THE ISSUES AT STAKE

The consequences of this accident have to be read within the context of the ecclesiastical politics of the time. Abbot is generally viewed as having been an unpopular archbishop.Footnote ³ He was probably the last Archbishop of Canterbury with a Calvinistic theological perspective and was succeeded in this see by the anti-Calvinist William Laud. Within hours of the accident the news had reached John Williams, who was bishop-elect of Lincoln as well as Lord Keeper of the Great Seal of England. In a letter dated 27 July 1621 Williams wrote to the Marquess of Buckingham to inform him that by this accidental homicide the archbishop had ‘by the common law of England’ forfeit all his estates and revenues to the king and also, by the canon law in force, been suspended from all ecclesiastical function.

Williams has been described as ‘Laud's opponent’.Footnote ⁶ He was also notoriously ambitious, as his accrual of ecclesiastical preferments shows.Footnote ⁷ The Royalist churchman and biographer of Laud, Peter Heylyn, believed that one of Bishop Lancelot Andrewes' principal reasons for being generous to Abbot – of whom he was not a natural ally – during the ensuing crisis was that if Abbot were deposed then Williams, who enjoyed great favour at court, could well have been elevated to the See of Canterbury in his place.Footnote ⁸ Heylyn suggested that Andrewes ‘knew too much’ about Williams and predicted ‘dangerous consequences’ were Williams to succeed to Canterbury. Heylyn points in evidence to another letter, not quoted, from Williams to the Marquess of Buckingham: ‘That his majesty had promised him upon the relinquishing of the Seal, one of the best places in this Church. And what place could be more agreable [sic] to his affection than the Chair of Canterbury?’Footnote ⁹

The potential irregularity of the Archbishop of Canterbury had practical consequences. There was the question of his lands and revenues and, importantly for his allies and opponents on the episcopal bench, the question of his carrying out episcopal functions. At the time four bishops, including Williams and Laud, had been elected to their office (in these cases the sees of Lincoln and St David's respectively) but had not yet received episcopal consecration.Footnote ¹⁰ The Archbishop of Canterbury, as metropolitan, enjoyed the ancient privilege of presiding at episcopal consecrations within his province but the bishops-elect did not wish to be consecrated by an archbishop who might have forfeited his appointment, or even his orders, as a result of having committed homicide.Footnote ¹¹

The questions that were asked at the time, and can be asked again now, were, first, whether Abbot had committed a canonical or common law offence leading to censure of some sort in the first place and, second, if he had, what remedy could be applied to restore him. While there are hints that Abbot's opponents would have liked him out of the way, the sources are unanimous in presenting the death as having been entirely accidental.Footnote ¹² No accusation of intent or negligence was levelled at the archbishop at the time. The first hearing of the facts of the case took place in the Coroner's Court. The verdict of the jury was that the keeper's death had occurred ‘by misfortune and his own fault’.Footnote ¹³ This is an unclear verdict, which Abbot initially sought to challenge, but for the purposes of this examination it is at least clear that no blame attached to the archbishop.Footnote ¹⁴

CRIME AND PUNISHMENT

The first question, then, is whether the archbishop had committed a common law offence. Today, or at any time since the Offences against the Person Act 1861, the archbishop would not have been held liable to punishment or forfeiture after killing another ‘by misfortune … without felony’.Footnote ¹⁵ However, there is a question as to when this distinction came to be made by the law.

The modern commentators John Baker and S F C Milsom are of the opinion that the common law was, in theory at least, very rigid on this matter at the time. There was no distinction in the common law between voluntary and involuntary homicide. The penalty for both, as with all felonies, was death by hanging. The change in the law that united the offences under one capital offence probably came about in the twelfth century, ‘though neither chronology nor mechanism is clear’.Footnote ¹⁶

Older commentators are not unanimous in their reading of the distinction, if any, between culpable and non-culpable homicide in the early part of the seventeenth century. Blackstone, writing in the eighteenth century, describes homicide as falling into categories of ‘justifiable, excusable and felonious’.Footnote ¹⁷ In the preface to the 1979 facsimile edition of Blackstone's commentaries, Thomas A Green suggests that ‘the distinction between murder and manslaughter, or between capital and non-capital homicide, was a product of the sixteenth century’.Footnote ¹⁸ Excusable homicide is divided into ‘per infortuniam, by misadventure; or se defenendo, upon a principle of self-preservation’,Footnote ¹⁹ the former being ‘where a man, doing a lawful act, without any intention of hurt, unfortunately kills another’.Footnote ²⁰ An involuntary killing arising out of an unlawful action is described as manslaughter.Footnote ²¹ So, for Blackstone, there is a distinction in the description of the homicide and, possibly, in the sanction to be applied, between one that arises from a lawful action and one that arises from an unlawful action. Such distinctions could well have been made in 1621 and, as will be seen, the lawfulness of Abbot's hunting was subject to detailed debate at the time.

