David Garciandía Igal, COVID-19 regulations on religious freedom in the United Kingdom and the response of the Catholic Church in England and Wales

1. Introduction

The COVID-19 pandemic has affected almost every country in the world. The United Kingdom is not an exception. However, stricter measures have been taken several days after most major European countries. As an example, the Spanish Government declared the state of alarm on 14 March (which came into force at the time of its publication in the Official State Gazette)[1], under article 116.2 of the Spanish Constitution of 1978[2] and in accordance with the ‘Organic Law 4/1981’[3]. On that date, there were already 6,391 confirmed cases and 196 deaths. On the other hand, in the United Kingdom, the ‘Coronavirus Act 2020’[4], which could be considered as its equivalent in legal terms, was granted Royal Assent on 25 March[5] (although it was introduced to Parliament on 19 March). At that point, there were 9,529 confirmed cases and 694 deaths. However, leaving political controversies aside, the main goal of this article is to analyse COVID-19 regulations on religious freedom in the United Kingdom and the response of the Catholic Church in England and Wales.

Under the extremely difficult circumstances produced by the COVID-19 infection, the Government has taken several measures in order to reduce its effects. Limitations of rights and freedoms outstand among them. This kind of provisions do not necessarily violate, in itself, freedom of religion in the United Kingdom (which in the case of public religious services is exercised through the right to freedom of peaceful assembly[6]), because religious freedom is not conceived as an unlimited and absolute right. In every Western legal system[7], as well as in the international treaties[8], freedom of religion is configured as a right under the limits of some public interests (such as health) or the rights of others.

Specifically, Article 9 of the ‘Human Rights Act 1998’[9] subject freedom of religion to five kind of limits (which must be necessary and prescribed by law): (i) “public safety“, (ii) “public order“, (iii) “health“, (iv) “morals“, and (v) “rights and freedoms of others“. In the same vein, Article 11 of the same Law subject freedom of assembly to five similar limits (which must be necessary and prescribed by law as well): (i) “national security or public safety“, (ii) “prevention of disorder or crime“, (iii) “health“, (iv) “morals“, and (v) “rights and freedoms of others“. In this regard, the faculty to prohibit or restrict specific public religious activities, such as Mass gatherings or funerals, is fully legitimate under the coronavirus exceptional circumstances. This capacity of the Government fit both in the “health” category and in the protection of “rights and freedoms of others” category (regarding the right to life). Therefore, that kind of restrictions are not additional and excessive limitations of freedom of religion or freedom of peaceful assembly[10], but intrinsic limits of both rights.

The main legal document with implications for religious freedom under current COVID-19 circumstances is the mentioned Coronavirus Act 2020, which is time-limited for two years[11], and enable the Government large powers in order to take a variety of measures. Provisions on (i) prohibitions and restrictions of public events, gatherings and premises, and (ii) the management of funerals, are particularly significant. Let’s analyse them separately.

2. Prohibitions and restrictions on events, gatherings and premises

The Coronavirus Act 2020 states in its Schedule 22, Part 2, paragraph 5, that “the Secretary of State may for the purpose of (a) preventing, protecting against, delaying or otherwise controlling the incidence or transmission of coronavirus, or (b) facilitating the most appropriate deployment of medical or emergency personnel and resources, issue a direction prohibiting, or imposing requirements or restrictions in relation to, the holding of an event or gathering in England“. This provision is crucial to freedom of religion, as it allows the Secretary of State[12] to forbidden or restrict public gatherings in England, such as religious services.

In order to ensure a high degree of guarantees, the Act establishes that the direction “may be issued in relation to (a) a specified event or gathering, or (b) events or gathering of a specified description“. General prohibitions are not allowed under this Act. And these events or gatherings are determined “(a) by reference to a number of people attending the event or gathering, (b) by reference to a requirement for medical or emergency services to attend the event or gathering, or (c) in any other way“. The establishment of this provision ensures that prohibitions are made on the basis of objective, proportional and non-discriminatory criteria. In addition, these directions are time-limited, and “may only be issued during a public health response period“. As we can observe, the Government’s power is bounded not only by objective limits but is also time-limited.

Moreover, the Act affirms that the direction of the Secretary of State “may only have the effect of imposing prohibitions, requirements or restriction on (a) the owner or occupier of premises for an event or gathering to which the direction relates; (b) the organiser of such an event or gathering; or (c) any other person involved in holding such an event or gathering“. However, this last reference “does not include a person whose only involvement in the event or gathering is, or would be, by attendance at the event or gathering“. By the same token, this provision points out the interest of the Parliament in guaranteeing the rights and freedoms of the individuals at the highest level, protecting mere attendants.

