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opinion; (5) The Court is not compelled to affix a definite meaning to any article (»).

As to what amounts to a sufficient revocation within the statute is dealt with in the cases of The Procurator-General v. Stone (1808) (s), and Heath v. Burder (1862) (t), in which it is said that a statement which amounts to a mere promise of future silence, but no revocation of past error, is not sufficient, nor is a mere expression of regret. There must be formal

. revocation; but it may be doubted whether this would be held to be correct since the alteration in the mode of assent.

The following are the most important cases which have been decided on the construction of the Articles :

In Breeks v. Woolfrey (1838) (u), it was held that prayers for the dead do not necessarily constitute a part of the doctrine of purgatory, and therefore do not contravene Article 22 or the Homily on Prayer (x). It has, however, been held over and over again in the English Law Courts that prayers for the dead are “superstitious”under 1 Edw. 6, c. 14, and gifts for them void on that ground (y). In Elphinstone v. Purchas (1870) (2), it was held that the insertion of a prayer for a deceased person into the Communion Service was illegal, but apparently because it was an additional rite. Also that it was illegal to give notice that next day there would be “a mortuary celebration for the repose of a sister." The prayers

for the deceased in the Burial Service which were contained in the 1st Edwardian Prayer Book have been omitted in all subsequent editions.

In Hodgson v. Oakeley (1845) (a), it was held that to maintain all Roman doctrine necessarily contravenes the Articles, and therefore no particular article need be specified.

In the Gorham case (1850), it was held that regeneration


(r) Voysey v. Noble (1871), 3 L. R. P. C. 357; Hodgson v. Oakeley (1845), 1 Robertson, 322.

(s) i Hagg. Cons. 424.

(1) 15 Moo. P. C. 1; 8 Jur. N. S. 597.

(u) i Curteis, 880.
(x) Cf. "

Essays and Reviews" cases, post.

(3) L. R. 3 A. & E. 98.
(a) Ubi supra.

does not necessarily accompany the sacrament of baptism. See further as to this under BAPTISM.

In Heath v. Burder (1862) (6), it was held to be contradictory to Article 11 to explain justification to be “ by the faith of Jesus himself," and not by our faith in Jesus.

Also Articles 2 and 31 are contravened by a statement that “God is propitiated by Christ, but Christ's blood has long ago been poured out not to propitiate His kind and benevolent Father, but to bring men to His Father again.” Also by rejecting as darkening and confusing the expressions "guilt of sin,” “ satisfaction."

Also Articles 8, 16, and 27 are contravened by a statement that " forgiveness of sins has nothing to do with the Gospel," although it is admitted that there is “remission” of sins.

On the other hand, it is allowable to reject the phrases " going to heaven," "going to hell,” “immortality of the soul,” as such rejection does not necessarily dispute the doctrine of everlasting life as it appears in the creeds.

In the “Essays and Revieroscases (1863) (c) it was held that on matters of doctrine on which the Church has prescribed no rule, there is so far freedom of opinion that they may be discussed without penal consequences. It is allowable to say that the Bible is an “expression of devout reason,” and “the written voice of the congregation,” when coupled with such words as the following as to the Holy Spirit, “If such a spirit did not dwell in the Church the Bible would not be inspired.” “The sacred writers acknowledge themselves men of like passions with ourselves, and we are promised illumination from the spirit which dwelt in them.” It must not be taken that such phraseology denies the Bible to be the word of God (d).

Article 11 is silent as to the merits of Jesus Christ being transferred to us; therefore it is not penal to speak of merit

(6) Ubi sup.

(c) Williams v. Salisbury, and Wil. son v. Fendall, 2 Moore, P. C. N. S.


(d) Pages 425-427.

as it

by transfer as a “fiction," however unseemly the word may be (e).

Although Article 6 says that “Holy Scripture containeth all things necessary to salvation,” it does not say that every part of Holy Scripture is inspired. This latter proposition is not to be found in any formulary of the Church, and it is allowable to deny it (s).

