[Opinion] Decree suspending Fr. Samuel Adapore : A canon lawyer’s analysis

The decree is timely and is in the interest of the person concerned and of the particular Church. After taking a closer look at the decree, however, I have some observations to make.

In the paragraph explaining the reason for the suspension, the bishop writes that the suspension is due to “serious acts” on the part of Rev. Fr. Samuel Adapore, “including” his unilateral decision to take a leave of absence from the diocese and his abandonment of his pastoral ministry at St. Anthony of Padua Rectorate, Nkwantakese, without legitimate permission. The decree also states that he took all his personal belongings from the mission house without informing or consulting anyone.

Konongo-Mampong Diocese : Bishop suspends priest over unauthorised absence

The word “including” is significant. It appears to indicate that the acts mentioned in the decree may not constitute the whole picture. There may be other circumstances or acts known to the diocesan authorities that have not been made public.

From the way the decree is written, it seems to me that the priest’s departure was deliberate and prepared, rather than a sudden decision. Taking all his personal effects with him suggests that he intended to leave his place of assignment and did not simply leave temporarily.

This raises an important question: Was he running to something or someone, or was something or someone causing him to run? At this point, however, that remains speculation. We simply do not have enough information to know.

I would also imagine that some members of the presbyterium or other persons may have been aware of his intentions or may know something about his movements. This is possible, especially because moving all his personal belongings would ordinarily require some form of assistance. However, the decree itself does not establish that anyone in the presbyterium or elsewhere knew his plans or his present whereabouts.

It would therefore be inappropriate to present this as a fact. We cannot exclude the possibility that he moved his belongings with the assistance of others, sold some of them, or made other arrangements. At present, we simply do not know.

Another detail that I find significant is that there is no reference in the decree to the police or to any report concerning his safety. The decree does not indicate that the diocese is treating the matter as a reported disappearance or as a situation requiring immediate police intervention. However, the absence of such a reference does not allow us to conclude that the priest is safe or that the diocese has no concern for his welfare. It simply means that this aspect is not addressed in the decree.

What strikes me most is the final part of the decree. The bishop says that the priest has blocked access to him and that even his immediate family says they do not know his whereabouts. This suggests that the diocese is dealing with a situation whose full circumstances are not yet publicly known.

At the same time, it is important to remember that a public decree cannot be expected to contain the entire itinerary of all the events and pastoral interventions that preceded it. An administrative or penal decree has a specific juridical purpose. It is not necessarily a complete historical narrative of everything that happened between the priest, the bishop, the diocese and other persons before the decree was issued.

Therefore, the fact that certain warnings, conversations, attempts at reconciliation or pastoral interventions are not mentioned in the decree does not necessarily mean that they did not take place.

Instead, the decree principally establishes the canonical position of the diocese: the priest has left his assignment without permission, his whereabouts are unknown to the diocesan authorities, and the diocese is formally distancing itself from his actions and from any consequences that may follow from them.

The pastoral office and the obligation of residence

There is also a further canonical consideration concerning the nature of Fr. Samuel’s assignment.

Since Rev. Fr. Samuel exercised the obligations of a pastor, Canon 533 §1 is relevant to the question of his residence and absence from his pastoral assignment. The canon requires a parish priest to reside in the parish house, or near the parish church, and provides that an absence from the parish exceeding one month requires the permission of the diocesan bishop, while taking account of the exceptions provided by the law.

This means that the matter is not simply about where the priest chose to live. It concerns his canonical obligation to remain available for the pastoral office entrusted to him and to obtain legitimate permission when the law requires it.

His unilateral departure therefore raises not only a question concerning residence but also a possible abandonment of the pastoral responsibilities entrusted to him. Under Canon 519, the pastor is the proper shepherd of the parish entrusted to him, exercising the pastoral care of the community under the authority of the diocesan bishop. His responsibilities include teaching the faithful, sanctifying them through the ministry of the word and the sacraments, and governing the parish community. These responsibilities are further expressed in Canon 528 and related provisions of the Code.

Consequently, leaving the pastoral assignment without legitimate permission can have consequences beyond the mere fact of physical absence. It may constitute a failure to fulfil obligations attached to the pastoral office itself.

This, in my view, strengthens the canonical rationale behind the bishop’s concern. The issue is not simply that a priest travelled away from his place of residence. The more serious question is whether he unilaterally withdrew himself from an ecclesiastical office and from pastoral responsibilities that had been entrusted to him by legitimate authority.

Warnings and pastoral solutions before the decree

There is also an important canonical consideration here. Canon 1341 requires the competent authority to pursue the restoration of justice, the reform of the offender and the repair of scandal. For this purpose, the authority is to use pastoral means, fraternal correction, warning and other appropriate remedies when these are suitable. When the competent authority judges that such means have proved insufficient or cannot adequately restore justice, reform the offender and repair scandal, a judicial or administrative procedure for imposing or declaring a penalty is to be initiated.

Canon 1339 also provides for warnings and corrections in appropriate circumstances.

In light of these canonical provisions, I believe that, before this decree was made public, the competent authorities would ordinarily have already attempted appropriate warnings, corrections and pastoral solutions aimed at addressing and correcting the serious acts attributed to Fr. Samuel. The decree itself does not give us the details of those preceding steps, so I cannot say precisely what was done.

