The fiercest struggle took place in England. Henry II did not deny the right of the Church to jurisdiction over her members; but he demanded that clerks found guilty of grave crime should be unfrocked by the ecclesiastical court, and that then, being no longer clerks, they should be handed over to the royal officers, by whom they should be punished according to their deserts. Archbishop Thomas Becket answered that it was contrary to justice and the Canon Law that a man should be punished twice for the same offence; that the punishment by the Church involved the offender's damnation and was therefore quite adequate; and that finally he himself was officially bound to defend the liberties of the Church even to the death. Henry II attempted to solve the difficulty by issuing the Constitutions of Clarendon (1164), the third clause of which decreed that the royal officer should determine whether any matter in which a clerk was concerned should be tried in the secular or the ecclesiastical court, and that even if it went to the latter, the King's officer should be present at the hearing. As the price, however, of his reconciliation with the Papacy after Becket's death, Henry was obliged to withdraw the Constitutions. The position of the Church on this question was clearly stated by Pope Celestine III in 1192. If a clerk had been lawfully convicted of theft, homicide, perjury, or any capital crime, he should be degraded by the ecclesiastical judge; for the next offence he should be punished by excommunication, and for the next by anathema; then, since the Church could do no more, for any subsequent offence he might be handed over to the secular power to be punished by exile or in any other lawful manner. This, of course, was a direct licence to the ill-disposed clergy to commit more crimes than were allowable for a layman; but the laity had to proceed cautiously in opposing it. In 1219 Philip II of France demanded that a clerk who had been degraded should not be protected by the Church from seizure outside ecclesiastical precincts by the royal officers with a view to his trial in a secular court. But here again, both at his coronation as Emperor in 1220 and again in the code of laws drawn up for his kingdom of Sicily in 1231, Frederick II confirmed the privileges of the Church in the matter of jurisdiction. On the latter occasion, however, he did reserve cases of high treason for the royal court. Almost the only immediate effect of these protests on the part of the State was that Popes and Councils enjoined on the ecclesiastical courts greater severity of treatment of offenders, even to the extent of perpetual imprisonment in the case of those whom the lay tribunals would have condemned to death. [Sidenote: Increase of ecclesiastical jurisdiction.]