1436 THE CHURCH IN THE DOMINIONS [PART VII 
patent granted were really valid, which no doubt was the 
case. The Archbishop of Canterbury had no jurisdiction, in 
their opinion, to inquire into the doctrines of the bishop, and 
the Crown had no power to appoint commissioners, or the 
Privy Council to hear the action, for though the Crown was 
supreme over all causes ecclesiastical, it was so in no other 
sense and to no greater extent than in causes temporal, that 
is, by law and by means of the established Courts. The High 
Commission Court was illegal, and to refer the matter to the 
Privy Council under the Act of 1832 would be to re-establish 
the High Commission Court. A scire facias to revoke the 
letters patent would only apply to an improvident grant, 
and very possibly the letters patent were valid. There was, 
therefore, no Court which they considered capable of deciding 
the question of his holding or not holding heretical opinions. 
It is clear, however, from the remarks of the Master of the 
Rolls in the case of the Bishop of Natal v. Gladstone that 
the matter could have been settled by the trustees refusing to 
pay the bishop on the ground of his heretical opinions, when 
the matter would have been decided by the Court of Chancery 
and, on appeal, by the House of Lords. 
The decision of these cases once and for all made clear the 
position of Churches in the Colonies. It is still possible for 
a bishop to be consecrated by an archbishop of the English 
Church with the permission of the Crown for service in some 
place either in or without His Majesty’s dominions! but 
such consecration carries with it no grant of jurisdiction.’ 
The members of the Church of England in the place in 
question would be assumed to assent to the doctrines of the 
Church of England, and questions of civil right, depending 
on questions of doctrine would be decided by the principles 
of the Church of England. Such bishops are from time to 
time consecrated for service in the Crown Colonies and 
1 Cf. Anson, Law and Custom of the Constitution, IL ii, 247-9. 
* Nor is any special diocese assigned ; this was asked for by the Bishop 
of Sydney in 1872, but Lord Kimberley declined to change the practice ; 
see New Zealand Parl. Pap., 1872, A. 1a, p. 31. Cf. Hansard, ser. 3, 
clxxxvii, 256, 762; Adderley, Coloniul Policy, pp. 395 seq. ; Parl. Pap., 
H. C. 259 IL, p. 50. The title Lord Bishop is now incorrect, Parl. Pap. 
{. 3184. n. 7: Richt Rev. is used officially.