The papal bull Apostolicae Curae of Pope Leo XIII, promulgated September 18th, 1896, holds an important place in the annals of magisterial documents. The bull (also known by its longer English title, “On the Nullity of Anglican Orders”) provided the definitive papal statement on the long disputed question of the validity of Anglican orders. The problem had been discussed by theologians ever since the time of the Counter Reformation and it was the express intention of Leo XIII to put to the issue to rest, as the pontiff said, so that “all doubt, or even shadow of doubt” as to the Church’s stance on the complicated and sensitive topic should removed. (1) Besides the important question of Anglican orders, the bull also made important contributions to some other theological subjects: it developed important working principles of sacramental theology, as well as demonstrated the importance of tradition and precedent for forumlating contemporary papal policy. It is therefore no exaggeration to say that Apostolicae Curae is a document whose significance goes far beyond the single issue about which is was written.
The Question of Anglican Orders
Apostolicae Curae is a unique papal document because it deals with what had often been considered an issue of speculation. Until Leo XIII, the question of the sacramental validity of Anglican orders was commonly regarded as something beyond the authority of the papacy to settle dogmatically, since it was too often believed to hinge upon the validity of the ordination of a single individual: Dr. Matthew Parker, Archbishop of Canterbury, from whom all Anglican ordinations are traced. As long as commentators on both sides of the problem made the question one of the validity of Parker’s ordination, the Holy See could not make any declarative statement on the issue, for the validity of Parker’s ordination is a historical question that could not be ultimately settled by theological reasoning, either dogmatic or speculative. Whether or not Dr. Matthew Parker was validly ordained in 1559 was beyond the authority of the Holy See to determine in any dogmatic sense.
That is not to say that the Holy See had never taken any stance on the matter. Ever since the time of Cardinal Pole, Anglican clergy coming into the Church were given ordination; not a conditional ordination, but regular ordination, by which it seems that the Church never considered Anglican orders valid. In Apostolicae Curae, Leo XIII does not proclaim anything new; rather, he wishes to explain the reasons behind a discipline that the Church had been practicing since 1559 but had so far failed to explain why. The bull therefore ought not to be seen as Leo properly “settling” the question of Anglican orders, for he considered it settled long before his pontificate, a “settled custom of the Apostolic See” and the “constant practice of the Church.” (2) It should be seen rather as illustrating the rationale behind the Holy See’s consistent judgment over the years that Anglican clergymen need ordination before they could become Catholic priests.
Though the question can be seen as a speculative matter, Pope Leo understood that it had very concrete ramifications. If the issue was seen to be undecideable historically, it did not diminish the need for something to be done pastorally. Of the Holy See’s previous decisions regarding Anglican orders, Leo said, “it is necessary to lay it down as a fundamental principle that [previous papal decrees] were certainly not intended to deal with an abstract state of things, but with a specific concrete issue.”(3) The Holy See needed to ground its practice on something firmed than speculation about the validity or invalidity of Parker’s ordination. This is what Leo ultimately does by basing the invalidity of Anglican orders on a double defect of form and intent in the Anglican rite, as we shall see.

History of the Controversy
The source of the question goes back to the so-called Edwardine Ordinal of 1552. When Henry VIII severed relations with the Holy See in the 1530’s, the entire English hierarchy was at that time in possession of valid Holy Orders. Though Henry made many assaults on the Church, he refrained from meddling with the rite of ordination itself; that would come later under his succcesor. It was that under the brief reign of the young and inept King Edward VI (1547-1553) that the most domineering personalities of the English Reformation—Cranmer, Somerset and Northumberland—took it upon themselves to restructure the rite of ordination to suit their reformed theology, divorcing it from its associations with a sacrificing priesthood. The new rite was introduced in 1550, reissued in its final form in 1552, and was given the name “Edwardine Ordinal” after the reigning King Edward. (4)
In the revised rite, the essential form of the sacrament was the words, “Accipite spiritum sanctum,” (“Accept the Holy Spirit”) followed by the words, “Whose sins thou dost forgive they are forgiven; and whose sins thou dost retain they are retained; and be thou a faithful dispenser of the Word of God and of His Holy Sacraments.” In an episcopal ordination the words were altered slightly (“Take the Holy Ghost, and remember that thou stir up the grace of God which is in thee by imposition of hands, for God hath not given us the spirit of fear, but of power, and love, and of soberness”). These words in themselves were not the problem, as prayers very similar to these, coupled with the laying on of hands, were also found in the Catholic rite. The issue was not with anything extraneous added to the rite, but that something essential was removed, for the Edwardine Ordinal lacked any of the references to a sacrificing priesthood found throughout the Catholic rite; for example, the prayer, “Receive the power to offer the Sacrifice to God and to celebrate Masses for the living and the dead.” Cranmer, Ridley and his associates, influenced by the continental Zwinglians Peter Vermigli and Martin Bucer, intentionally saw to it that the English Church was pulled away from the ecclesiology of Catholic tradition and planted firmly in the sphere of reformed principles. (5) This would be a crucial consideration in Apostolicae Curae‘s discussion of sacramental intention and its power to validate or invalidate the sacraments.
