The Archbishop of Canterbury seems to be much annoyed at
the statement of the Judges of the Queen's Bench that the Public Worship Act created a new jurisdiction, and that the judgments under that Act are not ordinary judgments of the Dean of the Arches. He has sent to the papers a Memo- randum,—rather hastily drawn up, and containing several technical errors,—to prove that the declarations of the Judges as to the "new jurisdiction" conferred by the Public Wor- ship Act are to be regarded as " °biter dicta," and not as de- 'elating the law on the issue really before the Court. Nothing contained in the Memorandum, however, throws the slightest doubt on the unquestionable fact that there is no proper ecclesiastical jurisdiction at all exercised by anybody in relation to proceedings taken under the Public Worship Act, though it is undoubtedly the Dean of the Arches who hears the proceedings 'under that Act, Dr, Tait's Memorandum completely fails to Drove that the clergy, in submitting to the judgment of Lord Penzance when given under the Public Worship Act, are sub- mitting to an ecclesiastical Court, or indeed doing anything which they are required to do by their canonical obligations.
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