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Hardly had the Acts of Royal Supremacy and Uniformity been passed when a commission was addressed to a number of judges and officials to administer the oath of supremacy. Of the bishops within the sphere of English jurisdiction at this period Curwen had already given his adhesion to these measures, William Walsh of Meath promptly refused, as did also Thomas Leverous of Kildare (Feb. 1560).[33] Later on, when the Lord Deputy returned from London, another attempt was made to induce these bishops to change their minds, but without success. In reply to the Deputy the Bishop of Kildare declared that all jurisdiction was derived from Christ, "and since Christ did not deem it right to confer spiritual authority on women, not even on His own Blessed Mother, how, he asked, could it be believed that the Queen of England was the supreme governor of the Church?" Thereupon the Deputy threatened him with deprivation and the consequent loss of his revenues unless he made his submission, but the bishop reminded him of the words of Sacred Scripture, "What shall it profit a man to gain the whole world if he suffer the loss of his own soul?"[34] He was driven from the See, and for a time taught a private school in the County Limerick, but he returned to his diocese, where he died near Nass (1577).[35] The Bishop of Meath continued to oppose the religious policy of the government. In 1565 he was summoned once more by the commissioners, but "he openly protested before all the people the same day that he would never communicate or be present where the service should be ministered, for it was against his conscience and against God's word." As he was a man "of great credit among his countrymen, upon whom in causes of religion they wholly depend," he was thrown into prison,[36] where he languished in great suffering till 1572, when he contrived to make his escape to France. Later on funds were supplied by the Holy See to enable him to continue his journey to Spain. He died amongst his brethren, the Cistercians, at Alcalá in 1577. John O'Tonory, too, who had been appointed to Ossory after the precipitate flight of Bale, seems to have given offence to the government. Though the latter preferred to devote himself to historical studies after the accession of Elizabeth rather than to entrust himself to the tender mercies of the people of Kilkenny, his rival does not seem to have been regarded by the government as the lawful Bishop of Ossory. His name does appear on a list of ecclesiastical commissioners appointed in 1564,[37] but this seems to have been a mistake on the part of the officials or possibly a bait thrown out to induce O'Tonory to make his submission. At any rate it is certain that in 1561 the Bishopric of Ossory was returned as vacant, and it was suggested that the appointment should be conferred on the Dean of Kilkenny,[38] and in July 1565, before the death of O'Tonory, in the instructions drawn up for Sir Henry Sidney and corrected by Cecil, her Majesty is made to say that the "Bishopric of Ossory has been long vacant."[39] As this can refer only to the death of Bale, who died in 1563, it is clear that O'Tonory was bracketed with Walsh and Leverous as far as Elizabeth's ministers were concerned. Had it been possible for the government to do so, similar measures would have been taken against the bishops in the other parts of Ireland, but, faced as it was with Shane O'Neill in the North and a threatened confederation of the whole Geraldine forces in the South, it was deemed prudent not to precipitate a crisis by a violent anti-Catholic propaganda in those parts of the country not yet subject to English influence.[40]

Commissioners were appointed to administer the oath of supremacy to the bishops, the judges, and higher officials, to the justices of the peace, etc., in Kildare (1560), and to the officials in Westmeath.[41]

But unless bishops could be found willing to take the place of those who refused to accept the new laws, no progress could be made. Curwen of Dublin, following his old rule of accepting the sovereign's religion as the true one, submitted to the Act of Supremacy and the Act of Uniformity. In accordance with the queen's instructions he removed the pictures and statues from Christ's Church and St.

Patrick's, blotted out the paintings and frescos on the walls, so as to cover up all signs of "idolatry" and to prepare a back-ground for carefully assorted Scriptural texts. He was not, however, happy in his new position. He petitioned to be transferred from Dublin to Hereford, basing his claim on the fact that "he was the man that of his coat hath surlyest stood to the crown either in England or Ireland."[42]

But his petition was not granted. Two years later Adam Loftus, who though nominally Archbishop of Armagh feared to visit his diocese, charged Curwen with serious crimes which he was ashamed to particularise, and probably as a result of this the queen instructed her Deputy to induce him to resign on the promise of an annual pension of ā200 (1563).[43] But Curwen, fearing that "the leaving of the archbishopric and not receiving another" might lead people to believe that he was deprived, stood out boldly for better terms. Hugh Brady, the queen's Bishop of Meath, then proceeded to attack him. According to him everybody in Dublin from the archbishop to the petty canons were "dumb dogs," "living enemies to the truth," "neither teaching nor feeding any save themselves," and "disguised dissemblers."[44] As this did not produce any effect, he wrote once more, demanding that the authorities should "call home the old unprofitable workman," a petition in which he was supported by Adam Loftus.[45] Their prayers were heard at last, and Curwen was translated to Oxford. When the news of his recall was announced to him he merely expressed the wish that he could get "the last half-year's rent of the Bishopric of Oxford,"and that he should be allowed to change quickly so that "he might provide fire for the winter and hay for his horses."[46]