All Anglican ordinations were done according to the Edwardine Ordinal up to 1662, a span of 110 years. In 1662, under the brief tenure of Archbishop William Juxon, the rite was revised to include a fuller definition of the nature of the priesthood being imparted. The new words added were, in the case of ordination to the priesthood, “for the office and work of a priest in the Church of God now committed unto thee by the imposition of our hands,” spoken after the words “receive the Holy Ghost.” (6) Juxon was the first to hold the see of Canterbury after the Stuart Restoration and was influenced by his friend and predecessor Archbishop William Laud, whose High Church theology had so offended the English Puritans that it cost him his head.
It was not until the Oxford Movement in the mid-19th century, with its intense focus on the Catholicity of the Anglican Church, that the validity of Anglican Holy Orders became a very pressing topic among English ecclesiastics. Many Anglicans who followed the Low Church tradition of Cranmner and the Puritans held that the question was irrelevant because the whole concept of a sacrament of Holy Orders was a popish innovation. The Oxford men, on the other hand, had a firm conviction in not only the reality of the sacrament of Holy Orders but of its importance in the sacramental life of the Church. It was therefore essential that they establish the validity of their own ordinations if their claims to the Catholicity of the English Church were to have any substance.
Thus were the state of things when Leo XIII published Apostolicae Curae on September 18th, 1896. It is interesting to note that, despite the subsquently divisive nature of this document, Pope Leo XIII initially issued it in order to promote ecumenism, “in the hope that our teaching might both strengthen Catholics and bring the saving light to those divided from us.” (7) Leo had a profound understanding of the connection between clear proclamation of the faith and ecumenical dialogue. For Leo XIII, all dialogue had to be based upon an open and frank discussion about the real differences between Catholics and Anglicans, rather than on a reserved commendation of their similarities. Leo was not looking to simply dialogue with the Anglicans, but as he says in the ull, to “bring the saving light to those divided from us.” Since the end was not dialogue but reintegration of the English into the Catholic Church, nothing but a concise and defininitive explication of Catholic doctrine would suffice for the task at hand. All real ecumenism has to be based on the truth.
The bull was not well-received by Anglicans, neither by the High Church party for whom it was intended nor by the Low Church party who distrusted Rome anyway. In 1897, the English Archbishops issued their Responsio in which they attempted to argue that the pope had misjudged the Edwardine Ordinal. This was met by a “Vindication of the Bull ‘Apostolicae Curae’” in 1898, issued by Cardinal Vaughn and the English Catholic hierarchy. The Anglican Church continued to protest Rome’s decision into the 20th century, but some Anglicans, taking Leo XIII’s decree to heart, managed to obtain ordinations through some remnants of the Old Catholic Church of the Union of Utrecht, who possess valid ordinations. This caused Cardinal Basil Hume of Westminster to doubt in 1994 that all Anglican ordinations could now be declared invalid with the same certainty that Leo declared them in 1896. (8) Cardinal Ratzinger, however, upheld Leo XIII’s in the 1998 “Doctrinal Commentary on the Concluding Formula of the Professio fidei,” in which he stated that Apostolicae Curae demanded firm and definitive assent of the faithful. (9)
Parker and the Nag’s Head Fable
The bull thus sought to establish on firm and irrefutable doctrinal grounds a practice that the Holy See had already condoned for three centuries: the unconditional ordination of Anglican priests who converted to the Catholic Church. Because the ordinations were unconditional, the rationale for this discipline had to be similarly unassailable. To this end, Pope Leo was eager to distance himself from any speculative or merely circumstantial reason for his declaration. The problem was that for many centuries Catholic apologists had attacked Anglican ordinations precisely on a circumstantial piece of evidence: the ordination of Dr. Matthew Parker as Archbishop of Canterbury in 1559.