In addition, similar requisites must be observed for restrictions and prohibitions imposed on premises and people entering or remaining in them. The Act allows the Secretary of State to issue directions imposing “prohibitions, requirements or restrictions in relation to the entry into, departure from, or location of persons in, premises in England“. In these cases, the prohibitions, requirements or restrictions can bound “(a) the owner or occupier of premises to which the direction relates” or “(b) any other person involved in managing entry into, or departure from, such premises or the location of persons in them“. And those requirements can be imposed “for the purpose of (a) closing the premises; (b) restricting entry into the premises” or “(c) securing restrictions in relation to the location of persons in the premises“. Similar criteria must be taken into account when imposing this kind of measures: “(a) the number of persons in the premises; (b) the size of the premises; (c) the purpose for which a person is in the premises; (d) the facilities in the premises; (e) a period of time“. As we can observe, the Act tries to list a sort of objective criteria in order to guarantee an appropriate use of this power, safeguarding religious freedom and freedom of peaceful assembly at the highest possible level.

The same provisions on the powers conferred on the Government relating to events, gatherings, and premises apply to Scotland (Part 3 of Schedule 22), Wales (Part 4 of Schedule 22) and Northern Ireland (Part 5 of Schedule 22).

Before the Coronavirus Act 2020, the Government published on 16 March a ‘Guidance and advice for those arranging or planning to attend Mass gatherings in the United Kingdom’[13]. The aim was to reduce the social interaction between people. Despite the fact the Government recognised that the risks of transmitting the disease at Mass gatherings were “relatively low“, it advised that “large gatherings should not take place“, in line with the general recommendations at that time. However, the Act was granted Royal Assent on 25 March, and stricter measures were taken after this guideline was released.

The Government, in the framework of the powers conferred by Parliament through the Coronavirus Act 2020, issued ‘The Health Protection (Coronavirus, Restrictions) (England) Regulations 2020’[14] on 26 March, which entry into force the same day. Section 7 regulates the restrictions on gatherings, establishing that “during the emergency period, no person may participate in a gathering in a public place of more than two people except (a) where all the persons in the gathering are members of the same household, (b) where the gathering is essential for work purposes, (c) to attend a funeral, (d) where reasonably necessary: (i) to facilitate a house move, (ii) to provide care or assistance to a vulnerable person, including relevant personal care within the meaning of paragraph 7(3B) of Schedule 4 to the Safeguarding of Vulnerable Groups Act 2006, (iii) to provide emergency assistance, or (iv) to participate in legal proceedings or fulfil a legal obligation“. It should be noticed as well that ministers of religion or worship leaders are able to leave the place where they are living to go to their place of worship, according to Section 6, paragraph 2 (k). This statutory instrument gave legal force to the social distancing rules announced by the Prime Minister on 23 March and prohibits Mass gatherings (except funerals under strict requisites).

The original guidance for Mass gatherings referred to the ‘Guidance on social distancing for everyone in the UK’[15], published on 30 March. The social distancing measures promoted by this document pretend “to avoid large and small gatherings in public spaces, noting that pubs, restaurants, leisure centres and similar venues are currently shut as infections spread easily in closed spaces where people gather together“. This guidance was withdrawn on 1 May 2020 and replaced by a new document titled ‘Guidance: Staying at home and away from others (social distancing)’[16], were stricter advice is given. In line with The Health Protection (Coronavirus, Restrictions) (England) Regulations 2020, prohibitions on public gatherings and places of worship, with the exception of funerals, are set out in the document.

3. Special regulations on the management of funerals

The Coronavirus Act 2020 includes several provisions on the management of the deceased in Schedule 28, conferring special powers for local authorities and Government to support the resilience of local death management systems, and step in if they become overwhelmed. In this line, the Government released a ‘Guidance for care of the deceased with suspected or confirmed coronavirus (COVID.19)’[17], with its last update on 20 April, and an additional ‘Statutory guidance for local authorities on Schedule 28 and the Powers in Relation to Transportation, Storage and Disposal of the Deceased’[18].

