Williamson v Bishop of London
[2020] EWHC 3518 (Admin)
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.
Fapte
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.
Rezumatul hotărârii
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.
Citate cheie
"The clergy discipline procedures are amenable to judicial review. The established Church is subject to the rule of law."
— Swift J
Tratament ulterior
Confirms the supervisory role of the secular courts over Church of England disciplinary procedures.