As to the future life, the following passages are not contrary to Church doctrine :-“We must rather entertain a hope that there shall be found after the great adjudication receptacles suitable for those who shall be infants, not as to years of terrestrial life, but as to spiritual development nurseries, were, .. where the stunted may become strong and the perverted be restored. . . . And when the Christian Church in all its branches shall have fulfilled its sublunary office, and its founder shall have surrendered his kingdom to the Great Father—all, both small and great, shall find a refuge in the bosom of the Universal Parent, to repose, or be quickened into higher life, in the ages to come, according to His will.” As to this, the Court said that the passages contained no denial that at the end of the world there will be a judgment. And after referring to the Apostles' and Nicene Creeds, the Absolution, Burial Service, Catechism, Commination Service, and Athanasian Creed, their lordships said that they did not find in these formularies any such distinct declaration of our Church, as to the eternity of final punishment, as to require them to condemn as penal the expression of hope by a clergyman that even the ultimate pardon of the wicked who are condemned in the day of judgment may be consistent with the will of Almighty God (9).

It will be observed that all the above cases were decided before the year 1865, when the change was made in terms of the subscription to the Articles.

The case of Sheppard v. Bennett (1871) (h) decided that the following statements contravened the Articles, viz. :—“That (e) 2 Moo, P. C. N. s.


(9) Ibid. p. 433. ) Ibid. p. 430.

(1) L. R. 4 P. C. 371.


there is a real, actual, and visible presence of the Lord upon the altars of our churches”; “who myself adore, and teach the people to adore, the consecrated elements, believing Christ to be in them-believing that under their veil is the sacred body and blood of our Lord and Saviour Jesus Christ.”

The following, however, though “rash and ill-judged, and perilously near a violation of the law,” do not sufficiently contravene the Articles as to render them penal :-(1) “In the sacrament of the Lord's Supper there is an actual (spiritual) presence of the true (spiritual) body and blood of our Lord in the consecrated bread and wine, by virtue of, and upon the consecration, without or external to the communicant, irrespective of the faith and worthiness of the communicant, and separately from the act of reception by the communicant; (2) that the communion table is an altar of sacrifice at which the priest appears in a sacerdotal position at the celebration of the Holy Communion, and that at such celebration there is a great sacrifice or offering of our Lord by the ministering priest, in which the mediation of our Lord ascends from the altar to plead for the sins of men ”; (3) " adoration is due to Christ (spiritually) present upon the altar .... in the sacra

) ment, under the form of bread and wine, on the ground that under their veil is the (spiritual) body and blood of our Lord.”

In order to make these statements legal, the word spiritual must be understood, as it is unlawful in terms to allege a corporal presence of the natural body of Christ in the elements, or that the body of Christ is present in a corporal or natural manner. (See PRESENCE.)

In Voysey v. Noble (1870) (i), it was held that it is not competent for any clergyman of his own mere will, not founding himself upon any critical inquiry, but simply upon his own taste and judgment, to assert that whole passages of some of the canonical books are without any authority what


(i) L. R. 3 P. C. 357.

ever, as being contrary to the teaching of Christ as contained in others of the canonical books.

The following passages (k) were held contradictory to the Articles:"He (the Saviour) never hinted at such a doctrine as that of the fall of man, or the atonement by sacrifice, or justification by faith. He never taught that men needed to be accounted righteous before God, or needed any mediator to propitiate His wrath, or to draw them to Himself. All these notions were Jewish, and Christ never gave any sanction or encouragement to them that I have been able to discover.” “To us, God is a father, and we are His children; and if this be true, it sweeps away the dusty cobwebs of mediation, intercession, sacramental sacrifice, and all the sacred and consecrated follies which grow out of it. We want neither altar nor sacrifice, neither victim nor priest, no sprinkling of blood, or fumes of burning incense, to render our approach to the mercy seat of God more reverent or more successful.” “Sincere sorrow for sin is, or ought to be, enough to make a man quite reconciled and at peace with God; at least, so our Lord teaches. We do not therefore need any atonement or justification. We need no atonement, for God requires none."

“The very idea of Incarnation itself, which means Deity coming from heaven and dwelling in an individual man for some years, implies a belief that God does not, nor never did, dwell in the hearts of all men. This belief, and a belief in other miracles, are not peculiar to Christianity; they are common to all the religions of the world. The Brahmins have their nine incarnations of Vishnu, which, in their way, are splendid conceptions of Divine love and sympathy."

" The revelation of the knowledge of God by means of any book is impossible; all true knowledge of God comes directly from the law of God written in men's hearts."

BANKRUPTCY.-A clergyman may be made a bankrupt

(k) L. R. 3 P. C. pp. 388 et seg.

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