Matthew Parker had been the private chaplain of Anne Boleyn and a friend of Martin Bucer, the German Protestant luminary. Parker somehow managed to pass the reign of Queen Mary in England unmolested and was elected Archbishop of Canterbury on August 1st, 1559 once Elizabeth was on the thone. However, given the ecclesiastical choas that surrounded the death of Queen Mary and the ascension of Elizabeth, it was difficult to find any qualified bishops who were willing to consecrate Parker. Every see was vacant following the Act of Uniformity (1559), except for the see of Llandalf, whose bishop refused to consecrate Parker. It was thus not until December 17th of that year that he was finally consecrated in Lambeth by William Barlow, formerly Bishop of Bath and Wells, John Scory, former Bishop of Chichester, Miles Coverdale, formerly Bishop of Exeter, and John Hodgkins, Bishop of Bedford. All subsequent Anglican ordinations came through Parker, and so for many years the arguments on both sides of the controversy understandably centered around whether Parker had been validly consecrated. If Parker’s ordination were invalid, all subsequent Anglican ordinations would be ipso facto null.

A further point of contention was the so-called “Nag’s Head Fable,” a legend arising during late Elizabethan times which asserted that Parker had received his ordination in Nag’s Head Tavern at Cheapside by having a Bible placed on his head while Scory simply said, “Preach the Word of God sincerely,” the implication being that Parker wasn’t ordained according to any ritual whatsoever, Anglican or otherwise. (10) The Nag’s Head Fable story was repeated by Catholic polemicists up until the turn of the 20th century, when many different proofs emerged to confirm that Parker was indeed consecrated in a ceremony using the Edwardine Ordinal. The consecration of Parker was done in great secrecy (as the Catholic party was still fairly strong in 1559), and this secrecy made the Nag’s Head Fable more believable in the polemical years of Elizabeth’s reign.
Because one can never rest a universally binding and infallible dogmatic pronouncement upon such circumstantial historical evidence, Leo XIII sought to shift the issue away from questions of Parker’s ordination to the firmer ground of Catholic sacramental theology. He says of his judgment, “[A]lthough it refers to a particular case, it is not based upon any reason special to that case, but upon the defect of form, which defect equally affects all these ordinations…” (11) Before making his case from sacramental theology, Leo lays the groundwork for the judgment by appealing to the long-standing practice of the Holy See in such cases, establishing a strong argument from precedent. Understanding that the Church interprets its current actions in light of previous decisions, Leo seeks in paragraphs 1-23 to set forth what the perennial practice of the Church was with regards to handling Anglican ordinations. To this end, Pope Leo appointed Cardinal Mazzella to head up a commission of twelve who were to reexamine all documents in the Vatican Archive touching on the issue and to express their opinions in writing in order to see what was “the settled custom of the Apostolic See, the origin and force of which custom it was undoubtedly of great importance to determine.” (12)
The argument from precedent is based on two sets of evidence: first, many letters from Pope Julius III (1549-1555) and Paul IV (1555-1559) from the time of the legature of Cardinal Pole in England (13) in which the topic of ordination was discussed; second, the practice of the Holy See of unconditionally ordaining converts from the Anglican clergy. A cursory examination of these historical actions in paragraphs 1-23 lays the groundwork for the sacramental argument in paragraphs 21-41 of the document. Let us look briefly at these historical precedents.
Historial Precedents
Pope Julius III issued a letter to Cardinal Reginald Pole on March 8th, 1554 wherein the first mention is made of a distinction between those English priests who are “rightly and lawfully promoted” and those who are “not promoted to Holy Orders,” but might be permitted to, “if they were found worhty and fitting subjects.” (14) This division of those “rightly and lawfully promoted” and those who are “not promoted” seems to suggest that even at this early date the papacy already regarded those ordinations done by the Edwardine Ordinal to be invalid. A further letter from Julius III to Pole in January of 1555 mentions those priests who had received their consecration “irregularly…and not according to the accustomed form of the Church.” (15) This statement is striking because it not only recognizes the fact that certain priests in the realm were consecrated irregularly, but that this irregularity was due in part to the ordination being “not according to the accustomed form of the Church.” Though undeveloped, this seems to be the first instance of a pope citing form as a problem with Anglican ordinations specifically.