Nevertheless, I would presume that the competent authorities had first sought, as far as circumstances permitted, to correct the situation through the appropriate pastoral and canonical means before arriving at the present measure.

This presumption should not be understood as an assertion of facts that are not contained in the decree. Rather, it is an appreciation of the canonical framework within which ecclesiastical discipline should operate. The decree cannot contain the entire itinerary of the preceding events, and we should therefore be cautious about judging what happened before the decree simply from what the decree does or does not mention.

More specifically, if the suspension in this case is imposed as a censure, Canon 1347 §1 states that a censure cannot be imposed validly unless the offender has first been warned at least once to end the contumacy and has been given suitable time for repentance. Canon 1347 §2 further explains that contumacy is ended when the offender has genuinely repented and has made suitable reparation for the scandal and harm, or at least has seriously promised to do so.

This is important because suspension is not simply punishment for punishment’s sake. Canon 1311 §2 places the Church’s penal discipline within the wider purpose of restoring justice, reforming the offender and repairing scandal.

Suspension a divinis

There is another point concerning the terminology used in the decree that deserves attention.

The traditional expression suspension a divinis has historically been associated with a broad restriction upon a cleric’s exercise of sacred ministry. In the current canonical discipline, however, the juridical content of a suspension is determined by the applicable provisions of Canon 1333.

Suspension may prohibit some or all acts of the power of orders, the power of governance, or the exercise of rights and functions attached to an office.

Therefore, one should distinguish carefully between the traditional expression “suspension a divinis” and the precise juridical content of the particular decree.

If the practical effect of this particular decree is principally to prohibit Fr. Samuel from publicly celebrating the sacraments and exercising public liturgical or pastoral ministry, then “prohibition from the public exercise of ministry” may be a more precise description of what is actually being imposed, depending on the juridical nature and wording of the decree.

The Dicastery for the Doctrine of the Faith has itself addressed this terminology in its Vademecum, particularly in relation to precautionary measures. It notes that the older expression suspensio a divinis is sometimes used for a prohibition of ministry imposed as a precautionary measure, but recommends avoiding that terminology in such circumstances because, under the current law, suspension is a penalty. The more appropriate terminology for such a precautionary measure is, for example, “prohibition from the exercise of the ministry.”

This distinction is important. The DDF’s recommendation concerns precautionary, non-penal measures, and therefore should not automatically be applied to every decree that formally imposes the canonical penalty of suspension. If the bishop has actually imposed suspension as a canonical penalty, the terminology of suspension is juridically meaningful. The question is therefore not merely what expression appears in the title, but what the decree actually establishes in law.

The medicinal purpose of suspension

Consequently, if the suspension in this case is a censure, its ultimate purpose should be correction and restoration, not merely exclusion. A censure is medicinal by its very nature. The Church does not impose it simply to cast a person away, but to call the person back to the proper order of ecclesial life.

The possibility of lifting the censure is also provided for in Canon 1358 §1, which states that a censure is to be remitted when the offender has ended the contumacy according to Canon 1347 §2. Thus, genuine repentance, appropriate reparation and a sincere willingness to change are central to the eventual remission of the censure.

Therefore, I would be very careful not to conclude that we know what happened to Fr. Samuel. The decree leaves important questions unanswered. What we can say with reasonable confidence is that his departure appears deliberate, that the diocese considers his conduct serious, and that the expression “serious acts”, together with the word “including”, suggests that the public decree may not contain the entire story.

At the same time, we should give the diocesan authorities the benefit of the presumption that they have acted on information and circumstances that may not appropriately be included in a public decree. A decree is a juridical instrument, not a transcript of every conversation, warning, pastoral intervention, consultation, deliberation or event that preceded it.

For this reason, I do not think it would be prudent to rush to conclusions either about the priest’s motives or about the actions of the diocesan authorities. There is information that remains unavailable to the public, and prudence requires that we distinguish between what is established, what is reasonably inferred and what remains pure speculation.

The Church has the right and duty to protect ecclesial order, the faithful and the integrity of pastoral ministry. The diocesan bishop also has the responsibility to ensure that priests fulfil the obligations proper to their state and ministry. At the same time, the priest concerned remains a son of the Church, and canonical discipline should always leave room for repentance, reconciliation and restoration.

Canonical discipline must ultimately be understood within the Church’s supreme purpose: the restoration of justice, the reform of the offender, the repair of scandal and, above all, the salvation of souls. As Canon 1752 reminds us, “the salvation of souls, which must always be the supreme law in the Church,” is the final horizon within which all ecclesiastical law must be understood.

I believe this may only be the beginning of public knowledge of the situation. There are questions that remain unanswered, and perhaps, with time, the circumstances will become clearer.

For now, prudence, prayer and charity are required. I therefore wish to thank and pray for the diocesan bishop for the responsibility he carries in dealing with this difficult situation. The governance of a particular Church is not always an easy burden, especially when decisions must be made for the good of the faithful while also seeking the welfare and salvation of a brother priest. May the Lord grant the bishop wisdom, prudence, courage and charity in all the decisions he must take.

I also pray for Rev. Fr. Samuel Adapore. Whatever may have happened, and whatever circumstances may eventually become known, he remains a priest and a brother. May the Lord protect him wherever he is, enlighten his conscience, guide his steps and bring him to whatever truth, reconciliation and restoration the Lord desires for him.

May the will of the Lord be done.
Fr Joseph.
ochonogorjoseph@gmail.com