However, more significant for the study of religious freedom is the mentioned provisions of ‘The Health Protection (Coronavirus, Restrictions) (England) Regulations 2020’ (THPR, now on), issued on 26 March. According to Section 7, it is possible to participate in a funeral with more than two people (the general rule is that no person is permitted to participate in gatherings in public places of more than two people). Nevertheless, according to Section 6, paragraph 2 (g), only members of the person’s household or close family members are allowed to attend the funeral. Only in the case that no-one in these categories attends, then friends would be permitted to assist, although the number of friends attending the funeral should be modest.

This exception to the general rule should be inspired by the ‘Guidance for managing a funeral during the coronavirus pandemic’[19], published on 19 April (and police should take this document into account when weighing the circumstances up and evaluating the situation before fining people). Its main principles are to ensure that “bereaved people are treated with sensitivity, dignity and respect” and “mourners and workers involved in the management of funerals are protected from infection“. In the background, the principles that need to be balanced are, on the one hand, freedom of religion and the right to peaceful assembly (specifically, as expressed in the guideline, “the needs of the bereaved to mourn appropriately“), and, on the other hand, public health interests (as expressed in the guideline, “minimising the spread of coronavirus infection“).

Although this guideline does not have legal force, it is extremely useful for authorities in order to interpret and apply properly the provisions established in THPR. In this sense, the guideline affirms that, in addition to members of the person’s household, close family members, or friends (if the above are unable to attend, as established in the mentioned regulation), the Funeral Director, the funeral staff, the Chapel Attendant and a celebrant of choice (should the bereaved request it) may also attend the funeral. However, the organisers should “restrict the number of mourners who attend so that a safe distance of at least 2 metres (6ft) can be maintained between individuals“. In the same line, “the size and circumstance of the venue will determine the maximum number that can be accommodated“. Additionally, mourners who are self-isolating or those who are vulnerable should be facilitated to attend the funeral in person. Only those mourners who are showing coronavirus symptoms should not attend the funeral. These provisions are totally reasonable and proportionate, and match an expansive vision of religious freedom.

Preventive measure should be taken in the funeral, such as “handwashing facilities with soap and hot water and hand sanitiser“, or ventilation “by opening windows and doors where possible“, as well as ensuring “that processes are in place to allow a suitable time to clean and disinfect the area in which the service has taken place both before and after each service, paying attention to frequently touched objects and surfaces, using regular cleaning products“.

Another exception established by THPR in its Section 6, paragraph 2 (ga), is the possibility of leaving the place where a person is living “to visit a burial ground or garden of remembrance, to pay respects to a member of the person’s household, a family member or friend“. The scope of this clause, which was introduced on 22 April as an amendment, encompasses a high level of protection of religious beliefs. In this regard, under a freedom of religion approach, this clause must be considered positively.

4. Response of the Catholic Church of England and Wales

Following public instructions, and after the speech of the Prime Minister on 23 March, the Catholic Church in England and Wales closed all the churches to the public[20]. Cardinal Vincent Nichols announced the measure on 24 March, alleging that “we ought to be good citizens playing our part in the protection of the vulnerable, in our support for the NHS and in the preserving of human life, which is so precious to God in the face of this virus“. The social responsibility shown was exemplary, taking extreme measures the day after the lockdown was announced on 23 March and two days before formal restrictions were established by THPR.

Since then, Mass gatherings have been suspended and even Easter celebrations, which we must bear in mind is the most important tradition in Christianity, were cancelled. In accordance with the ‘Decree for the Celebration of Easter’[21] issued on 25 March by the Congregation for Divine Worship and the Discipline of the Sacraments of the Holy See, Bishops and priests in the United Kingdom celebrated the rites of Holy Week without the presence of the people and avoiding concelebration.

Inability to attend religious services was such a shock for Christian communities, that even the Queen addressed this issue in an unprecedented speech. For the first time, the Queen delivered an Easter message to the nation, on 5 April, in which she said that in those days Easter was needed “as much as ever“. However, far from a passive attitude, the Catholic Church has enabled an online website called ‘Church Services TV’[22], were online religious services are offered. A complete list of churches that have joined the website is available (with 63 churches offering this kind of online services only in England), with a complete schedule of live services for the week. In addition, the Bishops’ Conference of England and Wales has produced prayer materials in order to help Catholics to worship, like the document ‘When Mass cannot be celebrated publicly’[23], ‘An act of Spiritual Communion’[24] or ‘Prayers during a time of ´flu and illness’[25].

