many cases impliedly, but not so in registered land. In most instances, lay holders are willing to donate them without payment to the diocese, on being asked to do so in a polite letter from the bishop. Advowsons have lower value to lay holders, since the ban on sale of livings is more easily enforced and few lay holders wish to exert a proxy influence over the morals of their neighbourhood, most of which would have from medieval times to the 19th century have been their tenants in the parish, nor in such a way for their younger children to be put forward for preferred selection as parish priests, which was in the era of tithes often a source of high real-terms pay. Lay advowsons have been left by successive wills or estate successions and so it is a sign of past wealth to hold many advowsons. Debrett's Peerage of 1995 shows John Hervey, 7th Marquess of Bristol (d. 1999), then aged 40, in a modern extreme example: he was "patron of thirty livings". Many advowsons rest with the Church Society on the Protestant wing of the church, and on the Anglo-Catholic wing by The Church Union and Oxford Movement. Donation to one of these can help to seek to see that style of worship remains constant over generations in a parish with slightly less regard to reforms in either direction introduced by the local bishops, though in all cases the ultimate decisions to appoint and promote rest with the bishops. This is tempered by the central policies of many faiths, but particularly churches, of subsidiarity (local differentiation) which is opposed to dogma from senior figures. In 2019, Teresa Sutton argued for three specific reforms in the Ecclesiastical Law Journal:"First, propose a sunset rule on individual private lay patronage providing that personal patronage may no longer be passed onto another individual. Second, develop a nominal figurehead ‘charity patron’ role without formal rights of presentation for educational or guild patrons that are willing to retain supportive links with a church. Finally, recognise value in the work of the patronage societies in reflecting churchmanship through provision for societies to assist parishes, but only where PCCs opt into continuing that arrangement at the point of vacancy."Anthony Jennings responded to Sutton's article describing her proposal to abolish private patronage as "drastic". In March 2021, the PCC of St Luke's, West Holloway announced it is