UPHOLSTERED chairs must not be introduced into a listed church building of special architectural and historic interest, the Consistory Court of the diocese of Oxford has ruled.
The ruling said that they would cause harm to the significance of the building, and would not comply with the recommendations in the guidance issued by the Church Buildings Council (CBC). It applied even when the new chairs were identical to chairs that were already being used in the church.
The existing chairs, which had been acquired without a faculty, and therefore unlawfully, more than a decade ago, could not set a precedent, the diocesan Chancellor, the Worshipful Judge David Hodge KC, said, when refusing a faculty for the purchase of 35 additional upholstered chairs for use at St Leonard’s, Grendon Underwood, a Grade II* listed medieval church in Buckinghamshire.
Two churchwardens and the secretary of the PCC presented an unopposed faculty petition for the purchase of 35 additional stacking chairs of the same design as 25 existing chairs which had been purchased in 2013; and to dispose of 35 plastic bucket chairs which were in various states of disrepair.
Since St Leonard’s was Grade II* listed, the court was required to have regard for the Duffield guidelines laid down by the Court of Arches. It had to consider whether the implementation of the petitioners’ proposals would cause any harm to the significance of the church as a listed building of special architectural or historic interest.
If there was harm, the court must then consider how serious the harm would be, and how clear and convincing the justification was for carrying out the proposals. The petitioners had to demonstrate a sufficiently good reason for making any changes to a listed church building.
The parish had “provided a clear and convincing justification for the disposal of the 35 plastic bucket chairs”, which desperately needed to be replaced, the Chancellor said. They were, he said, “wholly unsuitable for a Grade II* listed, historic church building and should never have been introduced into this church in the first place”. A faculty was granted for their disposal. The question then was what should replace those chairs.
The CBC’s 2018 guidance note on seating issued under the Diocesan and Pastoral Measure 2007 stated that the CBC’s experience was that “wooden chairs have the greatest sympathy with historic church environments, present the best value for money with long life spans, and that a well-designed ergonomic wooden chair can provide as much comfort as an upholstered design”. It continued that “upholstered chairs are not considered to be appropriate” for several reasons. The CBC’s guidance should not be departed from, the chancellor said, unless the departure was justified by convincing reasons.
The Chancellor refused to allow the 35 plastic chairs to be replaced by 35 stacking chairs of the same design as the 25 upholstered chairs, which had been introduced into the church in 2013. He said that their presence had caused a degree of harm to this church of special architectural and historic interest.
The CBC guidance note provided examples of wooden furniture, including stackable chairs that had been used successfully in previous church reordering schemes. There was no reason to think that none of them would work just as well at St Leonard’s. The petitioners had not shown sufficient reason for departing from the CBC’s guidance on seating.
The upholstered chairs had been introduced into the church unlawfully over a decade ago, and the time had long elapsed since the court could make a restoration order requiring the removal of the chairs.
The Chancellor said that the case demonstrated “the need for the archdeacon, when conducting his regular visitation of each church within the archdeaconry, to be vigilant about identifying any changes that have been made to the church’s fabric and contents since the last visitation, and inquiring as to the nature of any requisite lawful authority for such change”.