Nevertheless, not only Mass gatherings were suspended but also other services offered in parishes. In addition to services with a religious component, such as catechesis or spiritual retreats (which were cancelled too), many social services used to be offered in person. As far as it is possible, all these groups continue to offer their services while avoiding personal contact. This is the case, for example, of Kairos Forum[26], which is a platform were prayer, reflection and resources for people with intellectual disabilities are provided. According to its website, “the aim is to encourage prayer, share stories and accompany each other by linking up with people around the world“. In the same line, the Domestic Abuse Group of the Catholic Bishops’ Conference of England and Wales has issued a ‘Guidance on how Catholic parishes can support victims of domestic abuse during the COVID-19 pandemic’. This guidance offer “information about how parishes can raise awareness of the issue, including a list of helplines and information about how to safely get help“, as well as a “step-by-step starter guide for how parishes can support their local domestic abuse services“[27].

Another significant and inherent service of the Catholic Church is the healthcare ministry. An interim ‘Guidance for engaging in ministry to take the sick during the COVID-19 pandemic’[28] was issued on 15 April. This text upholds that a basic principle during this crisis is “to provide as much pastoral care by telephone as possible, or other non face-to-face means, as a means of reducing the spread of the virus“. For this reason, it provides advice to healthcare workers, volunteers, scientists, priests, caterers and cleaners, among others. In relation to the Holy Communion, the guidance states that it should be spiritual, and bringing the Eucharist to people in hospital with COVID-19 or to those at home, especially self-isolating or ill, should be avoided. Regarding anointing, “the oil stock and any books, etc. should be left outside the room and oil put on either both ends of a cotton bud (one for anointing head, the other hands) or cotton wool pads and then disposed of as clinical waste“. All these measures and advice reflect the strong commitment of the Catholic Church to the religious and social services it provides.

Additionally, it is of particular importance the situation of Catholic charities in the COVID-19 crisis. Poor and isolated people are extremely vulnerable during crises. These are the most sensitive groups to economic crises or pandemics in our societies. In this regard, the Bishops of England and Wales urged Catholics to continue supporting charities and the people they serve during the pandemic. Bishop Terence Drainey, Chair of the Caritas Social Action Network, released a statement[29] expressing the high pressure on Catholic charities due to the COVID-19 outbreak. A loss of income from parish collections has been noticed. This fact, in addition to the increased costs (due to preventive measures) and the fewer number of volunteers, is making the situation more difficult, in a moment were, precisely, charities are working even harder to alleviate poverty and isolation. In this context, Catholic Social Teaching seems more relevant than ever[30].

 5. Conclusions

Given the extraordinary situation produced in the United Kingdom by the COVID-19 pandemic, the Government, within the powers granted in the Coronavirus Act 2020 approved by Parliament, has taken strict measures in order to reduce the effects of the disease. Rights have been temporarily limited as a means to fight against the expansion of the pandemic. In this context, freedom of religion and freedom of peaceful assembly have been restricted. The legitimacy of these restrictions lies in the protection of two principles: health and the right to life of others. These principles represent inherent limits to freedom of religion and freedom of assembly, in accordance with Article 9 and Article 11 of the Human Rights Act 1998, respectively.

In this regard, we consider that restrictions to both freedoms are legitimate and legal. They are not excessive, disproportionate or additional limitations, but rather inherent limits of both freedoms. We must bear in mind that rights and freedoms are not absolute and unlimited. They are delimited by other principles such as public safety, public order, health or the protection of the rights and freedoms of others.

Regulation on religious freedom in the context of the COVID-19 pandemic in the United Kingdom is characterised by a high degree of guarantees and flexible interpretation, allowing the law to accommodate itself to the specific circumstances of particular situations. This approach to individual freedoms fits with one of the countries in the world with a longer Human Rights tradition. COVID-19 legislation on religious freedom in other countries, such as Spain or Italy, has been more restrictive.

It is worth noting the real commitment of the Catholic Church in England and Wales, as well as other confessions such as the Church of England[31], to the social and religious initiatives it was undertaking before the pandemic. The response of the Catholic Church was quick and socially responsible, ordering the closing of churches on 24 March, the day after the lockdown was announced by the Prime Minister and two days before formal restrictions were established by The Health Protection (Coronavirus, Restrictions) (England) Regulations 2020. Masses and other religious activities continue to be offered through online channels to the extent possible. By the same token, non-directly religious activities, such as social care or healthcare, continue to offer services under high-pressure circumstances.

The duration of these measures remains unknown, although some experts forecast a long period. This is the case of Dr. Meirion Evans, a professional adviser to Wales’ chief medical officer, who affirmed that there may be restrictions on Mass gatherings “for quite a long time into the future”[32]. This fact represents a shift in the way social relations and religious freedom are conceived, at least in public. Without any doubt, the COVID-19 pandemic will bring about significant changes in our societies.

