What the Church of Scotland has said on Homosexuality

A Summary of Key Reports and Incidents

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The previous Principal Clerk to the Church of Scotland, Very Rev Dr Finlay Macdonald, has a chapter on human sexuality within his book Confidence in a Changing Church that provides an excellent summary of the Church of Scotland’s discussions on this issue. [1] It is highly recommended reading.

The Church and Sex… it can be an explosive mix. As Ron Ferguson wrote in The Herald on the Monday of General Assembly Week 2006, “What is it with the churches and sex? No, it’s not Catholics and condoms this week, but Protestants and gay relationships.” No matter how much we in the Church of Scotland might hope to keep a unified front as a part of the body of Christ, when it comes to sexuality and relationships divisions within the Church become all too clear.

Divisions over the Church’s response to homosexuality are not limited to the Church of Scotland. The Anglican Communion is struggling over the issue of openly gay bishops in the USA. Our sister church, the Presbyterian Church (USA) is also divided on whether openly gay or lesbian clergy should be ordained. While the Scottish Episcopal Church appears to be more open and inclusive towards homosexual clergy and members, nonetheless there are still tensions and divisions. On the other hand, other churches, such as the Protestant Church in the Netherlands, have accepted same-sex relationships fully.

Many ask what the Church of Scotland’s position on homosexuality is, and some claim that the ‘official’ position of the Church clearly defines homosexuality as sinful. Is this the case? Technically: it probably is. Morally: the issue is not so clear-cut. The Church of Scotland has, over the past decades, been divided on this issue and that division is reflected in the decisions that have been made, or, more interestingly, in the decisions that the General Assembly has chosen not to make.

Church and Society

It would be wrong to assess the Church of Scotland’s stance towards homosexuality without mentioning the vast changes in attitude toward homosexuality that have occurred within society over the past decades. Indeed on all matters of human sexuality and relationships there have been great changes.

Some of these changes we might justifiably decry, such as the increasing sexualisation of society. My own older daughters (aged 5 & 6) talk often of their desire for a Bratz doll, a modern-day equivalent to Barbie that looks more like a flirtatious street-walker from downtown Los Angeles than a child’s toy.

Nonetheless some of the changes have been undoubtedly positive for many. For example, the increasing openness within society has empowered women, it has removed (though not completely) the threat of personal injury from people with a homosexual orientation, and it has brought teenage pregnancy (which has always occurred[2]) into the open where young parents, often lacking self-esteem, can be better supported.[3]

In the experience of most parish ministers it is now the rare occurrence to find a couple seeking marriage who are not already living together, often with families. That is the reality.

In the past the Church was in a position to assert moral authority. In the 17th century the General Assembly passed an Act that set up the model of elders’ districts that we now know so well. One of the reasons for visiting homes was so that elders could “visit the same every month at least, and report to the Session what scandals and abuses are therein.”[4]

Instances of “fornication” were followed with public repentance on three Sabbaths, a repeat meant six Sabbaths, and if the fornicator was found guilty once more, they had to repent for 26 Sabbaths! Needless to say, in the patriarchal society of the day, the female transgressor suffered this humiliation more often than the male.

The Church has had to come to terms with the fact that most of the population is not listening when moral judgements are made by the Church that are out of step with the cultural norms of the day. This does not mean that the Church should keep quiet on issues where it has a distinctive voice and message that needs to be spoken. It does mean, however, that the Church should think carefully about what its message is rather than reflexively proclaim the message of a bygone cultural era without critically holding that message up to the light. For measured against the standards of our Lord Jesus Christ and his Gospel message, we may find that a “traditional” teaching of the Church can no longer be held as valid. We have done this already on the question of the remarriage of divorcees and the ordination of women to eldership and ministry of Word and Sacraments.

