Church Act 1869 did disestablish the Church of Ireland, since there was no express provision in that Act permitting its clergy to sit as MPs and MacManaway was still be subject to the strictures of the House of Commons (Clergy Disqualification) Act 1801, which debarred any person "ordained to the office of priest or deacon" from sitting or voting in the House of Commons. Modern scholars have questioned the rationale of this decision but, nonetheless, the House of Commons resolved on 19 October 1950 that MacManaway was disqualified from sitting. The House did, however, indemnify him (by the Reverend J. G. MacManaway's Indemnity Act 1951) from the £500-a-time fines that he had incurred for voting in parliamentary divisions while ineligible. MacManaway had voted on five occasions. MacManaway bitterly protested at what he perceived as an unjust anachronism bringing his career to an abrupt end, but did not contest the ensuing by-election, which was held for the Unionists by Thomas Teevan. His House of Commons career had lasted all of 238 days. Death Shortly after his leaving the Commons, MacManaway's wife died in January 1951. He resigned his seat at Stormont and died soon after, in November 1951, as the result of a fall. He was 53. Subsequent change in the law In the aftermath of the MacManaway case, in 1951 another Select committee examined the possibility of a change in the law. However, while acknowledging the anomalous and anachronistic nature of the ancient legislation, and taking soundings from various Christian denominations, the Committee recommended no specific change to the law. The law did not, however apply to churches such as the Presbyterian Church in Ireland and ministers such as Martin Smyth successfully served as MPs. There the matter lay for almost 50 years, until David Cairns was selected to fight the safe Labour seat of Greenock and Inverclyde. Cairns was a former Roman Catholic priest, and a re-run of the MacManaway imbroglio loomed. The Labour government introduced a bill removing almost all restrictions on clergy of whatever denomination from sitting in the House of Commons. The only exception would be Church of England bishops, because of their reserved status as members of the House of Lords. The bill came into law as the House of Commons (Removal of Clergy Disqualification) Act 2001 in time for David Cairns to take his seat in the Commons. Arms See also List of United