On the advice of Pole, “the Sovereign Princes, Philip and Mary” (16), and the Royal Ambassadors to the papacy, Pope Paul IV issued his bull Praeclara Charissimi in June of 1555, which was meant to ratify and confirm all of the work of Pole in the Kingdom of England. In this bull he makes the following declaration: “Those who have been promoted to major as well as minor ecclesiastical Orders, by any other person than a bishop or an archbishop duly and rightly ordained shall be bound to receive the said Orders anew from their ordinary, and shall not in the meanwhile minister in the said Orders.” (17) This declaration was confirmed with the highest authority of the Apostolic See, and of this decision Paul IV says a few lines down, “We, by the aforesaid Apostolic authority and with certain knowledge approve and confirm, and give to them the full and perpetual force of inviolable stability, making good all and singular defects of law or of fact, if any such there should be in the same, and We decree all these things to be valid and efficacious, and to have their full effect.” (18)
The bull Praeclara Charissimi really ought to have been the end of the controversy, save for the fact that Paul IV failed to make sufficiently clear who those bishops were who were not “validly and lawfully ordained.” Essentially, Paul’s statement is a tautology: those who did not possess valid Holy Orders did not have valid Holy Orders, something everybody already knew. What was needed was a declaration of who did not possess valid Holy Orders and why. Cardinal Pole had already formulated an opinion on the matter in a letter to the Bishop of Norwich, in which he said that the rite of the Edwardine Ordinal lacked “the form and intention of the Church.” (19) This would be the basis of the judgment reached in Apostolicae Curae three and a half centuries later.

Besides these documents, the commission under Cardinal Mazzella also reviewed two important cases from the late 17th and early 18th centuries: the ordinations of two men into the Catholic Church, both of whom had received prior ordinations according to the Edwardine Ordinal. The first was the case of a French Calvinist in 1684, the second of the former Anglican John Clement Gordon in 1704. In the first case, a body of consultors were assembled who thoroughly examined the ordination rite and voted that the Frenchman needed unconditional ordination, though they failed to forumlate a specific reason for their judgment. The same criteria were applied in the matter of Gordon, whose case was examined by theologians as far away as the Sorbonne and Douai. (20) Everybody who looked at the Gordon case agreed that the Anglican ordination was defective, but different reasons were given: some, for example, wanted to base the judgment on the Nag’s Head Fable and the invalidity of Parker’s ordination. (21) The final judgment, however, stated that any questions relating to Parker’s ordination were set aside, “nor, in pronouncing the decision, was weight given to any other reason than the ‘defect of form and intention.’”(22) Thus it was on April 17th, 1704, that Pope Clement XI decreed that John Clement Gordon be ordained, “from the beginning and unconditionally,” to the priesthood. (23)
Commenting on the abundance of evidence from precedent, Leo XIII states that “it must be clear to everyone that the controversy lately revived had already been definitely settled by the Apostolic See” (24) and cites ignorance of the pertinent papal documents for the reason why some were still questioning the Holy See’s decision on this matter. In his eyes, the question was already settled. Nevertheless, he uses the conclusion of Clement XI, that Gordon’s Anglican ordination had been invalid on grounds of defect of form and intention, to launch into the second part of the bull: the examination of the Edwardine rite itself and the sacramental theology behind the long-standing discipline of the Church, so that, as he said at the beginning of the document, “all doubt, or even shadow of doubt, should be removed for the future.” (25)
The Sacramental Theology: Defect of Form