1956-8: Church and Nation Committee

In the mid 1950s the Church’s attention was drawn to ‘the problem’ of homosexuality by the Wolfenden Committee. Set up by the Home Secretary in 1954, the Wolfenden Committee’s remit was to bring recommendations on two issues: street prostitution and homosexuality after a string of distasteful trials and hostile newspaper campaigns.[5] At this time homosexual acts between two men were illegal in Britain.[6]

The Wolfenden Committee heard testimony from three gay men who described what it was like to be gay. The committee heard that there was a ‘homosexual world’ in which these three men lived their private lives and Wolfenden refers to the ‘homosexual community’ in his report.[7]

The Church and Nation Committee reported in 1956 that

there are many men and women with homosexual tendencies who live admirable lives of service to the community and to the Church, whose condition is unsuspected by those with whom they come in contact, and who never indulge in criminal sexual conduct. Such people are entitled to unqualified sympathy and respect. There are, however, other homosexuals who give expression to their nature by physical acts. In fairness, it must be recognised that the homosexual is subject to difficulties which the normal individual of heterosexual disposition escapes. For the true homosexual there can be no prospect of a satisfactory marital relationship, and the conventional segregation of the sexes in modern society, which helps to preserve the morality of the rest of the community, is to the homosexual often an added source of temptation.

While sympathetic, however, the conclusion of this report was clear that homosexual practice was sinful.

The Wolfenden Committee recommended to Parliament in 1957 that male homosexuality should be decriminalised for those over 21 years of age.

The following year the Church and Nation Committee was divided on this issue. The sub-committee looking into the matter agreed with Wolfenden. The Committee as a whole did not, stating that decriminalisation was “calculated to increase, rather than decrease this grave evil”. The sub-committee brought a petition to the floor of Assembly which led to a counter-motion accepting Wolfenden’s conclusion (while still stating that homosexuality was sinful). The counter-motion was defeated and the Church of Scotland “became the only major church to oppose the Wolfenden Committee’s proposal to amend the law.”[8]

1967-8: Moral Welfare Committee

A decade later a report from the Moral Welfare Committee came to the General Assembly of 1967 with a more pastorally sensitive approach to those within the Church with a homosexual orientation. Aware that too hostile a stance would not allow the openness for gay men and lesbian women to seek counsel from the Church they recommended

a more sympathetic understanding of the difficulties and handicaps of those suffering from homosexual tendencies… regret the comparative lack of psychiatric and medical treatment available… and that ministers [should] show special pastoral concern and care to those suffering from such tendencies, so that they may know that the Gospel of redemption through Jesus Christ is for all.[9]

Despite the Wolfenden recommendations made in 1957, Parliament had still not decriminalised homosexual acts. The Moral Welfare Committee now proposed that this legal change should be supported.[10]

In response the General Assembly robustly rejected the report’s recommendations stating in no uncertain terms that homosexuality led to uncleanness, deterioration of a person, and even national weakness and decadence. With no hint of how devastating the previous statement might be for someone who was gay or lesbian, the General Assembly also stated a deep concern for their souls and urged them to belief in Jesus’ salvation and freedom.

In 1968 at the next General Assembly, and explaining how the previous years’ statement had destroyed any hopes of pastoral care for gay men who had come to church agencies seeking counsel, the Moral Welfare Committee successfully moved for the previous year’s more sensitive deliverance to be accepted.

1983: Board of Social Responsibility

In 1980 homosexual acts between two men became legal in Scotland. A year later a study group was formed by the Board of Social Responsibility to look once more at homosexuality.

The 1983 report to the General Assembly was wide-ranging and recognised the different interpretations of the relevant Biblical texts that existed within the Church of Scotland. While the report lamented the fact that few homosexual people could have “opportunity for fellowship within the Church”, it also confirmed that homosexuality was not God’s ideal for his people.

In this report there was acknowledgement that some Christian gay and lesbian people would see “in an active homosexual partnership a love which is in no way contrary to that described by Christ in his life and witness” while others would seek help to escape from their feelings which they sought to disown. In response to these two different views “a greater love, transcending the sexual, towards which [both] may be drawn” was promoted.

A supportive conclusion admitting the oppression and contempt that many homosexual people had faced from church and society may have offered hope to those gay and lesbian people in the Church that some progress was being made. The report was commended to the church as providing guidance for those dealing with homosexuality.

1993: Motion to Ban Blessings on Same-Sex Partnerships

Despite the generally negative tenor of the Church’s position, some same-sex couples approached sympathetic ministers in the intervening years seeking a blessing on their relationship. After one such blessing performed by Rev Margaret Forrester, at the 1993 General Assembly it was moved:

In view of the recent publicity given to a Kirk minister’s Service of Blessing on a “marriage” of two lesbians, instruct all Church of Scotland ministers not to perform services of blessing on homosexual/lesbian relationships.

