An earlier post reviewed the penalty of Deposition from Holy Orders, (more commonly known as “defrocking” or “unfrocking”[1], [2]), with regard to its reintroduction within the Church of England under the Clergy Conduct Measure;  the penalty continues to be an option in Wales, Scotland and Ireland.  This post relates to its use by the Church in Wales; subsequently we will consider the position in Scotland and Ireland.

Church in Wales

The powers of sentence open to Disciplinary Tribunals in the Church in Wales are set out at Paragraph 18 of Chapter IX of the Constitution of the Church in Wales. These range from the most minor, an absolute discharge, to the most serious, the deposition from Holy Orders and expulsion from the office of a Cleric in the Church in Wales.

Four of the recent determinations[3] cite the decision of the Provincial Court of the Church in Wales in the matter of the Reverend Clifford Smith Williams, for which the judgment was handed down on 1 November 1997[4]. Contemporary reports note that Williams was the first priest in the Church of Wales to be stripped of his office, on account of a six-year adulterous affair, that he had lied under oath and had not once expressed any regret or remorse.

Recent determinations

The Church in Wales website includes links to recent Decisions and Penalties for which the President of the Tribunal has ordered details to be published. However, these range from a single paragraph to 12 pages in length. With the exception of The Rev Ryan Forey, all of these current Determinations concern clergy who have been deposed from Holy Orders and expelled them from the office of Cleric in the Church in Wales. These decisions are summarized below.

Anthony Pierce – February 2026. Decision

On February 7th 2025, Anthony Pierce, the former Bishop of Swansea and Brecon from 1999 until 2008, appeared at Swansea Crown Court and admitted five counts of indecent assault on a male child under the age of 16. The offences dated from between 1985 and 1990, when Mr Pierce was a parish priest in West Cross, Swansea.

This was the first occasion on which the Church in Wales found itself in the circumstance of deposing a Bishop from their Orders. Section 42 of Chapter IX of the Constitution envisages the duty falling to the Bishop of the Diocese where the cleric holds, or last held, office. It does not make separate provision for Bishops, although a Bishop clearly falls within the Constitutional definition of a Cleric. However, the Tribunal was mindful that powers of deprivation of Bishops (and other disciplinary sanctions) were vested in the Metropolitan prior to disestablishment [5]. “For the avoidance of doubt and uncertainty”, the Tribunal stated it believed the appropriate way forward was for the Archbishop and the Diocesan Bishop jointly to execute a deed of deposition.

The Tribunal directed the then Archbishop of Wales, jointly with the Diocesan Bishop of Swansea and Brecon, to depose the Right Reverend Anthony Edward Pierce from Holy Orders and to expel him from the office of Cleric in the Church in Wales [21], and noted the effects of a deed of deposition:

[22]. … Section 42 (3) of Chapter IX of the Constitution state that the effects of a deed of deposition are the same as a deed of relinquishment. Such effects are set out in the Canon to amend the Canon Law Relating to Clerical Disabilities dated 19 April 1990. The effects include [emphasis in original]:

(a) he or she shall be incapable of officiating or acting in any manner as a cleric of the Church in Wales, and of taking or holding any preferment therein, and shall cease to enjoy all rights, privileges, advantages, and exemptions attached to the office of cleric in the Church in Wales;

 (b) every licence, office, and place held by him or her for which it is by law an indispensable qualification that the holder thereof should be a cleric of the Church in Wales shall be ipso facto determined and void;

[23]. In essence, the individual is returned to the status of a lay person in the eyes of the Church in Wales with effect from the date of the deposition. A deposition does not call into question the validity and lawfulness of Episcopal actions previously undertaken by a deposed Bishop (such as Confirmations and Ordinations).

The Church in Wales issued a statement which made it clear that when the offences were reported to the church’s safeguarding team in 2023, they were passed directly to police, while the church also immediately began an internal investigation into the background to the case. Proceedings relating to the former Bishop have been covered in a number of posts [6].

Samuel Erlandson – February 2026, Decision; 3pp

On 29 April 2025 the Bishop of St Asaph referred to the Disciplinary Tribunal of the Church in Wales the matter of Reverend Samuel Erlandson, a Clerk in Holy Orders; the grounds for the referral were that Mr Erlandson had, between 19 June 2024 and 22 November 2024, engaged in conduct giving just cause for scandal or offence contrary to Chapter IX, Paragraph 9(c) of the Constitution of the Church in Wales [1].

On 23 November 2024, the Respondent pleaded guilty to 3 offences of possessing indecent images and was sentenced by the Llandudno Magistrates Court to 32 weeks imprisonment, suspended for 18 months together with ancillary requirements; He was placed on the Sex Offenders Register for 10 years [2]. The convictions relate to a period between 19 June 2024 and 22 November 2024 and the making indecent images of children and the possession of extreme pornographic images [3].

