the formation
of a provincial synod was foreshadowed by a conference of Australasian
bishops at Sydney in 1850; (b) towards the close of the 19th century
the title of _archbishop_ began to be assumed by the metropolitans of
several provinces. It was first assumed by the metropolitans of Canada
and Rupert's Land, at the desire of the Canadian general synod in
1893; and subsequently, in accordance with a resolution of the Lambeth
conference of 1897, it was given by their synods to the bishop of
Sydney as metropolitan of New South Wales and to the bishop of Cape
Town as metropolitan of South Africa. Civil obstacles have hitherto
delayed its adoption by the metropolitan of India.

_Freedom from state control._

(2) By degrees, also, the colonial churches have been freed from their
rather burdensome relations with the state. The church of the West
Indies was disestablished and disendowed in 1868. In 1857 it was
decided, in _Regina_ v. _Eton College_, that the crown could not
claim the presentation to a living when it had appointed the former
incumbent to a colonial bishopric, as it does in the case of an
English bishopric. In 1861, after some protest from the crown lawyers,
two missionary bishops were consecrated without letters patent for
regions outside British territory: C.F. Mackenzie for the Zambezi
region and J.C. Patteson for Melanesia, by the metropolitans of Cape
Town and New Zealand respectively. In 1863 the privy council declared,
in _Long_ v. _The Bishop of Cape Town_, that "the Church of England,
in places where there is no church established by law, is in the same
situation with any other religious body." In 1865 it adjudged Bishop
Gray's letters patent, as metropolitan of Cape Town, to be powerless
to enable him "to exercise any coercive jurisdiction, or hold any
court or tribunal for that purpose," since the Cape colony already
possessed legislative institutions when they were issued; and his
deposition of Bishop Colenso was declared to be "null and void in law"
(_re The Bishop of Natal_). With the exception of Colenso the South
African bishops forthwith surrendered their patents, and formally
accepted Bishop Gray as their metropolitan, an example followed in
1865 in the province of New Zealand. In 1862, when the diocese of
Ontario was formed, the bishop was elected in Canada, and consecrated
under a royal mandate, letters patent being by this time entirely
discredited. And when, in 1867, a coadjutor was