ANGLICAN CHURCHES. 



conclusion : " If I give a title to a person to 

 whom it does not belong, I am liable to a 

 charge of flattering him, and of wronging 

 those to whom the title does belong. For 

 such reasons as these I have abstained from 

 giving the title of " Reverend " to Wesleyan- 

 preachers, not (I need hardly say) from any 

 feeling of disparagement toward them, but be- 

 cause I honor consistency and truth, and be- 

 cause I am sure they would despise me if I 

 acted against my conscience and were to prac- 

 tise the kind of liberality which courts popu- 

 larity by giving away what does not belong 

 to it." 



Mr. Keet brought the subject before the 

 Wesleyan Conference of 1874, and it was re- 

 ferred by that body to a committee to take 

 such action in reference to it as should be 

 thought fit. It was decided that the question 

 of the right of Wesleyan ministers to the use 

 of the title " Reverend " should be pressed by 

 means of a suit in the civil courts for a faculty 

 permitting the erection of the tombstone. The 

 case was begun in the Consistory Court of the 

 diocese. The Chancellor, Mr. Phillimore, de- 

 cided in June adversely to the right of the 

 complainants, sustaining in general terms the 

 views which had been expressed by the Bishop 

 of Lincoln, and declaring in addition that " a 

 Wesleyan minister is and professes to be noth- 

 ing else than a schismatic and a leader of 

 schismatics." An appeal was then taken to 

 the Court of Arches. The dean of this court, 

 July 31st, pronounced a decision sustaining 

 that of the court below, and supporting it by 

 the additional argument that the rector had an 

 absolute control over all structures proposed 

 to be placed in the churchyard. On this point 

 the dean said : 



" The churchyard is the freehold of the in- 

 cumbent, subject to the right of the parish- 

 ioner or the stranger happening to die in the 

 parish to simple interment, but to no more. 

 Indeed, the incumbent has the right to pasture 

 animals which do not injure the bodies interred 

 in the churchyard, and every gravestone, of 

 course, interferes with that pasturage. The 

 incumbent for this, as for other more impor- 

 tant reasons, has a prima facie right to pro- 

 hibit altogether the placing of any gravestone, 

 or to permit it on proper conditions, such as 

 those which relate to the size and character of 

 the stone, the legality and the propriety of the 

 inscription upon it, or the payment of a prop- 

 er fee. Usage, indeed, has much favored the 

 placing of such stones, and, as a general rule, 

 the incumbent permits them; while the exer- 

 cise of his right of refusal has become, or per- 

 haps always was, subject to the control of the 

 ordinary." 



The dean in his decision quoted the letter 

 written by the Bishop of Lincoln to Mr. Keet, 

 approving all of its positions, and concluded : " I 

 do not think that it would be proper or conso- 

 nant to practice that this court should overrule 

 not only the direct dissent of the incumbent, 



but also the deliberate judgment and authority 

 of the bishop in a matter, not of state law appli- 

 cable to all cases, but of discretionary permis- 

 sion, applicable to the particular case ; and I 

 think that in refusing to do so I act in accord- 

 ance with the spirit both of the general law 

 and of those rubrics in the Book of Common 

 Prayer which relate to the authority of the 

 ordinary. I decline to issue the faculty as now 

 prayed." 



An appeal was taken to the Judicial Com- 

 mittee of the Privy Council. 



The Right to exclude from the Communion in 

 Case of Heresy. A suit was brought in 1874 

 by Mr. Henry Jenkins, a parishioner of Christ 

 Church, Clifton, against the Rev. Flavel Cook, 

 vicar of the parish, for illegally refusing to ad- 

 minister the sacrament of the Holy Commun- 

 ion to him. The vicar having preached a ser- 

 mon on future punishment, Mr. Jenkins wrote 

 him a letter protesting against the doctrines 

 which he had announced. The vicar was 



Srompted to inquire iuto the character of Mr. 

 enkins's faith, and found that he disbelieved 

 the doctrines of future punishment and of the 

 personality of the devil, that he had published 

 a book of selections from the Bible, from 

 which all passages inconsistent with his views 

 were excluded, and that he regarded a great 

 number of passages in the Scriptures as "in 

 their generally received sense quite incompat- 

 ible with religion or decency." On the ground 

 of the avowal of these doctrines the vicar ex- 

 cluded Mr. Jenkins from the sacrament, as 

 being in the sense of the canon and rubrics of 

 the Prayer-Book "an evil-liver," and a "hin- 

 derer and slanderer of God's "Word." The 

 case was carried by Mr. Jenkins to the Court 

 of Arches. A decision was given, July 17th, 

 by Sir Robert Phillimore, dean of that court, 

 sustaining the position and course of the vicar. 

 Mr. Jenkins then took an appeal to the Privy 

 Council. 



Increase of the Episcopate. A bill provid- 

 ing for the increase of the Episcopate in the 

 Church of England was passed by the House 

 of Lords early in the session of Parliament. 

 It was passed to a second reading in the House 

 of Commons, but its further progress was op- 

 posed by dilatory motions, and the House 

 adjourned without finally acting upon it. Mr. 

 Beresford Hope gave notice that he should raise 

 the question again the next year, when he hoped 

 the subject would be properly discussed. He 

 had presented a petition on the subject, signed 

 by four or five thousand clergymen, a propor- 

 tion of nearly one-quarter of the clergy of the 

 Church of England. 



Coadjutor Bishops in India. Arrangements 

 were completed early in September for in- 

 creasing the number of bishops in India, by 

 the appointment of coadjutor bishops. Efforts 

 to effect this purpose had been making for 

 some time, but were opposed by difficulties, 

 the chief of which were legal ones. It was 

 found that these could be overcome by conse- 