The fact that Archbishop Juxon revised the Edwardine Ordinal in 1662 to include a more sacramental theology of Holy Orders (in keeping with the High Church realignment after the Restoration) is ultimately irrelevant to the case, since the defective Ordinal had been used for 110 years prior to the 1662 revision, thus causing the extinction of apostolic succession in the English Church. As Leo XIII said, “[Juxon’s revision] was introduced too late, as a century had already elapsed since the adoption of the Edwardine Ordinal, for, as the Hierarchy had become extinct, there remained no power of ordaining.”(26) In other words, by the time of the Juxon revision, England had been using the defective ordinal so long that anyone who possessed valid ordinations from the time of Queen Mary would have been long dead. Thus, even a return to valid form under Laud and Juxon could not restore validity to the sacrament, since a prequisite for valid Holy Orders is a validly ordained minister, and this was precisely what was rendered lacking by the institution of the Edwardine Ordinal a century prior. It is interesting to note, however, that Pope Leo takes the fact of the Juxon revision of 1662 as evidence that even the Anglicans themselves must have considered the original rite to be defective, otherwise, why the need for a revision? (27)
But putting aside the irrelevancy of the Juxon revisions, Leo goes back to the sacramental theology of the original rite as promulgated by Cranmer and Somerset. Following the precedent pioneered by Cardinal Pole, Leo says the Anglican rite is defective on two counts: form and intention. Furthermore, the defect of form is itself twofold: a defect of the actual words of ordination, as well as a defective sign value. It is important to emphasize Leo’s judgment that a defect of form occurred not because words were changed or extraneous ones added, but simply because some were omitted. As we have seen above, the Anglican ordinal left out any references to a sacrificing priesthood. This created a serious problem, because the essence of the priesthood is of “ consecrating and offering the true Body and Blood of the Lord” as a sacrifice to God the Father. (28) The spiritual reality of any sacrament is brought about by the right form attached to the proper matter. Since the Edwardine Ordinal omitted any reference to sacrifice, the chief activity of a priest, its form was incapable of conferring the powers of consecration upon the recipient.
Connected with this defect of form is the aspect of a defective sign value, and this has to do with specifically why the form is defective. By defect of form, we understand a lack or fault with the words used in the rite. Sign value, on the other hand, refers to what is symbolized by the sacrament, in both its form and its matter. Thus, in baptism, the rite has the sign value of representing washing or cleansing of the soul, which is actually accomplished through the ritual. All sacraments must have the proper sign value so that the invisible grace that they impart is rendered clearly intelligble to the senses. In fact, this is the textbook definition of sacrament: “an outward sign instituted by Christ to give grace.” (29) Leo also points out, however, that “[a]lthough the signification ought to be found in the whole essential rite, that is to say, in the “matter and form,” it still pertains chiefly to the “form”; since the “matter” is the part which is not determined by itself, but which is determined by the “form.” (30) Therefore, form and sign value are closely interwined.

Loss of sign value is what renders the form of Anglican ordination defective. Offering the Holy Sacrifice of the Mass is the chief work of the priest and is the very nature of what the priesthood is. Therefore, the sacrament conferring the priesthood must symbolize the reality that it confers.
But the Edwardine Ordinal, because of its omission of any reference to a sacrificing priesthood, has a defective sign value and therefore cannot give “form” to the matter. Therefore, no sacrament emerges, because the words “Receive the Holy Ghost,” in themselves, “certainly do not in the least definitely express the sacred Order of the Priesthood (sacerdotium) or its grace and power…[t]hat “form” consequently cannot be considered apt or sufficient for the Sacrament which omits what it ought essentially to signify.”(31) Because man consists of body and soul, God has thought it fitting that sacraments should be visible and perceivable to the senses. A sacrament cannot be valid that is unable to signify its invisible reality, whether in its form or matter.
The Sacramental Theology: Defect of Intenion
Following Cardinal Pole centuries before, Pope Leo cites defect of intention as another reason for the invalidity of Anglican orders. This was an important point to add, for otherwsie the Pope’s argument could have been in jeopardy for two reasons: first, as some High Church Anglicans attempted to maintain, the words of the Edwardine Ordinal would not be problematic at all if they were simply interpreted in an orthodox light. Second, as was pointed out in the 1897 Anglican “Responsio” to the Bull, the Catholic rites of Ordination prior to the Reformation were not any more definitive with regards to the sacrificial nature of the priesthood than the Edwardine Ordinal. Both of these are serious difficulties, and Leo sees them both as issues relating to intention in the sacrament.