The Reference from the Bishop enclosed the relevant certification of conviction from the civil authorities, and under S(4) Chapter IX of the Constitution the preliminary stage of the Tribunal Proceedings was dispensed with and the matter set down for full hearing on 3 November 2025 [4].

On 28 November 2024, the Church issued a Statement which indicated that immediately following his arrest, Mr Erlandson’s permission to officiate as a cleric was removed, prior to consideration by the Church in Wales Disciplinary Tribunal.

In accordance with Rule 31 of the Tribunal’s Rules, a certificate of conviction for a criminal offence from a secular court is treated as conclusive proof that the acts therein specified were committed by the person named in the certificate. The burden on the Proctor is therefore to prove that the conduct set out in the certificate gives just cause for scandal or offence [5]. Following the decision in the matter of the Reverend Clifford Smith Williams, supra, the Provincial Court decided that for an offence alleging just cause for scandal or offence to be proved, the Tribunal must be satisfied of three matters [8]. It had to be satisfied that:

• there was a course of conduct knowingly entered upon by the Respondent;
• the course of conduct must, in the eyes of the Church, be judged to be inherently wrong; and
• the course of conduct must bring such discredit upon the Respondent and the Church that, in the eyes of a person of reasonably robust persuasion, such a person would describe it as scandalous or offensive.

The Panel found find the charge proved [10] and was unanimous that only the most serious sanctions available to the Tribunal would be appropriate in a case of this nature [12].

 Andrew Robinson – February 2026; 3pp

In the case of The Reverend Andrew Robinson, despite his retirement in 2014, the Tribunal retained jurisdiction over him under Section 9 of Chapter IX of the Constitution, because he held a permission to officiate in his retirement, including during the time of the conduct giving rise to the complaint [8].

A Statement from the Church in Wales reported that at the Merthyr Tydfil Magistrates Court, Robinson admitted to offences relating to indecent images of children: 13 cases of possession/making category A images of children: 20 cases of Possession/making category B images of children; 196 cases of Possession/making category C images of children; and 327 cases of Possession/making prohibited images of children.

He was sentenced to a 12 week custodial sentence, suspended for 2 years. He is also subject to a Sexual Harm Prevention order for 2 years. His PTO was immediately withdrawn once police brought their investigation to the attention of the Church in Wales Safeguarding Team in January 2024 prior to consideration by the Church in Wales Disciplinary Tribunal.

Ryan Forey – August 2025. Decision; 12pp

The following summary of the case was posted by 4-5 Gray’s Inn Square, the Chambers of Peter Saville who acted as Proctor for the Church in Wales.

“A monition with conditions for his future ministry was imposed by the tribunal after Mr Forey entered admissions to all charges. The misconduct found by the tribunal included payments of charitable funds to Mr Forey and his household as the chair of charitable trustees of St Teilos Church (Aka “Citizen Church”) Cardiff; the lack of GDPR and safeguarding compliance of an app launched by Citizen Church and championed by Mr Forey, and the formation of a Church outside the Church in Wales whilst Mr Forey was still licensed in his role as vicar of Citizen.

The Judgment is notable for its highly unusual factual matrix in the disciplinary prosecution in the the Ecclesiastical Courts and for including charges brought under paragraph 9(d) of Chapter IX, Paragraph of the Constitution of the Church in Wales – wilful disobedience to or breach of the provisions of the Constitution or of the Statement of Terms of Service published pursuant to the Clergy Terms of Service Canon 2010.”

The determination Disciplinary Tribunal, Church in Wales: Rev Ryan Forey concerns three distinct elements,  Annex B, relating to: financial issues; the management of safeguarding matters; and establishing a church outside the Church in Wales (known as Be Church, Cardiff) and held or accepted the position of pastor without the consent of his Bishop. The Tribunal imposed a monition with a number of conditions that must be satisfied before consideration can be given to putting the Respondent in charge of a church organisation with ultimate responsibility.

Jason Kennett-Orpwood – October 2024, Details of Penalty.

“The Disciplinary Tribunal of the Church in Wales has directed that the Reverend Jason Kennett-Orpwood be deposed from Holy Orders and expelled from the office of Cleric in the Church in Wales, following a hearing on 30 October 2024. Mr Kennett-Orpwood, who has not been in active ministry since 1999, admitted a charge of conduct giving just cause for scandal or offence following a criminal conviction at Llandudno Magistrates’ Court on 2 August 2023”.