Blackstone goes on to state that:

In support of the assertion that some guilt is applied even to the accidental killer, Blackstone points to the Old Testament and to the system whereby an accidental killer may flee to a certain city for asylum but that he may be caught and put to death by the victim's avengers before he gets there.Footnote ²³ He also notes the Roman practice for ‘casual homicide’ to be excused by the emperor under the sign manual and the Greek practice of voluntary banishment of the accidental killer.Footnote ²⁴ Finally, he draws attention to the English practice of pardons and writs of restitution being granted in such cases and also to judges directing acquittals where ‘the death has notoriously happened by misadventure or in self-defence’ and reports that the views of Coke and Hale differ on the punishment from which pardon is granted, the former saying that it is death and the latter forfeiture of goods.Footnote ²⁵

Blackstone's views largely follow those of Sir Matthew Hale in his Historia Placitorum Coronae. Once again this work dates from after the time of Abbot; it was left unfinished by Hale at his death in 1676 and not published until 1736. However, Hale's legal career started before the Civil Wars. Hale distinguishes between homicide that is voluntary (and in this he includes both murder and manslaughter), that which is purely involuntary and that which is ‘mixt’.Footnote ²⁶ Anticipating Blackstone he states that:

Again anticipating Blackstone, he distinguishes between an accidental death during a lawful hunt (homicide per infortunium) and accidental death arising from hunting illegally (manslaughter).Footnote ²⁸

An earlier source, Sir Edward Coke, died in 1634. In his Third Part of the Institutes of the Laws of England he differentiates between various categories of homicide, distinguishing as to whether or not they were voluntary, with malice aforethought or resulting from an illegal act. At the bottom of the pile was homicide that was involuntary, with no malice aforethought and resulting from an action that was legal. To illustrate this homicide per infortunium or seu casu he uses a remarkably apt example:

Coke himself intervened in the Abbot case; Bowyer states that the king relied on his opinion.Footnote ³⁰ That opinion was that it was lawful for a bishop to hunt – this being implicit, Coke explained, in the old rule that a bishop's pack of hunting dogs escheated to the crown.Footnote ³¹ The question of whether it was indeed lawful is discussed in greater detail below. The pardon readily given by the king and the verdict handed down by the coroner's jury must, if Coke's interpretation of the law of the time is correct, have assumed that Abbot was acting legally in being part of the hunt.Footnote ³² The result of it having been otherwise would have been the prospect of the Archbishop of Canterbury on a capital charge for murder.

Had Abbot committed a felony, there would have been ways in which he could have avoided censure or punishment. The most readily available in this case was royal pardon. Baker states that, under the common law, dating from before the rise of the mandatory death penalty, the life of the felon was at the king's mercy.Footnote ³³ Royal pardons had always been given, and mercy was (and remains) part of the royal prerogative.

Pollock and Maitland state that, while pardons were widespread or even invariable for certain categories of felony, they were actually necessary: ‘The man who commits homicide by misadventure or in self-defence deserves but needs a pardon.’Footnote ³⁴ However, Baker believes that ‘from the fourteenth century, many of those found before coroners to have killed by accident were probably not arraigned at all’.Footnote ³⁵ This was the case with George Abbot: he did not face trial for felony but was pardoned by the king after the verdict of the coroner.

As well as removing any suspicion of felony, the king's pardon removed from the archbishop any threat of forfeiture. There was certainly some discussion of the fate of his ‘temporalities’ in the aftermath of the accident.Footnote ³⁶ When the king gave Abbot a pardon, specific reference was made to the ‘remission and restitution of all forfeitures’,Footnote ³⁷ although there is no evidence that he was ever parted from his goods or his income between the accident on 21 July 1621 and the granting of the pardon on 20 November of the same year. Likewise, the dispensation granted to Abbot on the orders of the king refers to him being able to continue to have ‘enjoyment’ of his ‘office and archiepiscopacy’.

