that the English Church in a self-governing colony is a voluntary association. Opposition to the dogmatic principle in the church was maintained. Some practices introduced by clergy desirous of bringing the services of the church to a higher level came before the judicial committee in the case of _Westerton_ v. _Liddell_ in 1857, with a result encouraging to the ritualists, as they then began to be called. An increase in ritual usages, such as eucharistic vestments, altar lights and incense, followed. In 1859-1860 disgraceful riots took place at St George's-in-the-East, London, where an advanced ritual was used. In 1860 the English Church Union was formed mainly to uphold high church doctrine and ritual, and assist clergy prosecuted for either cause, and in 1865 the Church Association, mainly to put down such doctrine and ritual by prosecution. A royal commission appointed in 1867 recommended that facilities should be granted for enabling parishioners aggrieved by ritual to gain redress, and in 1870 that a revised lectionary and a shortened form of service should be provided. A new lectionary was approved by the two convocations and enacted, and convocation having received letters of business in 1872 and 1874 drew up a shortened form of prayer which was also enacted, but the commission had no further direct results. Between 1867 and 1871 two decisions of the judicial committee were adverse to the ritualists, and by exciting dislike to the court among high churchmen indirectly led to an increase in ritual usages. Among those who adopted them were many self-devoted men; their practices, which they believed to be incumbent on them, were condemned as illegal, yet they saw the rubrics daily disregarded with impunity by others who trod the easy path of neglect. In 1873 a declaration against sacramental confession received the assent of the bishops, and in 1874 Archbishop Tait of Canterbury introduced a bill for enforcing the law on the ritualist clergy; it was transformed in committee, and was enacted as the Public Worship Regulation Act. It provided for the appointment of a new judge in place of the old ecclesiastical judges, the officials principal, of the two provinces. Litigation increased, the only check on prosecutions being the right of the bishop to veto proceedings, and in 1878-1881 four clergymen were imprisoned for disobedience to the orders of courts against whose jurisdiction they protested. In consequence of the scandal raised by this mode of dealing with spiritual causes, a royal commission on ecclesiastical courts was appointed in 1881, but its report in 1883 led to no results, and the bishops strove to mend matters by exercising their veto. Advanced and illegal usages became more frequent. Proceedings in respect of illegal ritual having been instituted against Bishop King of Lincoln, the archbishop of Canterbury (Benson) personally heard and decided the case in 1890, and his judgment