“Mae Tribiwnlys Disgyblu’r Eglwys yng Nghymru wedi gorchymyn i’r Parchedig Jason Kennett-Orpwood gael ei ddiarddel o’r Urddau Sanctaidd a’i ddiarddel o swydd  Clerigwr yn yr Eglwys yng Nghymru, yn dilyn gwrandawiad ar 30 Hydref 2024. Fe  wnaeth Mr Kennett-Orpwood, sydd heb fod mewn gweinidogaeth weithredol ers 1999, gyfaddef cyhuddiad o ymddygiad gan roi achos cyfiawn am sgandal neu drosedd yn dilyn euogfarn droseddol yn Llys Ynadon Llandudno ar 2 Awst 2023”.

Further information is on the National Sex Offenders Register (NSOR) here which includes a link to a media report.

Nigel Cahill – August/October 2021. Details of Penalty; 1 page. 

IN THE DISCIPLINARY TRIBUNAL OF THE CHURCH IN WALES: RE THE REVEREND NIGEL CAHILL

Following a hearing which took place on 5 August 2021, the Disciplinary Tribunal of the Church in Wales ordered that the Reverend Nigel Cahill, formerly Rector in the Rectorial Benefice of Aberavon, be deposed from Holy Orders and expelled from the office of Cleric  in the Church in Wales. The Tribunal found a charge of ‘conduct giving just cause for scandal or offence’ proved, following his conviction for two offences of making indecent images of  children contrary to the Protection of Children Act 1978.

11th August 2021

JMH Powell QC

President, Church in Wales Disciplinary Tribunal

NOTIFICATION OF DEPOSITION FROM HOLY ORDERS: RE NIGEL CAHILL

No appeal to the sentence imposed by the Disciplinary Tribunal of the Church in Wales was lodged within the time limits prescribed in the Constitution of the Church in Wales. The Bishop of Llandaff therefore executed a deed deposing Nigel Cahill from Holy Orders on 23 September 2021. The deed of deposition was enrolled in the Registry of the Archbishop of Wales on 4 October 2021.

6th October 2021

M J Chinery

Deputy Registrar to the Archbishop of Wales

Nigel Cahill: Notification of Deposition from Holy Orders

Comment

The Crown Prosecution Office provides guidance, inter alia, on Indecent and Prohibited Images of Children. The offence of making computer-generated indecent images involves creating or distributing images that simulate sexual activity, often involving children or individuals who appear to be children. These images are considered illegal under the Protection of Children Act 1978 and the Criminal Justice and Immigration Act 2008. The law criminalises the possession, distribution, and creation of such images to protect children from exploitation and abuse. Offenders can face severe penalties, including imprisonment, fines, and registration as sex offenders. The legal system prioritizes the safeguarding of children, and prosecuting those involved in the creation, possession, or distribution of such material.

[1] An overview of the term “defrocking” is given by Wikipedia. It is not used Anglican Canon Law, and “laicization” is often, but incorrectly, associated Roman Catholic Canon Law. However, “deposition from Holy Orders” does not make for a snappily-titled headline, and within this post the term “Deposition” will be used.

[2] In his post What’s with all this “defrocking” lingo? Dr Ed Peters comments: “Since the advent of the Johanno-Pauline Code in 1983, the correct phrase to denote the most severe expiatory penalty the Church can impose on a deacon, priest, or bishop is “dismissal from the clerical state” (1983 CIC 1336.1, n. 5). Even the term “laicization”, used for a while after Vatican II to soften the harsh rendering of Latin’s degradatio as “degradation”, is generally avoided today as it seems to imply that the lay state itself is some sort of punishment”.

[3] Anthony Pierce – February 2026, Decision; Samuel Erlandson – February 2026, Decision; Andrew Robinson – February 2026, Decision; Ryan Forey – August 2025. Decision; Jason Kennett-Orpwood – October 2024, Details of Penalty; Nigel Cahill – August/October 2021. Details of Penalty. 

[4] See Thomas Glyn Watkin, Welsh Church Courts and the Rule of Law, Ecclesiastical Law Journal [2000] 5 (27) 460-469. Reference 19 states “As the Welsh bishops are not corporations sole, the case was technically between the Right Reverend Barry Morgan and the Reverend Clifford Williams, [1998] EWCA Civ J1023. It was held, in civil law, that in disciplinary cases, the authority of the courts of the Church in Wales, as a voluntary association, is based on consensual submission to their jurisdiction; they are private bodies and not susceptible to judicial review”. The provincial bodies have no interest other than in providing the judicial mechanisms for its resolution.

[5] Reference (1) of the Decision states: See Halsbury’s Laws of England (1st edition, 1910), Ecclesiastical volume, para 726.

[6] Safeguarding in the Church in Wales: Anthony Pierce, (27 February 2025); Church in Wales statement on Anthony Pierce sentence, (12 March 2025); Anthony Pierce Review published, (26 February 2026); Anthony Pierce, judgment, (17 November 2025).