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, Annals of Early Life, p. 83). Early in the following year he spoke powerfully and at length both on the Irish Education Bill and on the Reform Bill. On the latter occasion Lord Grey, in reply, bade him ‘set his house in order,’ an expression for which he made the minister apologise. His pronounced resistance to the Reform Bill—he signed Wellington's protest—led to an attack by the Exeter mob on his episcopal palace, which his son garrisoned with coastguards. His opposition to the other ministerial measures—the Irish church temporalities bill, the ecclesiastical commission, and the new poor law—was hardly less active. To any reform of, or interference with, the church from without he was at all times opposed; least of all would he brook interference from the whigs. He resisted vehemently the act for the registration of marriages in 1836, and accused the whigs in his episcopal charge of having exhibited ‘treachery, aggravated by perjury’ (see Hansard, 3rd ser. xli. 145). He opposed the Ecclesiastical Discipline Bill in 1838, coming into conflict with Howley, the archbishop of Canterbury, in debate, attacked the conduct of the Irish education board (Hansard, xliii. 221, 1212), and to the last, year after year until it passed, he protested on religious grounds against the Irish Corporations Bill. Again, in 1841, he raised unsuccessfully the question of the catholic foundation of St. Sulpice in Canada, and subsequently fought against the commutation of tithes, the proposed foundation of an Anglican bishopric of Jerusalem, the Religious Opinions Bill in 1846, and the Deceased Wife's Sister Bill. He offered a strong opposition to Dr. Hampden's appointment to the see of Hereford in 1847, and it was by his efforts, with those of Samuel Wilberforce, bishop of Oxford, that, after some years of clerical agitation, convocation recovered its former consultative functions in 1853. On questions of politics, other than ecclesiastical, he often took views that were independent of party considerations. He was probably the only leading tory who was opposed, at its inception, to the Crimean war.

The bishop came as a high churchman to a diocese long known for its evangelical temper, and as a disciplinarian to one not characterised by ecclesiastical strictness. He was, further, a man publicly accused of having changed his opinions to win preferment, and of having scandalously accumulated benefices in order to fill his pockets. Hence his clergy were in many cases ill-disposed towards him. It was in connection with protracted ecclesiastical litigation that during the major part of his episcopate he was best known. Sometimes these disputes related to patronage, sometimes to discipline; but the most notable were in effect trials for heresy or schism. In 1843 he began a suit in the court of arches against the Rev. John Shore, a clergyman in his diocese, who, in defiance of his warning and in consequence of personal disputes, was holding church services in an unlicensed building at Bridgetown, near Totnes. From that court to the privy council and to the queen's bench Mr. Shore took the case under various forms, always unsuccessfully. In the end, being unable to pay his costs, he went to prison, until he was released, on the bishop's foregoing part of his costs and the rest being paid by public subscription. With the Rev. H. E. Head, rector of Feniton, a low-church clergyman, the bishop also had a successful lawsuit. The Gorham case, originally a suit of duplex querela in the arches court, is of all the bishop's lawsuits the most famous, and arose in connection with Phillpotts's refusal to institute the Rev. G. C. Gorham to the living of Brampford Speke, to which he had been duly presented in 1847, on the ground that the presentee had failed to satisfy him as to his orthodoxy on the doctrine of baptism [see ]. The ultimate judgment, on appeal to the privy council, was adverse to the bishop, and Gorham was instituted (8 March 1850). Archbishop Sumner was stated to approve the decision. Phillpotts wrote to him in terms of great severity, protesting that the archbishop was supporting heresies, and threatening to hold no communion with him. He assembled a diocesan synod at Exeter to reaffirm the doctrine, which the privy council had held not to be obligatory on Gorham, and repeated his censure of the archbishop in his visitation in 1851. But he bore Gorham no personal ill-will, and liberally subscribed to the restoration of Gorham's church at Brampford Speke.

Phillpotts's episcopal activity was incessant and well directed, and in later life he became an open-handed giver. The 20,000l. to 30,000l. which his son publicly stated he had spent upon law during his lifetime ought to be balanced by the 10,000l. which he gave to found a theological college at Exeter, and the large sums which he devoted to the restoration of his cathedral and to the building of churches. He ardently supported one of the earliest sisterhoods, Miss Sellon's at Devonport (see, Life of Pusey, 3rd ed. iii. 194–200), and presented his valuable library to the clergy of Cornwall. After reaching the age of eighty Phillpotts ceased to