Macdonald recounts that as Depute Clerk at the time he

argued that the Church had a long tradition of trusting its ministers to make appropriate judgements in pastoral situations and that we should not be making ad hoc exceptions without some kind of considered process.[11]

The vote was 338 for the motion, 534 against. There were strong feelings on both sides of the debate, and it was clarified that no special service for such a ceremony existed in the church’s liturgy.

1994: Board of Social Responsibility & Panel on Doctrine

At the 1994 General Assembly the Board of Social Responsibility once more brought a report on human sexuality, while the Panel on Doctrine reported on the theology of marriage.

The Board of Social Responsibility report, as in 1983, covered much ground. While noting the advances in understanding human sexuality, specifically homosexuality, from a biological and psychological standpoint, the Board was not convinced either way by the evidence on the causes of homosexuality. And while the Board recognised the diversity of interpretation of Scripture it concluded

that for many in the Church of Scotland, their view about homosexuality would still be the one outlined in the 1983 report. Questions about causation, alternative interpretations of Scripture, and cultural factors are not enough to alter that view. At the same time, the Board would also recognise that in the Church of Scotland there are some who are convinced that in light of scientific evidence, socio-psychological understanding, critical scholarship and personal testimony, the view of homosexual practice as necessarily sinful can no longer be held with integrity and sincerity.

The report was very clear in its condemnation of homophobic behaviour and encouraged congregations to provide a welcome to all people, whatever their sexual orientation.

The Panel on Doctrine report on the theology of marriage trod a rather different path in comparison to the Board of Social Responsibility report. While providing a detailed theological reflection on marriage, the report was also realistic about current social trends:

It seems to us undeniable that a huge gulf has opened up between the Church’s traditional teaching and the views of many younger church members. It is a gulf which perhaps extends beyond the young; many parents feel respect, rather than censure, for life choices made by their children which are different from the choices they themselves made.

Many different patterns of relationship, other than traditional marriage, were becoming increasingly common, not just in society but within committed Christian circles also. The Panel argued this was not necessarily to be lamented; absolute categories of right and wrong with respect to human relationships were no longer proving helpful in relating to the realities of human life.

The report noted the changes in other Churches in responding to the pastoral reality within the Church, particularly the Church of England after their House of Bishops 1991 Statement[12] and the American Episcopal Church which had ordained openly gay clergy living in partnerships.

Tolerance and mutual respect was urged from both sides of the debate. No one side, it was argued, had the right to insist that those who held a different viewpoint accept its view.

Applying the principles for defining what made a good heterosexual relationship, the  Panel on Doctrine report concluded its section on same-sex relationships:

The Christian would probably describe as “good” a heterosexual relationship that is characterised by the principal quality of love, which in turn may be recognised by defining qualities or features such as fidelity, commitment, devotion, caring, forgiveness, patience. Conversely a relationship will be rejected if it is exploitative, unloving or unfaithful. The gay Christian will apply such an evaluation to the quality of a gay relationship: it may similarly be characterised by love or by lack of love. So it is possible within the gay Christian community to reject gay prostitution, promiscuity or sex with minors, for example, as exploitative, uncaring or oppressive; in other words, as lacking the necessary quality of love.

Gay Christians believe, therefore, that a relationship which displays the quality of love as understood in an appropriate Christian way is as acceptable an expression of their God-given natures as heterosexual people enjoy in their relationships, and provides a context within which the full range of physical expression of that love is acceptable and appropriate.

This was a departure from previous reports brought to the General Assembly which, we have noted, maintained that homosexuality was a “problem” and that any homosexual acts were sinful. “Love the sinner, hate the sin” was the response in those reports, and indeed the general thrust of the Board of Social Responsibility report of 1994.

The Panel on Doctrine sought a different approach that no longer saw homosexuality as a “problem” to be cured. The Church was being called by this Panel to affirm gay and lesbian people for who they are.[13]

On the day of the debate on these two reports (incidentally, my first visit to the General Assembly as a first-year student!) there was much anticipation. However the Assembly decided not to vote on any of the deliverances being brought by either the Board of Social Responsibility or Panel on Doctrine on the matters of human sexuality. While this avoided any formal display of disunity it was, for many, a dissatisfying result.

The reports were debated with much passion from both positions. The Church was clearly divided on the matter of human sexuality and homosexuality. However the Church of Scotland did not make any decisions in 1994. This was to protect the unity of the Church, which is an admirable objective. However, it has left a continuing confusion over the Church’s position on matters of human sexuality.

