Ecclesiastical Discipline in the Anglican Church in North America: Part 5

Read Part 1, Part 2, and Part 3.
Read Part 4.

By Robin G. Jordan

Inhibition of Deacons and Presbyters. Under the provisions of Canon IV.9.1 a bishop may temporarily inhibit a deacon or presbyter if he believes, “upon reasonable grounds,” that the deacon or presbyter has engaged in conduct upon which a deacon or presbyter may be presented under the canons. The bishop may, “with the advice and consent of the Standing Committee or its equivalent,” extend the inhibition until “such charge is dropped or action taken by a Trial Court.” Canon IV.9.1 does not specify for how long a bishop may temporarily inhibit a deacon or presbyter or under what circumstances the temporary inhibition expires.

The Archbishop or his delegate may modify or revoke the temporary inhibition of a deacon or presbyter upon application of the deacon or presbyter and the showing of good cause. The canons require that the decision must be rendered within 30 days but do not specify whether the 30 days is from the date of the application or the Archbishop’s receipt of the application, another example of the canons’ murkiness and lack of sufficient detail.

In evaluating the requirements and procedure that the ACNA has adopted in its canons for the inhibition of deacons and presbyters, a comparison with the canonical requirements and procedures of the Episcopal Church for the inhibition of deacons or presbyters may prove useful. The requirements and procedures for the inhibition of deacons and presbyters in the Episcopal Church are prescribed in Canons IV.1.2-4, IV.7.2-3, and IV.10 of the canons of the Episcopal Church, as revised through 2006. Canon IV.1.2-4 delineates how a deacon or presbyter may be temporarily inhibited, under what circumstances, what redress the inhibited deacon or presbyter may seek, and how the temporary inhibition may be dissolved or modified:

Sec. 2 (a) If a Priest or Deacon is charged with an Offense or Offenses or serious acts are complained of to the Bishop that would constitute the grounds for a Charge of an Offense, and, in the opinion of the Bishop, the Charge or complaint of serious acts is supported by sufficient facts, the Bishop may issue a Temporary Inhibition.

(b) Any Temporary Inhibition shall: (i) be in writing, (ii) set forth the reasons for its issuance, (iii) be specific in its terms, (iv) define the Offense or Offenses charged or serious acts complained of, (v) describe in reasonable detail the act or acts inhibited, (vi) be promptly served upon the Priest or Deacon to be inhibited, and (vii) become effective upon being served upon the Priest or Deacon to be inhibited.

(c) A Temporary Inhibition may be issued without prior written or oral notice to the Priest or Deacon.

(d) Any Priest or Deacon against whom a Temporary Inhibition has been issued, modified, or extended may request a hearing concerning the Temporary Inhibition before the Diocesan Review Committee, which shall hear the same at the earliest possible time, but not later than fourteen days after the date of receipt of the request. The Diocesan Review Committee by a two-thirds vote may dissolve or modify the Temporary Inhibition. The Bishop and the Church Attorney shall be given notice of such hearing and shall be permitted to attend and be heard or to designate a representative to attend and be heard.

(e) At any time, a Bishop may dissolve or modify the terms of a Temporary Inhibition.

(f) A Temporary Inhibition shall continue in force and effect until the earlier of (i) the issuance of an Inhibition as otherwise permitted by this Title, (ii) the withdrawal of the Charge or the allegations, (iii) the refusal of the Diocesan Review Committee to make a Presentment on the Charges alleged, (iv) dissolution of the Temporary Inhibition, (v) imposition of Sentence following a voluntary submission to discipline under Canon IV.2., or (vi) a period of ninety days measured from the date of service of the Temporary Inhibition; Provided, however, the ninety-day period may be extended by the Bishop for additional ninety-day periods upon good cause.

(g) In the event that the Temporary Inhibition is dissolved, reduced, or otherwise expires, the Ecclesiastical Authority shall so notify all persons to whom notice of the Temporary Inhibition was given.

Sec. 3. If a Presentment has been made by the Diocesan Review Committee against a Priest or Deacon, or if a Priest or Deacon has been convicted in a criminal Court of Record in a cause involving immorality, or if a judgment has been entered against a Priest or Deacon in a civil Court of Record in a cause involving immorality, the Bishop in whose jurisdiction the Priest or Deacon is canonically resident or of the jurisdiction wherein the conviction or judgment has been entered may issue an Inhibition to the Priest or Deacon until after the Judgment of the Ecclesiastical Trial Court becomes final.

