ANGLICAN CHURCHES. 



ceased, to permit the corpse to be committed 

 to the grave in the churchyard of the parish 

 without hymn, anthem, or address of any 

 kind." The tipper House had voted that 

 hymns should be permitted at the grave. A 

 conference of the two houses was held, with 

 a view to the adjustment of the difference be- 

 tween them on this point, but without success. 

 A gravamen was signed by members of both 

 houses deploring the barbarities alleged to have 

 been exercised by the Mohammedans toward 

 the Christians in Bulgaria, and the asserted 

 sale of Christian children into slavery, and pray- 

 ing " that effectual steps will be taken by the 

 Government, in conjunction with the Porte 

 and others, to prevent, as far as possible, such 

 grievous scandal and offense to Christendom 

 and the civilized world." The Committee on 

 Intemperance presented a supplementary re- 

 port to the effect that the time had come when 

 Parliament might properly be urged to take 

 into consideration the further regulation of 

 the traffic in intoxicating drinks, and suggest- 

 ing that new legislation ought to embrace some 

 or all of the following points : 



The extinction of grocers' excise licenses ; the 

 gradual suppression of houses for the sale of beer to 

 be consumed on the premises ; the gradual reduc- 

 tion of the number of public-houses until a limit 

 shall have been reached which shall correspond to 

 the wants of a temperate population ; a large restric- 

 tion of hours for Sunday traffic, together with some 

 measure for country places for earlier closing at 

 night and earlier opening in the morning ; and the 

 admission of the principle of local control so far as 

 to give the inhabitants of any locality some voice in 

 the question of granting new licenses, of reducing 

 the number of houses, of Sunday closing, of earlier 

 or later opening, and of earlier closing on week- 

 days. 



The Convocation of York met in York Ca- 

 thedral, February 15th. It considered the 

 fourth report of the Ritual Commission. The 

 Upper House rejected the addition to the 

 Athanasian Creed in the form of a synodical 

 declaration which had been agreed to in 1874 

 by the Convocation of Canterbury and the 

 Lower House of the Convocation of York. 

 (For the text of this declaration, see the AN- 

 NUAL CYCLOPAEDIA for 1874.) 



At the Judicial Committee of the Privy 

 Council, January 19th, a special court was 

 constituted for the hearing of an appeal from 

 the Arches Court of Canterbury, in the case 

 of Jenkins vs. the Rev. Flavel Smith Cook, 

 rector of Christ Church, Clifton. In this case 

 the question was raised whether a parishioner 

 could be legally refused the Holy Communion 

 because he did not believe in the personality 

 of Satan and evil spirits, and the doctrine of 

 eternal punishment. Mr. Jenkins had several 

 years before compiled a book of selections 

 from the Bible for devotional uses, from which 

 were omitted all allusions to the doctrines of 

 the existence of the devil and eternal punish- 

 ment. On July 5, 1874, Mr. Cook preached a 

 sermon on "Rationalism," co which Mr. Jen- 

 kins took exceptions, and against which he 



wrote the minister a letter of protest. Mr. 

 Cook then gave Mr. Jenkins warning that he 

 would consider a depraver of the Book of 

 Common Prayer a hinderer and slanderer of 

 God's word, and "open and notorious evil 

 liver," and would refuse to administer the 

 communion to him. Mr. Jenkins, after having 

 been refused the communion several times, 

 brought suit against Mr. Cook in the ecclesias- 

 tical courts. The lower courts sustained the 

 vicar, and Mr. Jenkins appealed to her Majesty 

 in Privy Council. The judgment of the latter 

 court was given February 15th, and reversed 

 the decisions of the lower courts. Their lord- 

 ships held that the evidence did not sustain 

 the allegation that the appellant entertained 

 the doctrines attributed to him, and expressly 

 declared that they did not mean to decide that 

 thosd doctrines were otherwise than incon- 

 sistent with the formularies of the Church of 

 England. 



The only cause, they said, which will warrant a 

 minister under the rubric in repelling u parishioner 

 from the Holy Communion is that he is an " open 

 and notorious evil liver," who thereby gives offense 

 to the congregation ; and the only cause which will 

 warrant his repulsion under the 27th canon is that 

 he is a " common and notorious depraver of the 

 Book of Common Prayer." It became necessary, 

 therefore, to consider whether the appellant came 

 under both or either of these descriptions. As to 

 the first, there was absolutely ho evidence whatever 

 that the appellant was an evil liver, much less an 

 open and notorious evil liver. The term " evil 

 liver," according to the natural use of tlie words, 

 was limited to moral conduct, and the distinction 

 between conduct and belief was clearly recognized 

 in the canons, especially in the contrast between the 

 109th and 110th. As to the charge against the ap- 

 pellant of being a depraver of the Book of Common 

 Prayer, this was founded on the fact of his having 

 published a book of selections from the Bible for 

 reading at family prayer, from which certain parts 

 were omitted, as was alleged, on the ground of the 

 doctrine which they teach ; and it was argued that. 

 as some of the parts so omitted were either founa 

 in the Book of Common Prayer or were the support 

 of doctrines found in that book, omission of them 

 was equivalent to rejection, and rejection of them 

 to depravation of the Book of Common Prayer. In 

 none of these propositions nor in their logical con- 

 nection could their lordships concur. Omission was 

 not rejection, otherwise the lectionary in the Prayer 

 Book would be open to the grave charge. Nor was 

 it possible to establish the charge of depravation 

 upon these omissions, even coupled with the letter 

 written by the appellant to the respondent in justifi- 

 cation of them. For even if there were anything 

 in the letter which amounted to a depravation of the 

 Book of Common Prayer, which their lordships did 

 not suggest or think there was, it would be still im- 

 possible to hold that the writing of such a letter in 

 answer to one addressed to him by the respondent 

 in other words, not an open and spontaneous, but a, 

 private, friendly, and solicited communication 

 could make the appellant a " common and notorious 

 depraver of the Book of Common Prayer." They 

 would therefore advise her Majesty to reverse the 

 sentence of the Dean of Arches, and in remitting 

 the cause to admonish the respondent, the Eev. 

 Flavel Smith Cook, for having without lawful cause 

 refused to deliver to the appellant, or permit the 

 appellant to receive, the elements of the Holy Com- 

 munion ; and further, to monish him to refrain fro in 

 committing the like offense in future. 



