In February 2022, we issued a post on a Bishop’s Disciplinary Tribunal in the Diocese of Southwark which addressed issues arising from a priest’s use of the “Like” function on his Twitter account[1]. In this case the Complainant was the Archdeacon of Reigate, Diocese of Southwark, and after serving a “Respondent’s answer to a Complaint” in the appropriate format, the Respondent did not engage any further with the process[2].
A more recent CDM determination, The Revd Samuel Cross (June 2026) considered a different aspect of social media usage by clergy. Extensive material from WhatsApp and Snapchat assisted the court’s analysis of the relationship between the parties.
The CDM proceedings brought against the Reverend Samuel Cross arose out of a complaint by Person A (“the Complainant”) on 29 November 2024. By a decision dated 18 June 2025 the Deputy President of Tribunals referred the following charge to the Bishop’s Disciplinary Tribunal for determination: that the Respondent’s conduct was unbecoming or inappropriate to the office and work of a clerk in Holy Orders within S8(1)(d) Clergy Discipline Measure 2003 in that:
(a) Being a married man, he engaged in a sexual relationship with the Complainant Person A from in or about October 2021 until January 2023; (b) After January 2023, he continued to engage in an inappropriate relationship with the said complainant and by his actions failed to maintain any or any proper professional or pastoral boundary, and; (c) Throughout the period of the parties’ relationship, between about October 2021 and January 2024, he behaved towards the said complainant in a manner which was coercive and controlling.
The Respondent had been the vicar of St Thomas, St Andrew and St Philip, Kensal Town, in the Diocese of London since 2017. He married in 2014 and separated from his former wife in October 2021. They were divorced on 20 January 2023.
The Complainant lived as a lodger at the vicarage from August 2021. She was baptised in the parish in December 2021 and confirmed in June 2022. Initially she was a university student but then became employed by the Diocese as an apprentice children’s worker in the parish in September 2022. She left her employment sometime in the spring in 2024.
At the time of the alleged misconduct, it was alleged that the Respondent was, variously, the Complainant’s priest, partner, landlord and line manager, with responsibility for supervision at work [5].
The Tribunal had regard to the Guidelines for the Professional Conduct of the Clergy (2015) and also Canon C 26 – Of the manner of life of clerks in Holy Orders[7]. Its description of the circumstance [emphasis added] as:
“[8] … a sad case where, in the Tribunal’s view, the relationship between the Complainant (“Person A”) and the Respondent (vicar of St Thomas, St Andrew and St Philip, Kensal Town, Diocese of London) had inappropriate features from the beginning, sometime in the Autumn 2021 until it ended in January 2024. Evidentially this case is unusual in that the whole course of the relationship is tracked across 1000 pages of WhatsApp messages between the couple from the start until the end and further messages between the Complainant and [another priest and his wife].
A further complication was that although initially the Complainant paid rent, which apparently went to fund the organist, there came a time, in February 2022, when she stopped paying rent altogether[21].
One of the Complainant’s concerns was that she took on an increasing level of responsibility for the running of the vicarage, including looking after a menagerie of animals that they, particularly, the Respondent had acquired. One of the animals was the Respondent’s dog, Marshall, to whom he was very attached; however it was aggressive, biting the Complainant on more than one occasion necessitating outpatient treatment, and was put down in April 2023 at the insistence of the Complainant, “which may well have been terminal for their relationship”[14].
The Tribunal observed “The evidence from the parties [was] directly contradictory[8]”, although such is the nature of prolonged WhatsApp exchanges, “[o]n several occasions [the Respondent] let his guard down”; on 4 February 2022, he sent the Complainant a message at 01:25 asking if he could he join her to which she replied BYOP, (i.e. bring your own pillow). In addition to the 1000 pages of WhatsApp messages, there were screenshots from Snapchat and photographs for the whole period of the relationship[17].
The Tribunal concluded [19] that the contemporaneous records supported the Complainant’s evidence that there was a sexual relationship between the Complainant and the Respondent…The Tribunal rejected the Respondent’s answer in oral evidence that he did not respond to messages of a sexual nature, which he considered were more appropriate to discuss with the Complainant in person and not reply on WhatsApp. It added [21]: “If there was any lingering doubt about the matter, the Snapchat messages and photographs tell the same story”.