Sec. 4. No Bishop shall issue an Inhibition or Temporary Inhibition except as expressly permitted by this Title.

Whatever relief that the inhibited deacon or presbyter may obtain from a temporary inhibition must be obtained at the diocesan level. He may request a hearing before the Diocesan Review Committee or he may approach the bishop. It lies within the bishop’s discretion to dissolve or modify the terms of the temporary inhibition or to extend the period of the temporary inhibition for good cause. The provisions of Canon IV.1.2-4 recognize the right of a bishop of a diocese as the chief superintendent in matters ecclesiastical within a diocese and as the “ordinary” of the diocese with “ordinary jurisdiction in causes ecclesiastical” to not only to inhibit a clerk in holy orders canonically resident in his jurisdiction when circumstances demand such inhibition but also to dissolve the inhibition or modify its terms. This is a right that is recognized by all of the canons of Anglican bodies that I have studied. While English ecclesiastical law recognizes the right of a clerk in holy orders to appeal against the bishop’s power to censure, inhibit, or avoid a benefice to the ecclesiastical court of the province, as we shall see, it also recognizes the bishop’s right to inhibit. On the other hand, Canon IV.9.1 of the ACNA canons curtails this right—first by requiring the advice and consent of the standing committee or the equivalent of the diocese for an extension of a temporary inhibition and second by giving the Archbishop or his delegate the power to dissolve the temporary inhibition or modify its terms.

Canon IV.7.2-3 of the canons of the Episcopal Church permit a bishop of a diocese, “upon probable cause,” to inhibit from officiating in the diocese a deacon or presbyter who temporarily comes into his diocese if the deacon or presbyter is “under the imputation of having elsewhere committed” an offense or the deacon or presbyter, while temporarily in the diocese, commits an offense. If the deacon or presbyter officiates in the diocese after his temporary inhibition, the bishop of the diocese is required to give notice to all the clergy and congregations in the diocese that the deacon or presbyter’s officiating is inhibited. The bishop is also required to notify the ecclesiastical authority of the diocese in which the deacon or presbyter is canonically present. The inhibition continues in force until the bishop dissolves the inhibition, “the standing committee assuming jurisdiction thereof votes not to issue a presentment, or if the deacon or presbyter is presented, the presentment is dismissed, whichever comes soonest. Canon IV.7.2-3 applies these provisions to “clergy ordained in foreign lands by bishops in communion with this church,” requiring in such case the notice of the inhibition should be given to the bishop from whose jurisdiction the deacon or presbyter appears to have come, to all the bishops having jurisdiction in the Episcopal Church, and “to the Recorder.”

The provisions of Canon IV.7.2-3 are based upon the provisions of Canon 59, Sec. 2-3 of the PECUSA canons, as revised through 1976. They recognize the right of a bishop of a diocese to inhibit from officiating in his diocese clergy from outside his diocese temporarily in his diocese if there are reasonable grounds to inhibit them. They establish the procedure that the bishop must follow in exercising this right. They also identify what must happen in order for the inhibition to cease to be in force. They give the deacon or presbyter and the bishop the protection of due process. They make provision for the notification of the ecclesiastical authority that has jurisdiction over the deacon or presbyter.

Canon IV.10 of the Episcopal Church’s canons prescribe the procedure by which a deacon or presbyter may be inhibited and deposed for abandonment of the communion of the Episcopal Church:

Sec. 1. If it is reported to the Standing Committee of the Diocese in which a Priest or Deacon is canonically resident that the Priest or Deacon, without using the provisions of Canon IV.8 or III.7.8-10 and III.9.8-11, has abandoned the Communion of this Church, then the Standing Committee shall ascertain and consider the facts, and if it shall determine by a vote of three-fourths of All the Members that the Priest or Deacon has abandoned the Communion of this Church by an open renunciation of the Doctrine, Discipline, or Worship of this Church, or by a formal admission into any religious body not in communion with this Church, or in any other way, it shall be the duty of the Standing Committee of the Diocese to transmit in writing to the Bishop of such Diocese, or if there be no such Bishop, to the Bishop of an adjacent Diocese, its determination, together with a statement setting out in reasonable detail the acts or declarations relied upon in making its determination. If the Bishop affirms the determination, the Bishop shall then inhibit the Priest or Deacon from officiating in the Diocese for six months and shall send to the Priest or Deacon a copy of the determination and statement, together with a notice that the Priest or Deacon has the rights specified in Section 2 and at the end of the six-months period the Bishop will consider deposing the Priest or Deacon in accordance with the provisions of Section 2.

