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JGE v Portsmouth Roman Catholic Diocesan Trust

Court of Appeal: Ward, Tomlinson and Davis LJJ, 12 July 2012 [2012] EWCA Civ 938 Vicarious liability–diocese–priest

Published online by Cambridge University Press:  13 December 2012

Ruth Arlow*
Affiliation:
Chancellor of the Diocese of Norwich
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Abstract

Type
Case Notes
Copyright
Copyright © Ecclesiastical Law Society 2013

The Portsmouth Roman Catholic Diocesan Trust appealed against a decision of the High Court that it was vicariously liable for the torts allegedly committed by a parish priest in their diocese. In a majority judgment the court dismissed the appeal. Though it was common ground that a priest was not an employee, an examination of the recent cases on clergy employment indicated that whether or not there was a contract of service between a minister of religion and his Church depended on the facts of the case, that there was no general presumption of a lack of intent to create legal relations between a cleric and the Church and that it did not follow that an ecclesiastical office-holder could not be employed under a contract of service. The court held that Viasystems (Tyneside) v Thermal Transfer (Northern) Ltd [2005] EWCA Civ 1151 had established that for the purposes of vicarious liability the tortfeasor did not have to be an old-fashioned employee. Davis LJ stated that the time had come to announce emphatically that the law of vicarious liability has moved beyond the confines of a contract of service. Leave to appeal was refused. [Frank Cranmer]