The distinction made by Coke between accidental death as a consequence of lawful action and as a consequence of unlawful action was an important distinction, traces of which are seen in later works.Footnote ³⁸ This distinction was also played out in the debate about the fate of Archbishop Abbot. The king was able to pardon felons on application (in July 1621 he took a long time to make up his mind whether to pardon a certain Richard Owen for the killing of a man called ButlerFootnote ³⁹) and could, by pardon, absolve Abbot from any blame under the common law and restore to him any goods forfeit. However, the threat of canonical irregularity, resulting in Abbot's being unable to fulfil his spiritual functions, hung over him during this time.

CANONICAL IRREGULARITY

It has been noted above that the bishops-elect, for whatever reason, refused consecration at Abbot's hands. The king was clearly less scrupulous about preachers than the bishops were about the minister of consecration, as he heard Abbot preach at court in September 1621.Footnote ⁴⁰ As already mentioned, there may have been political motivations behind the bishops' scruples but there is clear evidence that questions were asked about whether the archbishop had become in some way irregular (or even excommunicate) as a result of the accident. The matter was debated at the Sorbonne, resulting in Abbot being declared canonically irregular.Footnote ⁴¹ The famous lawyer and antiquary Sir Henry Spelman examined the case and found the same.Footnote ⁴² Coke, on the other hand, thought otherwise, as noted above.

The key texts in the argument about whether or not there was a canonical irregularity are the anonymous Apologie for Arch-Bishop Abbot, widely believed to have been written by Abbot himself,Footnote ⁴³ the response to this by Spelman and the opinion of Coke on the matter.

The Apologie sets out a number of pre-Reformation dicta pointing to accidental homicide not bringing about guilt. It reports that Azorius the Jesuit and Ivo of Chartres suggest that, provided the accidental killer is acting lawfully and with due care and attention, then they are innocent. It argues that this was the case with Abbot as ‘seen in the verdict of the coroner's inquest’. The Apologie then goes on to examine what became the key issue – whether hunting was illegal for clergy. If so, then Abbot would have been acting unlawfully and would therefore open himself up to censure – the homicide having come about through an illegal activity. The writer points to a mediaeval canon De Clerico Venatore, which was, apparently, used to show that clergy were prohibited from hunting. He goes on to dismantle this argument by systematically unpicking the authority of this canon. Gratian is said to have described the canon as ‘no better than chaff’ and to have pointed out that it was not, as claimed, promulgated by the Fourth Council of Orleans. Furthermore, the canon forbids hunting with hounds or hawks rather than with a bow, and forbids hunting publicly or as an occupation rather than as a private recreation.Footnote ⁴⁴

After this, the writer moves on to point to English statute law, and especially to the Henrician principle that no canon contrary to the laws or statutes of the realm or to the royal prerogative can have continued to be operational. He refers to mediaeval statutes such as the Charta de Foresta and a statute of Richard II that allowed archbishops and bishops to hunt and clergy with an income above ten pounds per year to keep hounds.Footnote ⁴⁵ This statute, the Act for Preventing the Unlawful Destruction of Game 1389 (not repealed until 1881), stated: ‘nor any Priest, nor other Clerk, if he be not advanced to the value of Ten Pounds by the Year, shall have or keep from henceforth’ hounds, ferrets or hunting equipment. The permission to hunt is therefore implicit in the exemption of clergy with higher incomes from the 1389 ban. The canons against hunting, consequently, could not be argued to affect an English bishop in 1621.

Sir Henry Spelman's An Answer to the Foregoing Apologie for Arch-Bishop Abbot is a lengthy contradiction of the Apologie. It seeks to rehabilitate the canon dismissed in the Apologie seemingly on the authority of Gratian and goes on to give further examples of how Abbot could have committed a canonical offence. For instance, Spelman bases a number of assertions on the fact that Abbot was hunting with a crossbow, suggesting that this is a dangerous weapon and consequently not permitted for a clerk; that arguments based on the legality of hunting as exercise and recreation are negated by the fact that firing a crossbow is neither; and that references to Archbishop Cranmer being taught to hunt are not relevant as Cranmer was taught using a longbow rather than a crossbow.Footnote ⁴⁶ He goes on to deal with the relationship between common and canon law on the matter, examining in detail the liberties given to clergy by the mediaeval statutes cited by the apologist. For instance, in dealing with the Charta de Foresta he states that the liberty to take a deer does not necessarily extend to a liberty to shoot it oneself. According to Spelman, the canon and the Charta are compatible and, pointing to the Charta's companion statute Magna Carta, he suggests that for Henry III to contradict the canon law when making the Charta de Foresta would have been contrary to the provisions of Magna Carta that the liberty of the Church shall be preserved.