Sec. 2. Prior to the expiration of the six-month period of Inhibition, the Bishop may permit the Priest or Deacon to utilize the provisions of Canon IV.8 or Canon III.7.8-10 and III.9.8-11, as applicable. If within such six-month period the Priest or Deacon shall transmit to the Bishop a statement in writing signed by the Priest or Deacon which the Bishop is reasonably satisfied constitutes a good faith retraction of such declarations or acts relied upon in the determination or a good faith denial that the Priest or Deacon committed the acts or made the declarations relied upon in the determination, the Bishop shall withdraw the notice and the Inhibition shall expire. If, however, within the six-month period, the Bishop does not pronounce acceptance of the renunciation of the Priest or Deacon in accordance with Canon IV.8 or Canon III.7.8-10 and III.9.8-11, as applicable, or the Priest or Deacon does not make retraction or denial as provided above, then it shall be the duty of the Bishop either (i) to depose the Priest or Deacon as provided in Canon IV.12, or (ii) if the Bishop is satisfied that no previous irregularity or misconduct is involved, with the advice and consent of the Standing Committee to pronounce and record in the presence of two or more Priests that the Priest or Deacon is released from the obligations of Priest or Deacon and (for causes which do not affect the person's moral character) is deprived of the right to exercise the gifts and spiritual authority conferred in Ordination.

The provisions Canon IV.10 is based upon those of Canon 62 of the PECUSA canons as revised through 1976. The ACNA canons have no equivalent provisions to those of Canon IV.7.2-3 and Canon IV.10.

In light of the allegations of the irregular use or misuse of the Episcopal Church’s canons related to inhibition and deposition of deacons and presbyters, it is not unreasonable to expect the Anglican Church in North America to have very clear and detailed canonical provisions relating to these matters. However, the ACNA with its so-called “minimalist” approach to canon law does not include these important safeguards in its canons. While clarity and detail in the provisions of a canon cannot prevent the irregular use or misuse of its provisions, they can help those seeking to redress the irregular use or misuse in investigating how they were irregularly used or misused and bringing this irregular use or misuse to public attention, as well as the attention of the appropriate authorities for corrective action. They also prevent whoever irregularly used or misused the provisions of a canon from avoiding being held accountable for such irregular use or misuse of the provisions of a canon on the grounds that the ACNA canons did not specify what he should have done in a particular set of circumstances and by their silence appeared to leave it to an individual’s discretion.

The ACNA does not appear to have learned from the Richter trial at which the charges of heresy were dismissed against the accused because the Episcopal Church had not adopted a specific doctrinal position. On the latter basis it was argued that the Episcopal Church had no doctrine and therefore the accused could not charged with holding opinions contrary to a doctrine that the Episcopal Church did not have. It can be similarly argued that a bishop cannot be charged with irregularly using or misusing his power to inhibit or depose if the provisions of the canons do not prescribe the requirements that the bishop must meet or the procedure that he must follow in exercising this power. With its “minimalist” canons the ACNA has opened the way for even greater abuse of power and arbitrariness in discipline than in the Episcopal Church.

While the requirement in Canon IV.9.1 of the ACNA canons that the bishop must, in order to extend a temporary inhibition, seek the advice and consent of the standing committee or the equivalent of the diocese may be justified on the grounds that it discourages a bishop from abusing the exercise of his power to inhibit, the requirement that a deacon or presbyter desiring relief from a temporary inhibition must seek that relief from outside of the diocese—from the Archbishop or his delegate is unjustifiable. Under the provisions of the ACNA constitution the Archbishop is not the metropolitan of the province and therefore he does not have supervision of the bishops of the province in their exercise of their powers. Whoever proposed this provision was seeking to arrogate to the Archbishop metropolitical authority that the constitution does not recognize as inherent in the office of Archbishop or vest in that office.