Did it mean that the 1983 report from the Board of Social Responsibility, which had been agreed by the General Assembly, was still the official position of the Church of Scotland? Macdonald summarises:

…the 1994 General Assembly was a bit like the Battle of Sheriffmuir. “Some said that we’d won, and some said that they’d won, and some said that nane won at a’ man!” The Panel on Doctrine which had sought to move the Assembly to a position of acceptance of same-sex relationships could say that the Assembly had not rejected its thinking, nor endorsed the views of the Board of Social Responsibility. Conversely, the Board could argue that its assertion of the ‘traditional’ view had not been repudiated, while the Panel’s radical thinking had not been affirmed. Undeniably, many would have preferred a clearer signal so that the Church could express an unequivocal view. Equally, there were many who were grateful for the breathing space to debate the issues and the implicit recognition that the principle of liberty of opinion was being brought into play in the area of sexual ethics.[14]

Following the Assembly, study materials were produced by the Panel on Doctrine and Board of Parish Education to help congregations discuss the issues that the Panel had raised in its report. The report from the Board of Social Responsibility was commended to the Church for discussion.

2000: The Battle over Section 28

Across Britain in 1999/2000 a battle took place over the government’s decision to repeal Section 28 of the Local Government Act 1988 (in Scotland it was referred to as Section 2A).

Section 28 was an amendment intended to stop local authorities from promoting homosexuality. Under Section 28 no funding for books, plays, leaflets, films or any other such material that showed a gay relationship as normal would be allowed by a local authority.

The response from the gay and lesbian community was understandably strongly opposed to Section 28. Teachers also strongly objected. Sam Galbraith, Education Minister of the Scottish Parliament, said:

The legislation simply bans the promotion of homosexuality – just because we take that away it doesn’t mean that there will be a promotion of it. At present this law prevents teachers from dealing sensitively with such matters. It is a redundant piece of legislation and simply reinforces prejudice.[15]

An alliance of church leaders led by the late Cardinal Winning and businessman Brian Souter (who donated £500,000 to the ‘Keep the Clause’ campaign) fought against the repeal of Section 28. They feared that its repeal would lead to an undermining of marriage and family values and would see homosexuality actively promoted in schools.[16]

Unsurprisingly, the Church of Scotland was divided on the issue. The Board of Social Responsibility, under Anne Allan’s leadership, supported the ‘Keep the Clause’ alliance. On the other hand the Committee on Education, having listened to educational experts supported the repeal of Section 28. The Moderator of the day, Very Rev John Cairns, also supported a repeal of Section 28 and was quite outspoken on the issue, much to the delight of many gay and lesbian people within the church.[17]

To ward off a repeat of 1994, the Committee on Education and Board of Social Responsibility prepared a joint report to the 2000 General Assembly. With some modification the deliverances were adopted. On marriage, for instance, the Assembly declared:

The General Assembly adheres to its previous decisions that affirm marriage as the normative context for heterosexual, permanent relationships and, by extension, as the appropriate environment in which to raise and nurture children.[18]

The Scottish Executive was also urged in a proposed replacement for Section 2A to maintain the “value of marriage, parental commitment and family relationships in a child’s development”.

Two notices of motion had been received by the Assembly: one in favour of the repeal and the other urging for the retention of Section 28. This would have produced a face-off between either side. As in 1994, the General Assembly of 2000 decided to put the unity of the Church ahead of a clear decision and decided not to debate or vote on the motion.

2003: The Moderator and Gay Ministers

The Anglican Communion had a tumultuous year in 2003. The debacle over the appointment of Canon Jeffrey John as Bishop of Reading led to his withdrawal under pressure from some in the Church of England and from member churches of the Anglican Communion, the Church in Nigeria in particular. Canon Jeffrey John was qualified for the position in every way except that he was openly gay. He had a long-term partner but had announced publicly that he was celibate and had been for many years.

At about the same time the American Episcopal Church appointed Canon Gene Robinson as Bishop of New Hampshire. Bishop Robinson has a same-sex partner, is not celibate, and had been democratically approved.