The Tribunal considered that the Complainant gave her evidence…with clarity and confidence in a quiet and persuasive manner. It accepts her evidence regarding the nature of the sexual relationship she had with the Respondent in its entirety, however, it did not accept that the relationship was coercive and controlling [22]. However, it rejected the Respondent’s evidence regarding the sexual nature of the relationship and found that he consistently lied in these proceedings both in his witness statements and oral evidence[24].
The fact that the Respondent has lied to this tribunal is consistent with how he deliberately chose to deceive his church about his relationship with the Complainant, keeping it private from the churchwardens, PCC and other members of the clergy[25]. The Tribunal concluded:
“[28]. …mindful that that the burden of proof is on the Designated Officer, who bring this case on behalf of the Complainant, and that the standard of proof is that applied in civil proceedings, namely on the balance of probabilities, the tribunal finds that heads of charge (a) and (b) laid against the Respondent are proved and (c) is dismissed. The Respondent’s counsel accepted that if the tribunal found that the parties had engaged in sexual intercourse before the Respondent’s divorce in January 2023 then that would amount to conduct unbecoming.
The Tribunal stated that in its view, the Respondent was highly culpable in permitting the sexual relationship with the Complainant to develop, indeed inappropriate messaging began even before she moved into the Rectory. The relationship was inappropriate from close to the outset. It also noted a number of aggravating factors:
- the Respondent’s sexual relationship with the Complainant was undertaken over a prolonged period of 15 or so months from shortly after she moved into the Rectory until his divorce was finalised in January 2023 [6].
- there was a power imbalance between the Respondent and the Complainant in circumstances where he was aware that she was a vulnerable person with mental health issues, having dropped out of university. The Tribunal considered it was important to take into account that he was a parish priest and she was a student lodger living in his home [7].
- a further aggravating factor was the covert nature of the relationship which continued until it ended in January 2024. The Complainant made clear the harm that she suffered to her psychological state both before and after the relationship ended [8].
The Tribunal considered carefully the submissions of Ms Gyane (Counsel for the Respondent), particularly in relation to the Respondent’s own history of mental health issues. They have taken into account that he was of previous good character, and that the relationship was probably not destructive of the Respondent’s marriage and did not involve anybody else’s marriage, or indeed, have a detrimental impact on children. The character references were supportive of the Respondent being a capable and effective parish priest in a difficult area [9]. It noted:
“The Tribunal was concerned that the Respondent had failed to show any insight or remorse about entering into a sexual relationship with the Complainant whilst he was still married. Such insight as he has shown related to his failure to inform persons in authority in his church that he was in a romantic relationship with the Complainant…. [10]”.
“In the circumstances of this case, the Tribunal agreed that the only proportionate penalties open to it were a limited period of prohibition or prohibition for life. It did not consider that any of the other penalties adequately reflected the seriousness of the matters found proved. Ms Gyane accepted that the threshold for prohibition has been passed. [It] considered the view expressed by the Acting Bishop of London that a limited prohibition of three years is an appropriate sanction. Whilst this may have been appropriate where the Respondent had admitted the matters found proved but not where the matters had been denied throughout [11].
The Tribunal expressed its concern whether, in the absence of the Respondent’s insight and remorse, he will be able to resume public ministry in the future. On balance, it considered that there is such a possibility but only after appropriate pastoral, training and other necessary support, and after a long period of reflection over his past behaviour[12]. It concluded:
“[13]….the appropriate penalty that it should impose is a prohibition for a period of years from the date of this decision. It also directed that the Respondent should be removed from office as the incumbent of St Thomas, St Andrew and St Philip, Kensal Town, in the Diocese of London”.
Note
Some of the more explicit details of the relationship between the Respondent and the Claimant have been omitted.
[1] As from 13 June 2024, the “Like” capability on X/Twitter ceased to be accessible to others apart from the person “Liking” a particular Tweet.
[2] “He did not attend the hearing. An order was made in accordance with Rule 42 of the Clergy Discipline Rules that the tribunal should proceed in his absence, the Chair being satisfied that the Respondent had been properly made aware of the hearing and did not attend through choice[2]”. See also Non-involvement with CDM proceedings (II).