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 The English Law Courts. mittee of the Privy Council held — on very doubtful grounds, if we may respectfully say so — that they did. Mr. Mackonochie treated the decision of the Privy Council — which he regarded as a secular tribunal usurping spiritual functions — with scant respect, and a variety of subsequent proceedings — end ing in his practical removal from the incum bency of St. Albans, Holborn, where he had labored with such fi delity and success — were taken against him. The ways of the Church Association — which the late Bishop of Peter borough wittily dei scribed as the Church J Prosecution Co. Lim ited, — did not, how ever, prosper. On the one hand the Ritualists, strong in the goodness of their cause, set the de cisions of the Privy Council, in so far as these were adverse to them, at open de fiance. On the other hand the Privy Coun sm ROBERT cil not only blessed where the Church Association desired that they should curse, but put incidentally very effective weapons in the Ritualists' hands. To several of these we have already alluded. The most important of them all was however, by a strange irony of fortune, sup plied by Lord Cairns (who — an observa tion equally applicable to Lord Penzance — desired nothing more fervently than the extermination of Ritualism) in the case of Ridsdale v. Clifton (L. R. 2 P. D. 276). In that case it was argued that some of the points taken on behalf of the defendant had been concluded by the judgment of the Pri

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vy Council in Hebbert v. Purchas. Lord Cairns said : "Their lordships have had to con sider in the first place how far, in such a case as the present, a previous decision of this tribunal between other parties, and an order of the sovereign in council founded there on, should be held to be conclusive in all similar cases subsequently coming before them. ... In the case of decisions of final courts of appeal on questions of law affecting civil rights, especially rights of property, there are strong reasons for holding the decisions as a general rule to be final as to third parties. . . . Even as to such decisions it would perhaps be difficult to say that they were as to third parties under all cir cumstances and in all courts absolutely final, but they certain ly ought not to be reopened without the very greatest hesita tion. Their lordships are fully sensible of PHILLIMORE. the importance of establishing and maintaining, as far as possible, a clear and unvarying interpreta tion of rules the stringency and effect of which ought to be easily ascertained and understood by every clerk before his admis sion to holy orders. On the other hand, there are not, in cases of this description, any rights to the possession of property which can be supposed to have arisen by the course of previous decisions, and in pro ceedings which may come to assume a penal form, a tribunal even of last resort ought to be slow to exclude any fresh light which may be brought to bear upon the