Leo starts by explaining that the omissions of the Anglican rite have to be interpreted in light of the circumstances under which they were produced. The lack of a sacrificial element to the rite is no accident; it was a conscious attempt on the part of its creators to promulgate a novel theological understanding of the priesthood devoid of any of the Catholic element of sacrifice. “For this reason,” says Pope Leo, “there [is] no clear mention of the sacrifice, of consecration, of the priesthood, and of the power of consecrating and offering sacrifice but, as we have just stated, every trace of these things which had been in such prayers of the Catholic rite…was deliberately removed and struck out.” (32)
Knowing the reason why the Ordinal was composed the way it was, Leo says that we must look at it not as an isolated text to be interpreted as we see fit, but in the context of its authors’ intent. This is what he calls the “native character or spirit” of the Ordinal. (33) Thus, it is insufficient to simply say that the Ordinal can be interpreted in an orthodox sense, for words that are by their very nature ambiguous “cannot be taken in the same sense as they possess in the Catholic rite.” (34) This also answers the other argument: that pre-Reformation Catholic rites were just as ambiguous in their wording as the Edwardine Ordinal. Even if this were the case, we would distinguish between the intention of the Church in ordaining priests to offer the Eucharistic sacrifice and the intent of the Anglican reformers who abhorred all notion of a sacramental sacrifice. This is the principle behind why, for example, a baptism carried out by a priest with the correct matter and form is valid, but a actor performing the exact same rite in a film with no intent to baptize is not performing a valid baptism. Intent to do what the Church does gives power to the form; without it, the words of the form “remain as words without the reality which Christ instituted.” (35)
But is Pope Leo perhaps not going down a path that might later prove problematic with this emphasis on intention? After all, if he can cite lack of intention as a criterion for declaring a sacrament invalid, then how can we ever presume that any sacrament is ever valid, since we are unable to know the intentions of the officiating minister? And how can we rule definitively on such a matter, since it is something essentially internal? To answer this difficulty, Leo distinguishes between the intention of the minister himself and the intention of the creators of the rite. Of course the Church can never judge the heart of a priest in his intention since it is purely internal. But, “in so far as it is manifested externally she is bound to judge concerning it.” (36) Any priest who uses the correct matter and form is presumed for that very reason to be intending to do what the Church intends, and so the sacrament is presumed to be valid unless some other complicating circumstance arises.
A Catholic priest carrying out the prescribed form of the Church, however, is entirely different from the alteration of an entire rite itself by heretics. Leo says, “If the rite be changed, with the manifest intention of introducing another rite not approved by the Church and of rejecting what the Church does, and what, by the institution of Christ, belongs to the nature of the Sacrament, then it is clear that not only is the necessary intention wanting in the Sacrament, but that the intention is adverse to and destructive of the Sacrament.”(37) In other words, it is irrelevant what the intention of the individual priest is if the intention of the creators of the rite itself was contrary to the intention of the Church, which we know it was. For example, Cranmer’s Forty-Two Articles of 1553, Article XXXI states the following: “Wherefore the sacrifices of Masses, in the which it was commonly said that the priests did offer Christ for the quick and the dead to have remission of pain or guilt, were blasphemous fables and dangerous deceits.” It was this same Cranmer who authored the Edwardine Ordinal. Knowing his view of the Mass and his intention in removing the sacrificial language from the rite, it becomes evident that the character of the Edwardine rite negates any possible orthodox interpretation, and any such attempted interpretation must fail because of the manifest intent of the creators of the rite to disengage from any Catholic concepts of a sacrificing priesthood. (38)
Setting the stage by looking at historical precedent set by prior actions of the Holy See and laying out the case against the Edwardine Ordinal based on the sacramental principles of form, sign value and intention, Pope Leo goes on to definitively rule on the question: “Wherefore, strictly adhering, in this matter, to the decrees of the pontiffs, our predecessors, and confimring them most fully, and, as it were, renewing them by our authority, of our own initiative and certain knowledge, we pronounce and declare that ordinations carried out according to the Anglican rite have been, and are, absolutely null and utterly void.” (39)

The Importance of the Letter
Apostolicae Curae is one of the most important magisterial documents relating to sacramental theology. First and foremost, the bull reiterates the objective nature of the sacraments, the fact that they confer grace ex opere operato. In response to Apostolicae Curae, some Anglicans have subsequently appealed to an experiential argument; i.e., that the validity of Anglican orders are attested to by the piety and devotion found in the Anglican Church. This, of course, is a misunderstanding of the nature of the sacraments. Nobody has denied that one may have pious devotional feelings, sometimes motivated by grace, from invalid sacraments. The Church has always understood that God is not bound by the sacraments; grace is available ex opere operantis to whomever is open to receive it by interior acts of piety and faith. God is capable of giving grace producing authentic piety even through an invalid sacrament. This was never in question and has no bearing in the discussion of Anglican orders. The question is not whether or not Anglicans experience joy, piety and peace in their worship of God. Rather, the question is whether or not Anglican orders are objectively valid. Apostolicae Curae reminds us of the objective nature of the sacraments and the importance of attention to detail in their administration.
