cuar.1] THE CHURCH IN THE DOMINIONS 1429 
and authority the Colony could be required to recognize, after 
the Colony or settlement had received legislative institutions. 
The Judicial Committee considered that this view was 
borne out by the course of legislation. Thus the bishopric 
of Calcutta was established under the authority of an Act 
of 1813; the additional bishoprics of Madras and Bombay 
were also established under an Act of 1833, both of which 
Acts conferred an ecclesiastical jurisdiction as far as necessary 
for administering holy ceremonies and for the superinten- 
dence and good government of the ministers of the Church 
establishment. In 1824 a bishop was appointed in Jamaica 
by letters patent, but his position was confirmed by a 
Colonial Act, which would have been improper unless the 
Law Officers of the Government had been satisfied that the 
Colonial statute was necessary to give effect to the establish- 
ment of the bishopric. Moreover, in England even under 
Henry VIII it was considered necessary to pass an Act to 
establish new Dbishoprics, and the same plan had been 
adopted in the case of the bishoprics of Manchester and Ripon. 
No doubt letters patent had long been issued conferring an 
ecclesiastical jurisdiction, but such letters patent were no 
doubt inadvertent copies of the instruments issued for India 
ander the provisions of an Act of Parliament! 
They also laid it down that the ecclesiastical law of England 
was not in force in a settled Colony,? and that therefore eccle- 
siastical jurisdiction could not be conferred even if the letters 
patent were sufficient in law to confer on Dr. Gray the 
ecclesiastical status of metropolitan, and to create between 
him and the Bishop of Natal the personal relations of 
* Historically this argument is certainly incorrect. 
* Save, of course, by legislation as in Prince Edward Island in 1802 
'43 Geo. IIL. c. 6), with a saving for dissenters. This Act stood until 
1879, when it was repealed (c. 18), an attempt in 1878 having proved 
abortive by delay in assent ; Provincial Legislation, 1867-95, pp. 1200-2. 
In New Brunswick the Church was not established, though favoured ; see 
Hannay, New Brunswick, i. 169 seq. In Nova Scotia the Church was 
by Act of 1758 established, and its position was one of great strength ; 
the bishop was a member of the Council ; it is no longer in this position ; 
see Rev. Stat., 1900, c. 109; Act 1911, c¢. 117. In the rest of Canada it 
was never established.