formularies, as ratified, with certain explanations, by divers Acts of Assembly in the years 1645, 1646, and particularly in 1647, this church continues till this day to acknowledge as her subordinate standards of doctrine, worship and government."[11] In 1858 circumstances arose which, in the opinion of many, seemed fitted to demonstrate to the Free Church that her freedom was an illusion, and that all her sacrifices had been made in vain. John Macmillan, minister of Cardross, accused of immorality, had been tried and found guilty by the Free Presbytery of Dumbarton. Appeal having been taken to the synod, an attempt was there made to revive one particular charge, of which he had been finally acquitted by the presbytery; and this attempt was successful in the General Assembly. That ultimate court of review did not confine itself to the points appealed, but went into the merits of the whole case as it had originally come before the presbytery. The result was a sentence of suspension. Macmillan, believing that the Assembly had acted with some irregularity, applied to the court of session for an interdict against the execution of that sentence; and for this act he was summoned to the bar of the Assembly to say whether or not it was the case that he had thus appealed. Having answered in the affirmative, he was deposed on the spot. Forthwith he raised a new action (his previous application for an interdict had been refused) concluding for reduction of the spiritual sentence of deposition and for substantial damages. The defences lodged by the Free Church were to the effect that the civil courts had no right to review and reduce spiritual sentences, or to decide whether the General Assembly of the Free Church had acted irregularly or not. Judgments adverse to the defenders were delivered on these points; and appeals were taken to the House of Lords. But before the case could be heard there, the lord president took an opportunity in the court of session to point out to the pursuer that, inasmuch as the particular General Assembly against which the action was brought had ceased to exist, it could not therefore be made in any circumstances to pay damages, and that the action of reduction of the spiritual sentence, being only auxiliary to the claim of damages, ought therefore to be dismissed. He further pointed out that Macmillan might obtain redress in another way, should he be able to prove malice against individuals. Very soon after this deliverance of the lord president, the case as it had stood against the Free Church was withdrawn, and Macmillan gave notice of an action of a wholly different kind. But this last was not persevered in. The appeals which had been taken to the House of Lords were, in these circumstances, also departed from by the Free Church. The case did not advance sufficiently to show how far the courts of law would be prepared to go in the direction of recognizing voluntary tribunals and a kind of secondary exclusive jurisdiction