David Garciandía Igal, Public University of Navarre, Spain

garciandiad@gmail.com

___________________________________________

[1] Ministry of the Presidency, Relations with the Courts and Democratic Memory. Royal Decree 463/2020, of March 14, declaring a state of alarm due to the management of the health crisis situation caused by COVID-19. Official State Gazette, No. 67, 14 March 2020. Available at: https://www.boe.es/boe/dias/2020/03/14/pdfs/BOE-A-2020-3692.pdf.

This Royal Decree was partially amended by Ministry of the Presidency, Relations with the Courts and Democratic Memory. Royal Decree 465/2020, of March 17, amending Royal Decree 463/2020, of March 14, declaring a state of alarm due to the management of the health crisis situation caused by COVID-19. Official State Gazette, No. 73, 18 March 2020. Available at: https://www.boe.es/boe/dias/2020/03/18/pdfs/BOE-A-2020-3828.pdf.

[2] General Courts. The Spanish Constitution. Official State Gazette, No. 311, 29 December 1978. Available at: https://www.boe.es/legislacion/documentos/ConstitucionINGLES.pdf

[3] Head of State. Organic Law 4/1981, of June 1, on the states of alarm, emergency and siege. Official State Gazette, No. 134, 5 June 1981. Available at: https://www.boe.es/buscar/act.php?id=BOE-A-1981-12774.

[4] Parliament of the United Kingdom. Coronavirus Act 2020, c. 7. 25 March 2020. Available at: http://www.legislation.gov.uk/ukpga/2020/7/contents.

[5] As a point of interest, on the same day Spain, with 3,434 deaths, reached the world’s second-highest tally of coronavirus deaths, surpassing China, with 3,285 deaths, and only behind Italy, with 6,820 deaths.

[6] See article 11.1 of the Human Rights Act 1998: “Everyone has the right to freedom of peaceful assembly and to freedom of association with others, including the right to form and to join trade unions for the protection of his interests“. Available at: http://www.legislation.gov.uk/ukpga/1998/42/schedule/1/part/I/chapter/10

[7] See, for example, article 16.1 of the Spanish Constitution: “Freedom of ideology, religion, and worship of individuals and communities is guaranteed, with no other restriction on their expression than may be necessary to maintain public order as protected by law“. Available at: https://www.boe.es/legislacion/documentos/ConstitucionINGLES.pdf

[8] See, for example, article 18.3 of the International Covenant on Civil and Political Rights: “Freedom to manifest one’s religion or beliefs may be subject only to such limitations as are prescribed by law as are necessary to protect public safety, order, health, or morals of the fundamental rights and freedoms of others“. Available at: https://treaties.un.org/doc/publication/unts/volume%20999/volume-999-i-14668-english.pdf

[9] Parliament of the United Kingdom. Human Rights Act 1998, c. 42. 9 November 1998. Available at: http://www.legislation.gov.uk/ukpga/1998/42/schedule/1

[10] About the limits of freedom of assembly under current coronavirus circumstances, there has been some legal precedents in Europe. In this regard, we can observe two recent constitutional decisions with different effects. On the one hand, the Federal Constitutional Court of Germany (Bundesverfassungsgericht) resolved, on 16 April, in favour of freedom of assembly under strict preventive measures (available at: https://www.bundesverfassungsgericht.de/SharedDocs/Entscheidungen/DE/2020/04/rk20200415_1bvr082820.html), whereas the Constitutional Court of Spain (Tribunal Constitucional) restricted, on 30 April, freedom of assembly under the coronavirus tight legal framework, due to a balance between the right to life and the right to public assembly, on the basis of the prevalence of the former (available at: https://www.tribunalconstitucional.es/NotasDePrensaDocumentos/NP_2020_047/2020-2056ATC.pdf)

[11] The Act can be shortened or lengthened by six months at ministerial discretion. In that case, the Act will be subject to parliamentary renewal every six months.

[12] The Interpretation Act 1978 affirms that when the legislation makes a general reference to a Secretary of State, without specifying which one, it means “one of Her Majesty’s Principal Secretaries of State“, which nowadays can be created without primary legislation, at the behest of the Prime Minister.