What is missing from Canon IV.9.1 is the provision for a diocesan level hearing at which an independent panel of clergy and laity would examine the evidence and hear the testimony of the bishop or his representative, the deacon or presbyter and others and determine whether the bishop had probable cause to temporarily inhibit the deacon or presbyter and whether there are any mitigating circumstances that warrant dissolution or modification of the terms of the temporary inhibition. In the event the hearing panel found that there was no probable cause for the temporary inhibition and/or there were mitigating circumstances, the hearing panel would be empowered to dissolve the temporary inhibition or modify its terms. In the event the hearing panel found that there was probable cause for the temporary inhibition, the hearing panel would be empowered to sustain the temporary inhibition. In the event that the deacon or presbyter is dissatisfied with the ruling of the hearing panel, the deacon or presbyter would have the option of making an appeal against its ruling to the Provincial Tribunal. The canons should also authorize the Provincial Tribunal to establish a panel of its members to hear such appeals. In event the appellant is dissatisfied with the ruling of this panel, the appellant would have the option of appealing to the entire Provincial Tribunal. Before the expiration of a temporary inhibition the bishop would be required to request the assent of the diocesan level hearing panel if he wished to extend the temporary inhibition and the hearing panel would be required to hold a hearing, review the facts of the case, examine any new evidence and hear any new testimony before giving its assent to such an extension. The deacon or presbyter under inhibition and the bishop or his representative would be able to present new evidence and testimony. If the deacon or presbyter under inhibition is dissatisfied with the outcome of the hearing, he would have the option of appealing the hearing panel’s decision to Provincial Tribunal. The bishop or his representative would have the option of applying to the Provincial Tribunal for a reversal of a decision of the hearing panel if the panel refused to give its assent to an extension of a temporary inhibition. The bishop would be free to dissolve a temporary inhibition or modify its terms. Such provisions would not weaken the power of a bishop to inhibit a deacon or presbyter but would establish a procedure that a bishop would follow in exercising that power, a procedure similar to that which judges follow in issuing certain types of court orders. The procedure not only protects those affected by such court orders but also the judge.

The provisions of Canon IV.9.1 do not require the archbishop to hold a hearing, examine the evidence, or hear testimony. They provide no opportunity for the deacon or presbyter and his legal counsel to dispute the facts supporting the charge or complaint of serious acts made against the deacon or presbyter, to introduce evidence, or to call witnesses on the behalf of the deacon or presbyter. They provide no opportunity for the legal counsel of the deacon or presbyter under inhibition to challenge evidence or cross-examine witnesses. They do not even require the Archbishop to make a thorough review of the case. As they are worded, they only require the deacon or presbyter under inhibition to make application to the Archbishop or his designate and to show “good cause” to the satisfaction of the Archbishop or his designate in order for the Archbishop or his designate to “modify or revoke the temporary inhibition.” They permit the Archbishop who is not the metropolitan of the province or its highest judicial authority, to meddle in the disciplinary proceedings of a diocese and to overrule the decisions of its bishop.

Under English ecclesiastical law, under the provisions of the Church Discipline Act of 1840 and the Clergy Discipline Act of 1892 a bishop may, while a charge is under investigation, inhibit the accused if he thinks that the accused officiating is likely to cause great scandal or that the ministrations of the accused will be useless. Under the provisions of the Clergy Discipline Act of 1892 this power of inhibition also applies where the clergyman is accused before a temporal court of a criminal offence or of any act constituting an ecclesiastical offence.

Under the provisions of the Incumbents (Discipline) Measures, 1947 to 1953, a bishop, after personal investigation or upon the receipt of the report of the special court and subject to the other provisions of the Act, may, on the establishment of any charge against an incumbent, inhibit the incumbent for a period of up to three years. This power must be exercised within six months after the receipt of the report of the special court, or if an appeal is filed after receipt of notice of its withdrawal or determination. There is no similar limitation on the exercise of the power of inhibition after a bishop’s personal investigation. The inhibition may be rescinded by the bishop at any time.

Inhibition of Bishops. Under the provisions of Canon IV.9.2 in the case of the presentment of a bishop, including the Archbishop, three of the five senior members of the College of Bishops by date of consecration may “by affirmative vote” temporarily inhibit the bishop. Those inhibiting the bishop may not include “any bishop involved in the presentment or trial.” This presumably would exclude any of the three bishops who may have made charges against the bishop, any of the three bishops who may be serving on the Court for a Trial of Bishop, and any bishop who may be appointed as legal adviser to the court or as prosecutor if he was a senior bishop. The language of the canons is murky as to exactly when a bishop may be inhibited. The canons describe the filing of written charges against a bishop by the requisite number of bishops or other persons with the Archbishop, the Archbishop’s delegate, or the College of Bishop as the “presentment” of the bishop. The requisite number of senior bishops presumably may inhibit the bishop at this point. However, the canons also refer to the Board of Inquiry making a public declaration of its finding of the existence of probable cause for “presentment” for trial of the bishop for violation of Canon IV.2.

