The Gorham Judgment

There was a very interesting legal case in the middle of the nineteenth century which clarified the Anglican position. The Bishop of Exeter, Henry Philpotts, refused to institute George Gorham into a living in the diocese because he did not believe that regeneration invariably accompanied baptism. The dispute was so sharp that eventually it came before the Judicial Committee of the Privy Council. In 1850 Gorham won his case, and the position was stated by the Privy Council as follows:

That baptism is a sacrament generally necessary to salvation, but that the grace of regeneration does not so necessarily accompany the act of baptism that regeneration invariably takes place in baptism; that the grace may be granted before, in or after baptism; that baptism is an effectual sign of grace, by which God works invisibly within us, but only in such as worthily receive it—in them alone it has a wholesome effect; that in no case is regeneration unconditional.

It is an instrument … if you receive it aright. Baptism is not unimportant on the one hand, as if we could have done without this mark of the objectivity of the gospel. It is not unconditional, on the other, as if we could presume on its efficacy without making our proper response of repentance and faith.
‘All receive not the grace of God’, wrote Hooker, that most judicious of Anglican divines, ‘which receive the sacraments of his grace’.

Michael Green, Baptism: Its Purpose, Practice and Power, 39