Spelman does not offer any new evidence to support the assertion that Abbot had, by misadventure, rendered himself canonically irregular. He limits his writing to answering the points put forward in the Apologie. Coke, as noted above, agreed with the Apologie that references in positive law linking clergy with hunting made it unlikely that any canonical offence could have been committed.

The question of whether Abbot was felonious seems to rest, therefore, on whether the activity in which he was engaged at the time of the accident was itself legal. The legality of a bishop hunting in 1621 depends on the interpretation of the general condemnation of clerical hunting in the mediaeval canon law and its place in post-Reformation English law.

The most specific and authoritative condemnation of clerical hunting was issued by the Fourth Lateran Council of 1215, which stated: ‘We forbid all clerics to hunt or to fowl, so let them not presume to have dogs or birds for fowling’.Footnote ⁴⁷ Phillimore has claimed that the acts of this particular council have been considered as part of the ecclesiastical law of England.Footnote ⁴⁸ However, the Act for the Submission of the Clergy 1533, in limiting the authority of convocations, introduced the notion that pre-Reformation provincial ecclesiastical law had to be ‘not contrary or repugnant to the laws, statutes, and customs of this realm, nor to the damage or hurt of the King's prerogative royal’ in order to be continued after the Reformation.Footnote ⁴⁹ It is therefore arguable that, in a clash between the provisions of a canon of the Fourth Lateran Council and a contrary provision in the Charta de Foresta, the provision of the latter would prevail. In a similar vein, a prohibition may not satisfy the test laid down in the much later case of Bishop of Exeter v Marshall that pre-Reformation canon law, in order to be in force after the Reformation, must have been ‘received, observed, and acted upon in the Church of England since the Reformation’.Footnote ⁵⁰ The contemporary arguments do not provide examples of any clergy being disciplined for hunting in the relatively short span of years between 1533 and 1621.

THE SOLUTION

What the foregoing arguments and the result of the disputation of the bishops show is that there was considerable confusion about whether or not Abbot had become canonically irregular. It is unlikely that he was, as the hunting prohibition probably did not survive the Reformation, thus rendering the homicide an inculpable accident by the law of the day. However, it is important to note that there was both the will and the mechanism in place to soften the hard edge of the law had the archbishop been found to have been inhibited from his functions as a result of the homicide. The mechanism was a dispensation, the origins of the granting of which are ancient. Prior to the Reformation, bishops were able to grant dispensations to their subjects in certain areas (for example, in remitting the obligation to fast or permitting ordination below the minimum canonical age). However, appeals to Rome for dispensations in various matters reserved to the Holy See became a matter of Reformation controversy. The Ecclesiastical Licences Act 1533 was part of the package of Reformation statutes domesticating the law of the Church. Under this statute the rights of the Archbishop of York and other bishops to grant dispensations in customary areas was preservedFootnote ⁵¹ and the granting, or otherwise, of dispensations previously granted by the Pope or his legate was transferred to the Archbishop of Canterbury, under a certain amount of royal and parliamentary supervision.Footnote ⁵²

Dispensation in Abbot's case provided the removal of any taint or irregularity, or of the suspicion of the same. The result of the dispensation was that it would have been as if the accident had never happened; as such it was not in the same category as a dispensation which allows a person to do something that they would not otherwise be able to do. The treatment of the authority to grant such a dispensation is also interesting for this study. While the king had the power to pardon (and he did so in this case), he did not claim the authority to dispense, that authority having been given to the Archbishop of Canterbury under the Ecclesiastical Licences Act. In such a curious situation, prior to the Reformation the case of a homicidal archbishop would in all likelihood have been referred to Rome for determination. Consequently, after the Reformation the proper reference would have been to the archbishop himself, with the sanction of the king in Council, but the archbishop clearly could not determine his own case. A dispensation or absolution for an archbishop in such a situation does not appear on the list of dispensations habitually granted that can be found in the State Papers bound with Laud's trial papers.Footnote ⁵³ E F Churchill points to an example of a dispensation, or pardon, for a justifiable homicide in the Chancery Rolls of 1637 but does not record the fee, or fine, payable.Footnote ⁵⁴

The king's initial commission reported its findings to the king by letter dated 10 November 1621 as follows:

1. i. There was no majority of the six bishops and four lawyers either way on the question of canonical irregularity as the sources and authorities were confused;