The canons make no provision for the modification or revocation of a bishop’s inhibition even if the Board of Inquiry finds the existence of no probable cause to try the bishop or the Trial Court exonerates the bishop from all charges. This is another example of where the canons fail to state what happens next. Presumably the three senior bishops who inhibited the bishop would lift the inhibition upon a Board of Inquiry’s finding of no probable cause or the Trial Court’s acquittal of the bishop. However, the canons do not require them to do so. They also do not recognize that the three senior bishops have discretion to modify or revoke the inhibition of the bishop upon the application of the bishop and the showing of good cause. It cannot be assumed upon the basis of the silence of the canons on this matter that that the three senior bishops do have this discretion. As we can see, the lack of such provisions raise the issue of how silence on a matter in the constitution and canons should be interpreted. Should it be interpreted to permit an action or to forbid it, give a power or to withhold it? Greater clarity and more detail in the constitution and canons would reduce the possibility of conflicting interpretations of these documents and the likelihood of their misinterpretation. This was drawn to the attention of the Governance Task Force before the proposed constitution and canons were ratified but it did nothing to correct the problem.

As in the case of the inhibition of deacons and presbyters, a comparison with the canonical requirements and procedures of the Episcopal Church for the inhibition of a bishop, may also prove useful in evaluating the requirements and procedure that the ACNA has adopted in its canons for the inhibition of a bishop. These requirements and procedures are found in Canon IV.1.5-7 and Canon IV.9.1-2 of the canons of the Episcopal Church, as revised through 2006. Canon IV.1.5-7 delineates how a bishop may be temporarily inhibited, under what circumstances, what redress the inhibited bishop may seek, and how the temporary inhibition may be dissolved or modified.

Sec. 5 (a) If a Bishop is charged with an Offense or Offenses or serious acts are complained of to the Presiding Bishop that would constitute the grounds for a Charge of an Offense and, in the opinion of the Presiding Bishop, the Charge or complaint of serious acts is supported by sufficient facts, the Presiding Bishop may issue a Temporary Inhibition. The consent of a majority of All the Members of the Standing Committee is required for Bishops with jurisdiction.

(b) Any Temporary Inhibition shall: (i) be in writing, (ii) set forth the reason for its issuance, (iii) be specific in its terms, (iv) define the Offense or Offenses charged or serious acts complained of, (v) describe in reasonable detail the act or acts inhibited, (vi) be promptly served upon the Bishop to be inhibited, and (vii) become effective upon being served upon the Bishop to be inhibited.

(c) A Temporary Inhibition may be issued without prior written or oral notice to the Bishop.

(d) Any Bishop against whom a Temporary Inhibition has been issued, modified, or extended may request a hearing concerning the Temporary Inhibition before the Review Committee, which shall hear the same at the earliest possible time, but not later than thirty days after the date of receipt of the request. The Review Committee by a two-thirds vote may dissolve or modify the Temporary Inhibition. The Church Attorney and Presiding Bishop shall be given notice of such hearing and each shall be permitted to attend and be heard or to designate a representative to attend and be heard.

(e) At any time, the Presiding Bishop may dissolve or modify the terms of a Temporary Inhibition. If the Bishop is a Bishop with jurisdiction, the consent of a majority of All the Members of the Standing Committee shall be required for such a dissolution or modification.

(f) A Temporary Inhibition shall continue in force and effect until the earlier of (i) the issuance of an Inhibition as otherwise permitted by this Title, (ii) the withdrawal of the Charge or the allegations, (iii) the refusal of the Review Committee to make a Presentment on the Charges alleged, (iv) a dissolution of the Temporary Inhibition, (v) imposition of Sentence following a voluntary submission to discipline under Canon IV.2.9, or (vi) a period of one year measured from the date of service of the Temporary Inhibition.