Second, the bull establishes beyond doubt the place of intention in sacramental theology. Pope Eugene IV and the Council of Trent had already affirmed this (40), but Apostolicae Curae is the most thorough and important reaffirmation of the principle in modern times. Both the matter and form of the sacraments come from Christ and are there for a specific reason. Any attempt to arbitrarily modify or delete certain elements of the essential rite can be considered as ideologically motivated, and if the motivation of those proposing alterations to the rite differs from the intentions of the Church, then the validity of the sacrament is jeopardized. In the case of Anglican orders, the manifest intention to negate the sacrificial aspect of the priesthood invalidated the sacrament entirely.
Third, the bull exemplifies the Church’s conservatism with regards to sacraments where the exact form is not known in specie but in genere. In the case of Holy Orders, some critics attacked Leo XIII on the grounds that he condemned Anglican orders as suffering from defect of form when the Catholic Church itself was not able to say definitively in what words of her own rite the essential form of Holy Orders was contained. In the case of baptism, the Church can point to an exact phrase (ego te baptismo, in nomine Patris, & Filii, & Spiritus sancti, amen); in other sacraments, such as Holy Orders, we cannot point to one specific phrase with certainty as being the form. Nevertheless, we can have confidence that the rite of the Church as it was handed down contains within itself the proper form. For this reason, though different prayers and customs accumulate around various rites over the centuries, Leo says the Church has followed the practice of allowing additions but never subtractions, for fear that she might remove something essential. This is why the omissions of the Edwardine Ordinal were such a grave matter.
Finally, Apostolicae Curae presents a clear-cut methodology of how current Church praxis ought to be established in light of tradition and how papal decrees are based on precedent. In reaching his conclusions, Leo did not conjure up a new discipline out of nowhere, but set up a commission to look into what previous papal practice had been regarding the issue. In studying at the writings of Pole, the unconditional ordination of John Clement Gordon, and the practice of the Holy See from the Reformation up to his own day, Leo considered ordination of Anglican converts a “settled custom” and the issue of Anglican ordinations as having “already been definitively settled by the Apostolic See.” (41) Thus, the declaration of Apostolicae Curae is seen to be a clarification and reiteration of what had already been established Church discipline for several centuries, not as a novel innovation. Leo almost seems to take the attitude of incredulity that anybody still thought the question open for debate, (42) but sees the judgment of the bull as a chance to clarify and uphold previous papal teaching, “adhering…to the decrees of the pontiffs, our predecessors, and confirming them most fully, and as it were, renewing them.” (43) Current teaching is interpreted in light of tradition.
In its treatment of sacramental theology and in its methodological use of tradition and precedent in establishing contemporary Church discipline and dogmatic formulations, Pope Leo XIII’s Apostolicae Curae remains indispensible for the serious student of Catholic theology and is one of the pivotal documents of the inter-Conciliar period.
If you’d like to learn more about the life and thought of Pope Leo XIII, pick up a copy of The Life of His Holiness Pope Leo XIII by Richard H. Clarke (Cruachan Hill Press, 2024)
(1) Pope Leo XIII, Apostolicae Curae, 4
(2) Ibid.,6, 3
(3) Ibid., 8
(4) The issuanceof the new ordinal was but one part of a larger series of reforms put into effect under the sanction of the Act of 1550, which, among other things, banned the use of Mass books and images in churches in an attempt to further sunder the English Church’s connection to it’s Catholic past.
(5) Both Bucer and Vermigli were invited to England by Cranmer and exerted a profound influence on his thinking, which was later demonstrated in the “reformed” tone of the Book of Common Prayer.
