principles of Canon Law Common to the Churches of the Anglican Communion, advocating their utility in the promotion of ecumenism. The panel will comprise Professor Norman Doe, Professor of Law at Cardiff University, Rt Revd Dr Vicentia Refiloe Kgabe, Bishop of Diocese of Lesotho in the Anglican Church of South Africa, and Ven Alan Perry, General Secretary of the Anglican Church of Canada.

A Practical Pathway to Net Zero Carbon for Churches

The Church of England has issued A Practical Pathway to Net Zero Carbon for Churches – a digital practical guide which features a handy flowchart, a list of heating solutions and a checklist. The Table (pp 7 to 12) provides a useful indication of whether faculty authority is required or if applications fall within Lists A and B. 

Private prosecutions in England & Wales

Hardly anything to do with “religion” (though it might possibly come into play in a case of alleged sexual abuse), but the Ministry of Justice has announced a consultation on private prosecutions: Oversight and regulation of private prosecutors in the criminal justice system consultation. The announcement points to the Great Post Office Scandal and the quashing of “thousands of convictions for railway fare evasion offences”. Further:

“… there is no coordinated oversight or scrutiny of the steps private prosecutors must take before commencing a prosecution. There are also no quality assurance processes to ensure that private prosecutors are taking proper account of whether a prosecution is in the public interest. The Government is clear that, if we are going to prevent future failures, we must address these issues as a matter of urgency.”

In Scotland, anyone wishing to bring a private prosecution must first seek a bill of criminal letters from the High Court, which will only be granted in exceptional circumstances. Might it be time for something similar south of the border?

Date of Easter

Along with photos of choristers tossing pancakes and a sudden interest for aspects of “ashing”, the beginning of Lent is the time for commentators to demand the commencement of the Easter Act 1928, an issue on which we have posted earlier, here, and here. This year is significant in that, as in 2010, 2011, 2014, and 2017, the calendars of the Eastern and Western Christian churches coincide – when the full moon following the equinox comes so late that it counts as the first full moon after 21 March in the Julian calendar as well as the Gregorian. In his blog, Bosco Peters explains the complex calculations in his recent post A Common Easter which expresses the hope that as part of marking the 1700th anniversary of the Council of Nicaea, the vast majority of Christians will (again) from 2025 celebrate a common date of Easter – conscious that probably small minorities will continue current practices.

Quick links

• Government of Canada: The  Canadian Guide to Understanding and Combatting Islamophobia: For a more inclusive Canada.
• Eliot Wilson, Substack: Parliament considers the Church of Scotland—briefly…: on the Church of Scotland (Lord High Commissioner) Bill currently before Parliament.

And finally…I

From Thailand: Donoghue v Stevenson 2025???

And finally…II

This week, Robert Jenrick, MP for Newark and Shadow Lord Chancellor & Secretary of State for Justice, opined, “Above the Old Bailey sits a statue of Lady Justice. She wears a blindfold, because justice must be blind to colour, religion or sex“. Against this assertion, Scott Wortley responded: “Some swine’s taken her blindfold Bob”…”Hang on. Maybe she has never worn a blindfold. What could that mean?”

The Wikipedia entry Lady Justice provides the solution.