While this was going on in the Anglican Communion it was natural for the media to ask the Church of Scotland what its own position was with respect to gay clergy. The Moderator, Very Rev Prof Iain Torrance, was asked to comment on the Jeffrey John case. He reports that “recalling the report of the Panel on Doctrine in 1994, I confessed myself to be utterly untroubled by the ministry of a person of homosexual orientation.”[19]

This news hit the front page of The Sunday Times on 29 June 2003 with the title “Moderator backs gay ministers”. A follow-up poll of 200 ministers reported a fortnight later in The Sunday Times that 62% of ministers were relaxed about the appointment of a homosexual minister while 38% did not agree that gays had any place in ministry.

Rev Bill Wallace wrote an open letter to The Scotsman seeking clarification from the Moderator. This clarification was duly given in an article written by the Moderator in The Scotsman. Prof Torrance clarified that he was referring to the welcome into the church that people with a homosexual orientation who live a “chaste and disciplined life” should receive. He was not speaking about homosexual practice.

My argument for this is simple and theological. Did Jesus Christ not die and rise again for all of us? Did he not die for gay people? May they not be baptised? And if baptised, and qualified by the requisite gifts and learning, may they not be ordained? Or do they have some deficiency in their humanity which is so irremediable that they are beyond the scope of the incarnation?

When the Church of Scotland came to welcome the ordination of women, it understood theologically that what was at stake was not the gender of those who were ordained to ministry, but their humanity. At the incarnation, Jesus Christ assumed our humanity, not merely a gender, and a woman minister may represent the people of God on exactly the same basis as may a male minister. I believe the same may be said about orientation. That is the fundamental theological point I am making. Behaviour is a matter of discipline and a different issue.[20]

2006: Legal Questions Committee

And so we come to the present day and the 2006 General Assembly at which same-sex relationships were once more the source of considerable debate and media coverage. The unlikely source was the Legal Questions Committee who brought a Declaratory Act anent Civil Partnerships to the Assembly.

The Legal Questions Committee were responding to a number of factors: the introduction of the Civil Partnership Act 2004 which came into effect in December 2005, approaches to the Principle Clerk by ministers asking for guidance on what this new legislation meant (particularly as some same-sex couples were approaching their minister to mark their civil partnerships), and a desire to clarify what the law of the Church is on a minister’s pastoral conscience so to do.

Like all previous reports that strayed onto issues of human sexuality, there was recognition of the variety of views on same-sex relationships; nonetheless the Committee was determined not to move beyond its own remit. It was noted that the Worship and Doctrine Task Group would be reporting on ‘Theology and Human Sexuality’ in the future (2007).

The legal realities are that pension rights of those employed by the Church of Scotland now must be applied to civil partners in the same way as to a spouse.

The more controversial question was over whether ministers and others may recognise the civil partnership. The civil partnership ceremony itself cannot have any religious element, and so, the Committee notes, those entering a civil partnership “are likely to turn to sympathetic ministers to provide some kind of religious ceremony to mark the event.” This can be done at the moment by packaging it as an act of pastoral necessity in extremis. Such criterion keep an open door to the possibility of disciplinary action by Presbyteries under Act III 2001 (though none such has been advanced so far). The report of the Legal Questions Committee stated that:

The Committee, while acknowledging that this is a controversial question, believes that it is important to recognise the existing freedom of pastoral conscience of ministers and others, and to guarantee that they do not face censure in the wake of providing a service in this context.  Appended to this report… is a Declaratory Act that would effect that clarification.  However, the Committee is clear that no two people who have entered into a Civil Partnership can claim any right to such a service.

It is also necessary to respect the rights of those who in conscience could not affirm a same-sex relationship, legally recognised through a civil partnership. While recognising that, contrary to popular media parlance civil partnerships are not marriages, the Committee nevertheless noted some parallels with the decision of the General Assembly in 1959 to permit the re-marriage of divorced persons in Church. This offended the consciences of many ministers at the time and the legislation made clear that no minister was required to perform such a marriage against his conscience. The Committee believes that it is important to respect integrity and freedom on both sides of the argument surrounding the current issue, so that neither side need fear repercussions from their conduct. The proposed Declaratory Act is permissive in tone, in order to protect conscience on all sides.

An attempt to defer a decision on this matter until the Worship and Doctrine Task Group had reported was defeated by the Assembly. A counter-motion to the Legal Questions Committee in the name of Rev Gordon Kennedy was moved that “No minister or deacon shall conduct any service marking a civil partnership.”

