Systemic failures and pastoral vulnerability in a clergy discipline case

Re a complaint under the Clergy Discipline Measure 2003 before the Bishop’s Disciplinary Tribunal for the Diocese of Coventry concerned a complaint dated 25 January 2024 brought by the Acting Archdeacon Pastor for the Diocese of Coventry against the Revd Anne-Marie Marsh, a married woman recently divorced, who was accused of conduct unbecoming or inappropriate to the office and work of a clerk in Holy Orders within the meaning of s.8(1)(d) Clergy Discipline Measure 2003 “in that she engaged in an inappropriate relationship with Graham Slate, a man for whom she was pastorally responsible”.

Ms Marsh had been married for 27 years but was divorced in 2024 after enduring emotionally and physically abusive behaviour from her husband, culminating in an incident in which he grabbed her by the throat and threatened her with a kitchen knife [7]. Mr Slate had also been divorced in 2024 [8]. The diocese finally moved Mr Marsh into a vacant vicarage to get him out of Mrs Marsh’s way. Ms Marsh and Mr Slate had got to know each other between August and October 2023, when he attended a “Christianity Explored” course which she gave, and they maintained that their relationship had always been a platonic friendship [9]. The Designated Officer in the case, however, relied on various events and pieces of evidence to show that the relationship had been adulterous or inappropriate [10]. Her training incumbent, the Revd Mr Gold, had parked outside Ms Marsh’s house on three days in December 2023 between 11 pm and 6.45 am and had taken photographs which were produced to the tribunal which showed Mr Slate’s vehicles parked there overnight [33]. They explained that that he had parked there at her request to make it look as if she was not alone in the property because her estranged husband “had frightened her by coming to the house, taking photographs and sending them to her and peering through the windows etc” [34].

The Tribunal was satisfied that the relationship between the respondent and Mr Slate was not adulterous, nor was it:

“one of inappropriate proximity and emotional dependence such that it amounted to conduct unbecoming or inappropriate to the office and work of a clerk in Holy Orders. It was a close and supportive friendship which developed during a period of particular vulnerability” [44].

While Ms Marsh’s conduct might have exhibited “conspicuous naivety”, she had only been a priest for around 18 months at the time and “she had had, at best, inadequate support and guidance from her training incumbent during her curacy” [45].

The tribunal concluded with some critical remarks about the process underlying the complaint:

“47. We wish to close this determination by expressing concern about the route by which this matter came to be before this tribunal. False allegations, rumours and assumptions have been blindly accepted to create a situation where significant harm has been caused. Insufficient time has been taken to question motivations and perspectives, and questions which should have been asked have not been asked until too late. There are two instances which stand out sharply in this case.

48. First was the decision of the diocese to move the respondent’s abusive husband into a vacant vicarage within the parish in which she was working.

49. Second is the worrying acceptance without question of that husband’s allegations of an affair between the respondent and Mr Slate.

[…]

51. … We trust lessons will be learned and that the support that the respondent should have received from the Diocese of Coventry will now be provided to her in order to support her flourishing in her future ministry.”

Update, 8 August 2025: In the article Coventry diocese and Vicar criticised over handling of case founded on ‘false allegations and rumour’ against a curate, (Francis Martin, 8 August 2025), the Church Times reported (£):

“On Monday, a spokesperson for the diocese of Coventry said that it fully accepted the decision of the tribunal, and it was ‘grateful for the clarity that this had brought to a very difficult situation’.

‘The well-being of all those concerned is our priority at this time,’ the spokesperson continued. ‘We are in contact with those involved and they have our full support and prayers. The diocese acknowledges that there are learning points and is reflecting on how best to address these going forward.’

The new Bishop of Coventry, the Rt Revd Sophie Jelley, would be meeting Ms Ghosh ‘to discuss her future ministry’, the spokesperson said”.

Cite this article as: Frank Cranmer, "Systemic failures and pastoral vulnerability in a clergy discipline case" in Law & Religion UK, 1 August 2025, https://lawandreligionuk.com/2025/08/01/systemic-failures-and-pastoral-vulnerability-in-a-clergy-discipline-case/
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One thought on “Systemic failures and pastoral vulnerability in a clergy discipline case

  1. Your premise that;
    ‘Law & Religion UK was conceived as a forum for the academically-rigorous exploration of the interactions between law and religion – broadly defined – together with the human rights issues associated with them’.

    If you were academically rigorous you would have looked further into situation leading up to the tribunal. You would have researched the background and cited other works. Instead you have simply regurgitated the CDM determination, which was flawed. This is a lazy academic investigation and rides roughshod over the Human Rights of two people who were denigrated by a tribunal that did not have the authority to pass those judgments. Please in future be academically curious and rigorous in your research.

    There is no evidence in the tribunal determination for your statement;

    ‘…..culminating in an incident in which he grabbed her by the throat and threatened her with a kitchen knife.

    The tribunal states;

    ‘….culminated in an incident in July 2023 where Mr Marsh grabbed the respondent by the throat and grabbed a kitchen knife’.

    You have made an assumption, which if you’d have researched around the issues would have given you another take. Maybe in the heat of the argument and in fear of loosing 27 years of part of his life he was going to cut his wrists and end it all. Can you be sure he threatened his wife? If you can then why didn’t she call the police. To my knowledge no police report for that period of time was filed, please check your facts.

    You have again made an assumption in the following;
    Her training incumbent, the Revd Mr Gold, had parked outside Ms Marsh’s house on three days in December 2023 between 11 pm and 6.45 am and had taken photographs which were produced to the tribunal which showed Mr Slate’s vehicles parked there overnight [33].
    Paragraph [33] makes no reference to how Mr Gold arrived at the vicarage to take photos.
    The credibility of this work is disputable as I have demonstrated above I am disappointed that you do not seem to have prayerful reflected on this & used your stated premise, above, to measure your content against. I feel that to do the words law and academically-rigorous a disservice.
    Yours without prejudice Phil Clucas

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