2. ii. The majority held that there was no cause for scandal but that scandal might be seen ‘by the weak at home and the malicious abroad’;

3. iii. Restitution or dispensation might be granted by the king immediately under seal or by the hands of a clergyman delegated by the king or by some other means favoured by the king. The commission favoured a procedure whereby the archbishop sued the king for dispensation.Footnote ⁵⁵

What is clear from this and clear from the method used in the end is that the bishops did not claim the authority to dispense Abbot from any irregularity through their own individual or collective authority. There was no suggestion that a synod of bishops could be called to grant such a dispensation. Conversely, the king did not take up the suggestion that he grant a dispensation. The procedure used is in accordance with section 17 of the Ecclesiastical Licences Act, which determined that, should the archbishop default on the granting of a dispensation, then ‘the king may give power, by commission under the great seal, to two such spiritual prelates or persons as will do and grant the same’. In this case the archbishop's incapacity in the matter was due to his being the person requesting the dispensation.

The king asked eight bishops, rather than two, to fulfil this commission. The resulting dispensation was granted by the bishops collectively on the authority and command of the king. Abbot remained in post until his death in 1633, when he was succeeded by Laud. This story, as interesting as it is tragic, remains a curious footnote in the history of Church and State in the early Stuart period.

TRANSLATION OF THE TEXT OF THE DISPENSATION GRANTED TO GEORGE ABBOT, ARCHBISHOP OF CANTERBURY, 1621Footnote ⁵⁶

To the Most Reverend Father in Christ George, by divine providence Archbishop of Canterbury, Primate of All England and Metropolitan, from John, George, Lancelot, Samuel, Thomas, Arthur, Nicholas and George, by divine permission bishops respectively of Lincoln, London, Winchester, Norwich, Coventry and Lichfield, Bath and Wells, Ely, and Chichester, bishops of the Province of Canterbury. Grace and peace to you in God everlasting. We are in receipt of letters of commission from his most serene highness in Christ our Lord James by the grace of God King of England, Scotland, France and Ireland, Defender of the Faith etc delivered and directed to us under the great seal of England; the tenor of which is as follows:

‘James, by the Grace of God, King of England, Scotland, France and Ireland, Defender of the Faith etc to the Reverend Father in Christ our greatly beloved and trusty counsellor, John, Bishop of Lincoln, Keeper of our great seal of England, to the Reverend Father in Christ George, Bishop of London, to the Reverend Father in Christ, our greatly beloved and trusted counsellor Lancelot, Bishop of Winchester, also to the Reverend Fathers in Christ Samuel of Norwich, Thomas of Coventry and Lichfield, Nicholas of Ely, Arthur of Bath and Wells and George of Chichester, bishops of their respective sees, health and grace.

‘In humble supplication to us, the Most Reverend Father in Christ, our greatly beloved and trusted counsellor, George, Archbishop of Canterbury, explained that when recently in a certain park called Bramzil Park at Bramzil in our County of Southampton, being asked and invited by an honourable gentleman the owner of this same park, he intended to shoot a deer with an arrow, giving due care that no danger from this should come to anyone; it nevertheless happened by chance that the arrow he had shot and aimed at a wild beast, struck a certain Peter Hawkins at that time keeper of the aforesaid park, who was improvidently and carelessly exposing himself to the danger of being struck by an arrow, and was running headlong across a place where he could not be seen by the said Archbishop; it wounded the man's arm, and indeed as a result of this wound in less than the space of one hour he was breathing his last; and although because of the accidental nature of this kind of homicide, it happening through no fault of the aforesaid Archbishop but through the rashness of the slain man himself, and although this same Most Reverend Father relying on a clear conscience was completely convinced that he had committed no irregularity whatever; nevertheless in an attitude of cautious circumspection and so that every scruple might be removed from the minds of the weak, he humbly begged us that in his case with respect to every and every kind of irregularity and taint or suspicion of irregularity, if perchance he could seem to some people to have incurred any by reason of the aforementioned, a precautionary and excessive dispensation should be given:

‘Know therefore, that we, weighing in our own royal mind and out of compassion, the force and validity of such a petition and being assured of the truth by careful investigation of the aforementioned and so that we may comply with the conscientious intent of the Most Reverend Father in this matter, and with abundant caution that we may be seen to strengthen the status, reputation, and dignity of our extremely loyal counsellor and president to whom the Church and State owe so much, and indeed out of our own far from weak patronage, have come to this present arrangement:

‘And to you or some six of you, four of whom we wish to be you, the aforesaid John, George, Lancelot and Samuel, respectively bishops of Lincoln, London, Winchester and Norwich, in whose loyalty, judgement and diligence we have supreme confidence, we commission, and by the special grace which is ours, and according to our royal authority supreme and ecclesiastical, which we wield on our own behalf and on that of our heirs and successors, do give and grant full right and power through this document as far as you or some six of you are concerned, four of whom we wish to be the aforesaid John, George, Lancelot and Samuel, bishops respectively of Lincoln, London, Winchester and Norwich, that in the case of the aforesaid Most Reverend Father, regarding every and every kind of legal or actual defect, criticism or any penalty canonical or ecclesiastical, but particularly every irregularity or taint of irregularity (if by chance by reason of the aforementioned any has been incurred or may seem to certain people to have been incurred), and so that in the offices and judicial administrations for which he has responsibility according to the power entrusted to him by his office and archiepiscopacy he may be able freely to minister, have the enjoyment of, exercise and take delight in, as a great precaution you should make a dispensation, and you should do all and every other single thing which shall prove necessary in this task, or as you may have opportunity to preserve and strengthen the status, benefit and honour of the aforesaid Most Reverend Father and that a dispensation to this effect and all other things according to your preference or that of some six of you, four of whom we wish to be you, the aforesaid John, George, Lancelot and Samuel respectively bishops of Lincoln, London, Winchester and Norwich, should be made, and, having been put together in due legal form, and when inscribed, reverted and made firm by your seals, or some authentic seal, delivered without delay to the aforesaid Archbishop. Furthermore, this dispensation, and all other matters according to your preference, or that of some six of you, four of whom we wish to be the aforesaid John, George, Lancelot and Samuel respectively bishops of Lincoln, London, Winchester and Norwich, we wish to be confirmed by passing under our great seal of England, and in respect of these things we expressly commission the Lord Keeper of the aforesaid great seal of ours and all the ministers of our Chancery and grant them full power by the contents of these presents.

‘Witnessed by myself at Westminster on the 22nd day of November in the nineteenth year of our reign in England, France and Ireland and the fifty-fifth in Scotland.’

In accordance with the contents and demands of the previously communicated commissioning letter, and to remove every scruple from the minds of the weak if perchance any is or shall have been conceived in that quarter, we, the aforesaid John, George, Lancelot, Samuel, Thomas, Arthur, Richard and George, bishops respectively of Lincoln, London, Winchester, Norwich, Coventry and Lichfield, Bath and Wells, Ely and Chichester, and having God the Father alone before our eyes and in his name first, and bearing in mind and being certain that the said hunt over which you had taken pains, seeing that the said homicide occurred accidentally (without you suspecting any such thing) was well conducted, orderly and quiet, and that the careful attention required by the occasion had been taken in the said hunt to guard against any danger there from happening to any one, to you, the aforesaid Archbishop of Canterbury, concerning all irregularity and taint of irregularity, if perchance you have incurred any by reason of the accidental homicide or death of the aforesaid Peter Hawkins, or if you should seem to some people to have incurred, we grant dispensation as regards every and every kind of consequence of the law; and from every single awkwardness, difficult situation, irregularity, and other penalties, adverse criticism and any restraints whatever, canonical or ecclesiastical (if perchance you have incurred any by reason of the aforementioned or seem to some people to have incurred any) we set you free regarding all and every kind of consequence of the law and by the contents of this document we decree and announce that you be considered an innocent man; and every defect, blot, taint or stain (if perchance you have contracted any by reason of the aforementioned or seem to some people to have contracted any) we completely abolish these and declare and pronounce that they be considered abolished. And you, even the aforesaid George, Archbishop of Canterbury, excessively and from great precaution we reinstate and restore as regards every and every kind of consequence of the law. And so that in all and every single administration of justice, privilege, distinction, prerogative, honour and in all other matters which in any way have connection with and pertain to the said archiepiscopacy you may have power to minister freely, we give consent and permission just as if the aforesaid accidental homicide had not been committed; there being no hindrance in any way to this from canons, laws, decrees, ordinances and ecclesiastical regulations to the contrary (if there be any contrary rulings in this sphere). In witness to this matter, we have caused our episcopal seals to be affixed to this document. Given this 12th day of December in the year of our Lord 1621.

Witnessed by the King at Westminster, on the 24th day of December in the 19th year of the reign of King James etc and his 55th in Scotland.