[13] Department for Digital, Culture, Media&Sport, Department of Health and Social Care, Public Health England. Guidance and advice for those arranging or planning to attend Mass gatherings in the United Kingdom. 16 March 2020. Available at: https://www.gov.uk/guidance/covid-19-guidance-for-mass-gatherings

[14] Secretary of State for Health and Social Care. The Health Protection (Coronavirus, Restrictions) (England) Regulations 2020, No. 350. 26 March 2020. Available at: http://www.legislation.gov.uk/uksi/2020/350/contents

[15] Public Health England. Guidance on social distancing for everyone in the UK. 30 March 2020. Available at: https://www.gov.uk/government/publications/covid-19-guidance-on-social-distancing-and-for-vulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-and-protecting-older-people-and-vulnerable-adults

[16] Cabinet Office. Guidance: Staying at home and away from others (social distancing). 1 March 2020. Available at: https://www.gov.uk/government/publications/full-guidance-on-staying-at-home-and-away-from-others/full-guidance-on-staying-at-home-and-away-from-others

[17] Public Health England. Guidance for care of the deceased with suspected or confirmed coronavirus (COVID.19). 20 April 2020. Available at: https://www.gov.uk/government/publications/covid-19-guidance-for-care-of-the-deceased/guidance-for-care-of-the-deceased-with-suspected-or-confirmed-coronavirus-covid-19

[18] Ministry of Housing, Communities and Local Government. Statutory guidance for local authorities on Schedule 28 and the Powers in Relation to Transportation, Storage and Disposal of the Deceased. April 2020. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/880047/Schedule_28_local_death_management_guidance.pdf

[19] Public Health England. Guidance for managing a funeral during the coronavirus pandemic. 19 April 2020. Available at: https://www.gov.uk/government/publications/covid-19-guidance-for-managing-a-funeral-during-the-coronavirus-pandemic/covid-19-guidance-for-managing-a-funeral-during-the-coronavirus-pandemic

[20] Catholic Bishops’ Conference of England and Wales. 24 March 2020. Available at: https://www.cbcew.org.uk/home/our-work/health-social-care/coronavirus-guidelines/no-public-worship/

[21] Congregation for Divine Worship and the Discipline of the Sacraments. In time of Covid-19 (II). 25 March 2929. Available at: http://www.vatican.va/roman_curia/congregations/ccdds/documents/rc_con_ccdds_doc_20200325_decreto-intempodicovid_en.html

[22] Church Services TV. Available at: https://www.churchservices.tv/churches/

[23] Catholic Bishops’ Conference of England and Wales. When Mass cannot be celebrated publicly. Available at: https://www.cbcew.org.uk/wp-content/uploads/sites/3/2020/03/No-Mass-A5.pdf

[24] Catholic Bishops’ Conference of England and Wales. An Act of Spiritual Communion. Available at: https://www.cbcew.org.uk/wp-content/uploads/sites/3/2020/04/spiritual-communion-230420.pdf

[25] Catholic Bishops’ Conference of England and Wales. Prayers during a time of ´flu and illness. Available at: https://www.cbcew.org.uk/wp-content/uploads/sites/3/2020/03/prayer-flu-viruses.pdf

[26] The Kairos Forum. Available at: http://www.kairosforum.org/

[27] Domestic Abuse Group of the Catholic Bishops’ Conference of England and Wales. Guidance on how Catholic parishes can support victims of domestic abuse during the COVID-19 pandemic. Available at: https://www.cbcew.org.uk/home/our-work/health-social-care/coronavirus-guidelines/domestic-abuse/

[28] Catholic Bishops’ Conference of England and Wales. Guidance for engaging in ministry to take the sick during the COVID-19 pandemic. Available at: https://www.cbcew.org.uk/home/our-work/health-social-care/coronavirus-guidelines/covid-19-and-the-ministry-to-the-sick-interim-guidance/

[29] Catholic Bishops’ Conference of England and Wales. Available at: https://www.cbcew.org.uk/home/our-work/health-social-care/coronavirus-guidelines/catholic-charities-and-covid-19/

[30] Professor Jim McManus, Director of Public Health for Hertfordshire and advisor to the Catholic Church in England and Wales on COVID-19, recorded a podcast of particular interest on this topic. Available at: https://www.cbcew.org.uk/home/our-work/health-social-care/coronavirus-guidelines/covid-19-and-cst/

[31] More information on the response of the Church of England to the COVID-19 crisis is available at: https://www.olir.it/focus/cristiana-cianitto-let-us-continue-to-pray-la-chiesa-dinghilterra-e-il-covid-19/

[32] More information available at: https://www.bbc.com/news/uk-wales-52299966