Despite the fears of many for schism, the debate that followed was well-conducted and the speeches passionate without being derogatory of those with other viewpoints. The initial vote appeared to be carried in favour of the Legal Questions Committee but by a close margin – close enough that an electronic vote was called. The result was 322 for the Legal Questions Committee motion and 314 for the counter-motion. The counter-motion was defeated, and for a second time the General Assembly had voted not to discipline ministers or deacons for marking a same-sex relationship.

However, an intervention by Rev Ian Watson meant that whichever motion had succeeded, it would pass under the Barrier Act for Presbyteries to concur with or to reject.

When the General Assembly voted to accept the Declaratory Act anent Civil Partnerships it voted 372 vs 240 in favour of the Declaratory Act, but with 122 registering their dissent in the time-honoured tradition of Assembly.

The results of the votes in Presbyteries were brought to the 2007 General Assembly. A majority of Presbyteries rejected the Declaratory Act, leaving the current status quo where a minister or deacon may choose to mark a civil partnership but with the possibility that this decision may result in disciplinary proceedings by his or her Presbytery. As far as the author is aware, no such disciplinary proceedings have been brought forward in the years since.

NOTE this paper will shortly be revised to bring this situation up to date.

Rev J Peter N Johnston


[1]   Macdonald, Finlay A.J., Confidence in a Changing Church, (Edinburgh: St Andrew Press, 2004).

[2]   Mallon, Steve, Sexuality and Salvation: Why can’t we live together?, (Edinburgh: Scottish Christian Press, 2004), p. 38. The incidence of teenage pregnancy in Scotland over the past 20 years has remained remarkably stable, which seems at odds with the increasingly hysterical press coverage of the issue.

[3]   “Horror stories are told of girls concealing their pregnancies and killing their babies at birth, rather than face disgrace and punishment.” Macdonald, 2004, p. 146. The 2004 film Vera Drake dramatically depicts the reality of 1950s Britain when backstreet abortions were a frightening reality for some young girls.

[4]   Ibid.

[5]   For instance, the conviction of Peter Wildeblood, who had been diplomatic editor of the Daily Mail, for homosexual offences in 1953.

[6]   Lesbianism escaped criminalisation because Parliament refused to discuss it in case naming it might give the existence of lesbianism credence, which they did not want to do lest ‘impressionable women’ be led astray. Noted in Mallon, 2004, p. 27.

[7]   Unknown at the time was the fact that John Wolfenden’s son, Jeremy, had told his father that he was gay.  Wolfenden’s attitude and understanding of the homosexual community would undoubtedly have been affected by this.

[8]   Macdonald, 2004, p. 149.

[9]   Church of Scotland, Assembly Reports, 1967, as quoted in Macdonald, 2004, p. 150.

[10]  Homosexual acts were decriminalised in England and Wales this same year, 1967.

[11]  Macdonald, 2004, p. 147.

[12] Church of England House of Bishops, Issues in Human Sexuality, (London: Church House Publishing, 1991) which stated that the Church should accept into its fellowship those who in good faith commit themselves to a “loving and faithful homophile partnership”, while maintaining that celibacy for gay clergy was the norm.

[13] The Panel on Doctrine was divided in this conclusion (8 vs 6) and a dissent from the conclusions of the same-sex relationships section of the Panel’s report was added.

[14] Macdonald, 2004, pp. 156f.

[15] Galbraith, Sam, interview, BBC News, Church splits over anti-gay law, http://news.bbc.co.uk/1/hi/scotland/609968.stm, Online, 16 July 2006.

[16] It is worth noting that despite the scare stories about schools, Section 28 never was applied to schools as local authorities have no say in the teaching of sex education in schools. “Head teacher’s leader, David Hart, called the debate ‘unreal’ and local government leader, Graham Lane described the arguments as a ‘charade’ and a ‘red herring’.” BBC News, Section 28 more symbol than substance, http://news.bbc.co.uk/1/hi/education/848847.stm, Online, 16 July 2006.

[17] Mallon, 2004, p. 60.

[18] Macdonald, 2004, p. 158.

[19] Torraince, Iain, Homosexual Ministers: The Moderator Replies, The Scotsman, 15 July 2003, http://www.news.scotsman.com/opinion.cfm?id=768742003, Online, 16 July 2006.

[20] Ibid.

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