The former Bishop of Grafton, Keith Slater, resigned in May 2013 and retired to the Diocese of Brisbane. In 2015, after a complaint by the Diocese of Grafton's Professional Standards Committee relating to Bishop Slater's perceived failings in relation to allegations of child abuse within the diocese during his time as bishop, which had been upheld by the Professional Standards Committee under the terms of the Diocese of Grafton's Professional Standards Ordinance 2004, his successor deposed him from holy orders in the Anglican Church of Australia. The complaint was emphatically not that Bishop Slater had had any part in child abuse himself, but that he had failed to act appropriately on a series of allegations of abuse against others. A copy of the instrument of deposition was delivered to the primate and the relevant details were entered in the national register.

Bishop Slater appealed to the Appellate Tribunal of the Anglican Church of Australia. Before the tribunal he challenged the validity of his deposition and contended that he was entitled to appeal by way of a hearing de novo. The tribunal concluded that it had no jurisdiction because the 2004 Ordinance that had established the Professional Standards Board had not included any right of appeal. Moreover, the Episcopal Standards Commission of the Anglican Church of Australia – which would have had jurisdiction had he still been Bishop of Grafton – had formed the view that Bishop Slater's resignation had deprived it of jurisdiction to consider the information about his conduct while Bishop of Grafton. Nevertheless, even though the tribunal concluded that it did not have jurisdiction to hear the appeal, it also ruled that the deposition itself had no legal basis because the Professional Standards Board of the Diocese of Grafton had exceeded its own jurisdiction. It so ruled on the assumption that expressing and explaining this ruling would be welcomed and accepted in view of the justice of the situation, concluding that the Grafton authorities had no jurisdiction over Bishop Slater under the 2004 Ordinance. Furthermore, such jurisdiction as they purported to exercise was legally flawed. Therefore, the recommendation of the Board and the Instrument of Deposition issued in consequence were and are null and void. The Appellate Tribunal further declared that the General Secretary or other appropriate authority should rectify the national register by removing any reference to Bishop Slater's deposition from holy orders and suggested that the Episcopal Standards Commission might consider appropriate action. It did not make any order in respect of the nullity, lacking jurisdiction to do so; nor could it preclude the parties from re-litigating the jurisdictional issues in a civil court. [Frank Cranmer and Gavin Drake]