(6) In the case of the episcopate, the new addition read, “Receive the Holy Ghost for the office and work of a bishop in the Church of God now committed unto thee by the imposition of our hands.”
(7) AC, 1
(8) “While firmly restating the judgment of Apostolicae Curae that Anglican ordination is invalid, the Catholic Church takes account of the involvement, in some Anglican episcopal ordinations, of bishops of the Old Catholic Church of the Union of Utrecht who are validly ordained. In particular and probably rare cases the authorities in Rome may judge that there is a “prudent doubt” concerning the invalidity of priestly ordination received by an individual Anglican minister ordain in this line of succession. There are many complex factors which would need to be verified in each case…Of course, if there were other cases where sufficient evidence was available, the balance of that evidence may lead the authorities to reach a different judgment.” Statement of Cardinal Hume on the Ordination of Anglican Bishop Leonard as a Roman Catholic Priest”, The Catholic Resource Network, Trinity Communications, 1994. [http://www.ewtn.com/library/ISSUES/LEONARD.TXT ]Retrieved on 2007-12-05
(9) Congregation for the Doctrine of the Faith, “Doctrinal Commentary on the Concluding Formula of the Professio fidei”, No. 11.
(10) Some of these proofs included the discovery of an eyewitness account of Parker’s consecration, as well as an entry in the Lambeth “Register” of Parker’s consecration on that day, which was acknowledged as early as 1614 but was not widely known until later.
(11) AC, 21
(12) Ibid., 6
(13) Upon the death of Edward VI in 1553, Pole was appointed legate in England where he labored for the reform and reestablishment of the Church until his death in 1558.
(14) AC, 9
(15) Ibid., 10
(16) Ibid., 11
(17) Praeclara Charissimi, 318
(18) Ibid., 4
(19) Pole to Bishop of Norwich, quoted in Apostolicae Curae, 12
(20) “In order that the judgment concerning this form might be more certain and complete, precaution was taken that a copy of the Anglican Ordinal should be submitted to examination, and that with it should be collated the ordination forms gathered together from the various Eastern and Western rites.” AC, 20
(21) Gordon himself seems to have taken this position.
(22) AC, 20
(23) Ibid.
(24) Ibid., 22
(25) Ibid., 3
(26) Ibid., 26
(27) “This form had, indeed, afterwards added to it the word “for the office and work of a priest,” etc.; but this rather shows that the Anglicans themselves perceived that the first form was defective and inadequate.” (ibid.)
(28) Council of Trent, Sess. XXIII, de Sacr. Ord., Canon 1
(29) Baltimore Catechism, part 2, q. 136
(30) AC, 24
(31) Ibid., 25, 27
(32) Ibid., 30
(33) Ibid., 31
(34) Ibid.
(35) Ibid.
(36) Ibid., 33
(37) Ibid.
(38) See also the 1646 Westminster Confession, where the Anglican divines declared the following about the Mass: “In this sacrament, Christ is not offered up to His Father; nor any real sacrifice made at all, for remission of sins of the quick or dead; but only a commemoration of that one offering up of Himself, by Himself, upon the cross, once for all: and a spiritual oblation of all possible praise unto God, for the same: so that the popish sacrifice of the mass (as they call it) is most abominably injurious to Christ’s one, only sacrifice” (Article XXIX).
(39) AC, 36
(40) “All these sacraments are dispensed in three ways, namely, by things as the matter, by words as the form, and by the person of the minister conferring the sacrament with the intention of doing as the Church does; if any of these is lacking the sacrament is not fulfilled” (Pope Eugenius IV, Exultate Deo, 1439, Denzinger 695).
(41) AC, 6,22
(42) Listen to Leo’s language here: “Then, considering this matter, although already decided, had been by certain persons for whatever reason recalled into discussion, and that thence it might follow that a pernicious error would be fostered in the minds of many who might suppose that they possessed the Sacrament and effects of Orders, where these are nowise to be found, it seemed good to Us in the Lord to pronounce our judgment” (Ibid., 35).
(43) Ibid., 36
Phillip Campbell, “The Sacramental Theology of Apostolicae Curae,” Unam Sanctam Catholicam, June 22, 2026. Available online at: https://unamsanctamcatholicam.com/2026/06/the-sacramental-theology-of-iapostolicae-curae-i