Sec. 6. If a Presentment has been made by the Review Committee against a Bishop, or if a Bishop has been convicted in a criminal Court of Record in a cause involving immorality, or if a judgment has been entered against a Bishop in a civil Court of Record in a case involving Immorality, the Presiding Bishop may issue an Inhibition to the Bishop until after the Judgment of The Court for the Trial of a Bishop becomes final. The consent of a majority of All the Members of the Standing Committee is required for Bishops with jurisdiction.

Sec. 7. The Temporary Inhibition shall be an extraordinary remedy, to be used sparingly and limited to preventing immediate and irreparable harm to individuals or to the good order of the Church.

As we can see the requirements and procedures prescribed in these sections of Canon IV.5 are quite clear—a clarity that is lacking in of the ACNA canons. Under these provisions the inhibited bishop may request a hearing before the Review Committee and the Review Committee may by a two-thirds vote dissolve the temporary inhibition. Under the provisions of the ACNA canons an inhibited bishop has no redress.

Canon IV.9.1-2 of the canons of the Episcopal Church prescribes the following procedure for the inhibition and deposition of a bishop who abandons the communion of the Episcopal Church as defined in Canon IV.9 (1): The Review Committee, by a majority vote, of all its members must certifies the fact of the bishop’s abandonment of the communion of the Episcopal Church to the Presiding Bishop and sends the certificate to the Presiding Bishop with a statement of the acts or declarations which show such abandonment. The Presiding Bishop must record the certificate and statement. The Presiding Bishop may, with the consent of three senior bishops having jurisdiction in the Episcopal Church, then inhibit the bishop until such time as the House of Bishops have investigated the matter and acted upon it. The Presiding Bishop, or the presiding officer of the House of Bishops, must give the bishop notice of the certification and the inhibition. Unless the inhibited bishop, within two months, makes declaration by verified written statement to the Presiding Bishop that the facts alleged in the certificate are false “or utilizes the provisions of Canon IV.8 or Canon III.12.7, as applicable,” the bishop is liable to deposition. If the Presiding Bishop is reasonably satisfied that the bishop’s statement is “a good faith retraction of the declarations or acts relied upon in the certification to the Presiding Bishop or a good faith denial that the bishop made the declarations or committed the acts relied upon in the certification,” the Presiding Bishop may, with the advice and consent of a majority of the three senior Bishops consenting to the inhibition, terminate the inhibition. Otherwise the Presiding Bishop must present the matter to the House of Bishops at the next regular or special meeting of the House. If the House, “by a majority of the whole number of bishops entitled to vote, “gives its consent, the Presiding Bishop may depose the bishop. The Presiding Bishop is require to pronounce and record the bishop’s deposition in the presence of two or more Bishops.

As we can see, the requirement of the affirmative vote of three of the five senior bishops to temporarily inhibit a bishop under the provisions of the ACNA canons comes from the consent of three senior bishops requirement of Canon IV.9.1-2. The provisions of the ACNA canons do not specify what must happen before such a vote or what occurs after it. They vaguely make reference to “in the case of the presentment of a bishop…”

Under English ecclesiastical law where a complaint is referred to a commission of the Upper House of Convocation of a province for inquiry and report, the archbishop has power to temporarily suspend the bishop against whom the complaint has been made. The bishop must not as long as the suspension remains in force exercise any functions pertaining to his office until the Upper House of Convocation declares the complaint to be unfounded or decides not to take further action or censure the bishop; or the archbishop decides not to declare the bishopric vacant where has been requested to do so by the Upper House of Convocation; or Her Majesty the Queen has confirmed or decided not to confirm the archbishop’s declaration where the archbishop declares the bishopric vacant. As long as the suspension remains in force in the case of a diocesan bishop, the jurisdiction of the bishop is exercised by the archbishop as the guardian of the spiritualities of a vacant bishopric.

A suspension issued under this power cannot remain in force for a period exceeding a year. Any suspension may be revoked by the archbishop at any time.

If a complaint that an archbishop has been guilty of unbecoming conduct or neglect of duty is referred to a commission appointed by the Upper House of either Convocation, the two senior diocesan bishops of the archbishop’s province have power to temporarily suspend the archbishop. If so suspended the archbishop is disabled from discharging or exercising any of the functions or powers for the same period as a bishop similarly suspended. However, the suspension is at all times revocable by the two senior bishops.

During the temporary suspension of the archbishop his jurisdiction is exercised by the dean and chapter of the metropolitan church as though the archbishopric were vacant.