UK High Court Rules Exeter Breakaway Congregation Does Not Control FCE Properties

The High Court of Justice in London has ruled that the Free Church of England Central Trust, not the trustees of a breakaway congregation, holds the charity trusteeship of Christ Church Exeter’s principal properties. The decision, handed down on 8 September 2026, centers on the legal interpretation of “in union with” the Free Church of England, a phrase central to the dispute over property ownership and administration.

The case, titled *The Free Church of England Central Trust v Revd Steven Hanna & Ors [2026] EWHC 2260 (Ch)*, concerns the Grosvenor Place church, adjacent land, and former schoolrooms used by the Exeter congregation. Christ Church Exeter, one of the Free Church of England’s oldest surviving congregations, voted to leave the denomination in 2023. It was among several congregations that departed around that time, though the other churches were not involved in the proceedings.

Revd Steven Hanna, along with his wife Rachel Hanna and Lazlo and Ludivinia Flores, were the trustees of the registered charity Christ Church Exeter, charity number 1138246. Mr. Hanna was appointed as minister in March 2020, but his permission to officiate within the FCE was revoked in June 2022. He continues to lead a congregation at the Grosvenor Place church, with more than 30 regular worshippers, according to the evidence presented.

The breakaway congregation claimed it left the Free Church of England because the denomination had “no longer remain[ed] faithful to its founding principles.” The defendants, however, argued that the congregation, along with other former FCE churches, represented “the authentic voice of the FCE,” and that the central denomination had become friendly to Anglo-Catholicism—precisely the tendency from which the nineteenth-century founders of the FCE had separated.

The Central Trust, represented by Freeths LLP, initiated the claim to determine the trusts governing the buildings and the construction of the local charity’s 2010 constitution. The Attorney General was joined as required in charity proceedings but did not actively participate.

Master Brightwell noted that the issues behind the division were “redolent of the ecclesiastical disputes of the nineteenth century” rather than those typically associated with contemporary Protestant church conflicts. The ruling leaves the underlying accusation that the FCE has departed from its Protestant founding principles unresolved.

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