spiritual person who, upon due examination and inquiry, should be found unable to preach, administer the sacraments, perform other pastoral duties, and converse in the Welsh language. A right of appeal to the Archbishop of Canterbury was preserved to such spiritual person against the decision of the Bishop, and by section 105 the provisions of the Act were made to apply to the appointment of curates within the several Welsh dioceses in cases where the ecclesiastical duties were not satisfactorily performed by reason of insufficient instruction in the Welsh language. In 1885, by the Act amending the Law relating to Pluralities (48-49 Victoria, c. 54) (which was to be construed as one with the Act of 1838), the term "ecclesiastical duties" in the case of benefices in Wales and the county of Monmouth was defined to include such ministrations in the Welsh language as the Bishop should direct to be performed, but so that not more than one Welsh service on every Sunday should be required, and provision made for the English-speaking portion of the population. In 1886, the Marquis of Abergavenny presented a clergyman, who could not speak Welsh, to a rectory in the county of Monmouth, within the diocese of Llandaff. The Bishop of Llandaff (Dr. Richard Lewis) thereupon commissioned certain persons to hold an inquiry as to whether the parish required a pastor with a knowledge of Welsh. The report was in the affirmative, and the Bishop refused to admit or institute the nominated clergyman. Thereupon the patron brought an action in the nature of a "quare impedit" against the Bishop for such refusal. It was held by Baron Huddleston (Law Reports, 20 Q.B.D., p. 460) that the "due examination and inquiry" required by the 104th section of the Pluralities Act, 1838, meant examination and inquiry as to the clergyman's knowledge of the Welsh language, and that the Bishop was justified in his refusal. In this case a very interesting reference was made to the case of Albany v. The Bishop of St. Asaph, decided in the time of Queen Elizabeth, (Leonards Reports, p. 31), to the effect that it was a good
