is a memorable accident that the strongest statement of King Henry’s divinely instituted headship of the church occurs in a statute which enables unordained doctors of the civil (not canon) law to exercise that plenitude of ecclesiastical jurisdiction which God has committed to the king (_Stat._ 37 Hen. VIII., c. 17). [Sidenote: _The Scotch Protestants and Justinian._] [32] _Foreign Calendar_, 1558-9, p. 8. This seems to mean that the normal and rightful relation of church to state is that which is to be discovered in Justinian’s books. If so, ‘the Protestants of Scotland’ soon afterwards changed their opinions under the teaching of Geneva and claimed for ‘the estate ecclesiastical’ a truly medieval independence. [Sidenote: _The Henrician doctors of law. ‘The king’s great matter.’_] [33] The following facts are taken from the _Dictionary of National Biography_. Cuthbert Tunstall (afterwards bishop of Durham) ‘graduated LL.D. at Padua.’ Stephen Gardiner (afterwards bishop of Winchester) of Trinity Hall, Cambridge, ‘proceeded doctor of the civil law in 1520 and of the canon law in the following year.… In 1524 he was appointed one of Sir Robert Rede’s lecturers in the University.’ Edmund Bonner of Broadgate Hall, Oxford, ‘in 1519 he took on two successive days (12 and 13 June) the degrees of bachelor of civil and of canon law.… On 12 July, 1525, he was admitted doctor of civil law.’ Thomas Thirlby (afterwards bishop of Ely) of Trinity Hall, Cambridge, ‘graduated bachelor of the civil law in 1521 … and proceeded doctor of the civil law in 1528 and doctor of the canon law in 1530.’ Richard Sampson (afterwards bishop of Lichfield) of Trinity Hall, Cambridge, ‘proceeded B.C.L. in 1505. Then he went for six years to Paris and Sens and returning proceeded D.C.L. in 1513.’ John Clerk (afterwards bishop of Bath and Wells, Master of the Rolls), ‘B.A. of Cambridge 1499 and M.A. 1502, studied law and received the doctor’s degree at Bologna.’ Richard Layton (afterwards dean of York) ‘was educated at Cambridge, where he proceeded B.C.L. in 1522 and afterwards LL.D.’ Thomas Legh of King’s College (?), Cambridge, ‘proceeded B.C.L. in 1527 and D.C.L. in 1531.’ Instances of legal degrees obtained in foreign universities are not very uncommon. John Taylor, Master of the Rolls in 1527, ‘graduated doctor of law at some foreign university, being incorporated at Cambridge in 1520 and at Oxford in 1522.’ James Denton, dean of Lichfield, proceeded B.A. in 1489 and M.A. in 1492 at Cambridge. ‘He subsequently studied canon law at Valencia in which faculty he became a doctor of the university there.’ (For an earlier instance, that of Thomas Alcock of Bologna, see _Grace Book A_, Luard Memorial, p. 209. There are other instances in Boase, _Register of the University of Oxford_; consult index under Padua, Bologna, Paris, Orleans, Bourges, Louvain.)