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UK Law Reference
All Cases
Ecclesiastical Law
High Court (Administrative Court)
2020
England & Wales

Williamson v Bishop of London

[2020] EWHC 3518 (Admin)

Independent editorial summary — not the official judgment. Read the full judgment via the source link.

Ratio Decidendi

Clergy discipline decisions under the Clergy Discipline Measure 2003 are amenable to judicial review where procedural unfairness or error of law is alleged, though the court will give appropriate respect to the ecclesiastical tribunals' expertise.

Facts

A Church of England priest challenged a disciplinary penalty imposed on him. He argued the process had been procedurally unfair and that the Bishop's tribunal had made errors of law in reaching its decision.

Judgment Summary

The High Court held that clergy discipline proceedings were subject to judicial review on conventional grounds. However, the court applied a degree of deference to the ecclesiastical tribunal's assessment of matters within its expertise and found no grounds to quash the decision.

Key Quotes

"The clergy discipline procedures are amenable to judicial review. The established Church is subject to the rule of law."

Swift J

Subsequent Treatment

Followed

Confirms the supervisory role of the secular courts over Church of England disciplinary procedures.

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