

























RESIGNATION AS A JURIDIC ACT: THE 
QUESTION OF UNJUSTLY INFLICTED GRAVE 

FEAR IN CANON 188 CIC

THOMAS OYODE

Abstract
Every ofce holder in the Church has rights which are well 
protected by the Code of Canon Law. In protecting the right 
of a person, the Church also protects the common good of 
the Church by ensuring equity in ecclesiastical governance. 
This paper sought to analyse the validity of resignation as a 
juridical act vis-à-vis grave fear, highlighting a point that a 
juridical act is only valid when it is performed with freedom 
and consciousness. However, the deciency of the required 
freedom and consciousness is dependent on the degree to 
which grave fear is inicted. The paper, thus, argued that a 
resignation from ofce could result from grave fear but the 
fear must never be unjust if the resignation is to be valid. But 
how do we determine whether grave fear is just or unjust? 
With a delineation of two main modes of unjust fear, quoad 
substantiam and quoad modum, we undertook a study of 
Can. 188 CIC by which we note that a threat that inicts 
grave fear is just provided that it is inicted for the exercise 
of a right or an obligation; to attain a just end, the salvation 
of souls.

INTRODUCTION
Resignation from ecclesiastical ofce is, without doubt, a juridical 
act. The Church itself is a juridical entity and acts which are placed 
within it have juridical consequences. The recent Code of the Canon 
Law of the Latin Church presents the canonical doctrine of juridical 
acts in a manner that is quite systematic. It places it in Book I of the 



Code as a general norm for the entire Code so that it could be applied 
in understanding juridical conditions of persons in the Church, it 
could be applied in interpreting the validity of the sacraments when 
celebrated and, in our context, it could be applied to loss 
ofecclesiastical ofces. The focus of this paper is on resignation from 
ecclesiastical ofce. It seeks to analyse the validity of resignation as a 
juridical act vis-à-vis grave fear. In other words, if a person resigns an 
ofce as a result of grave fear, is there a way in which the resignation 
could be said to be invalid, given that juridical acts which are placed 
as a result of grave fear are generally conceived in law to be valid 
rescindable? The rights and obligations of the Christian faithful is at 
stake here and, faithful to ecclesiastical communion as proposed by 
the Second Vatican Council, the Code highlights them sufciently in 
Canons 208-231, bearing in mind the fundamental equality of 

1christifedeles  as seen in Canon 204. The paper attempted a concise 
analysis the concept of juridical act as found in Canon 124 indicating 
the element of grave fear as one of its defects. It, then, explored the 
canonical notion of resignation from ecclesiastical ofce 
highlighting its nature as a juridical act. The fundamental part of this 
paper is a canonical evaluation of how the element of grave fear can 
vitiateresignation from ofce. It argued that grave fear can be either 
just or unjust. It is just when it is aimed at the common good of the 
Church. Using Canon 1742 § 1 as an example, it concluded by 
holding that grave fear does not vitiate resignation from ofce when it 
is justly inicted.

JURIDICAL ACTS AND THE DEFECT OF GRAVE FEAR
Omnes de nitiones periculo sussunt, says the Latin maxim. Precisely 
for this the Code does not dene juridical acts. According to 
Thierault, it is difcult to dene juridical acts in Canon Law but it is 

2 3
not impossible.  Thus some authors only provide descriptions  while 

4others attempt a denition.

Juridical Act and Juridical Facts: A Distinction
Juridical acts are different from other acts. Juridical acts are 
commonly distinguished from juridical facts as both could be easily 
misconstrued. A juridical fact is that which has a juridical 

62 Ekpoma Review, Volume 9, 2022



consequence; the law ascribes juridical effects to it such that 
questions of right and obligation may arise ad normam legis.  
However, juridical facts only serve as sources of rights and 
obligations they are not rights and obligations in themselves neither 

5do they serve as an exercise of rights and obligations.  On the other 
hand, there are certain facts that are not beyond the will and choice of 

6the subject or person.  These are made voluntarily according to the 
norms of the law. They are called juridical acts. Juridical acts are 
those acts that are performed with personal freedom and with a free 
intention to produce a juridical effect. In this sense, while the law 
itself is the source of juridical facts, the source of juridical acts is the 
human will; take away the human will and its acts lack juridical 
effects, it lacks validity as a human act. Thierault puts it clearly: 
“actus humanus socialis legitime positus et declaratus, cui a legeideo 
et eatenus effectusiuridicusdeterminatusagnoscitur, quia et quatenus 

7
effectu silleabagenteintenditur”.
 Thus, a juridical act is an act of will externally manifested 
with certain juridical effect in view. The human person is central here 
as a subject of rights and obligations. The effects of such a freely 
placed act are recognized by the law because the law also recognizes 

8the private autonomy of the human person.  For this same reason, a 
juridical act must be a human act as different from an act of man. An 
act of man does spring from the will of the person; it is mechanical, 
involuntary and reexive. Some of these reexive acts can be 

9
conscious but they transcend the control of man's will . On the other 
hand, a human act is an act of man placed consciously and 

10
voluntarily , per rationemetvoluntatem. It is a deliberate and 
responsible act. If there is an absence of sufcient knowledge/ 
consciousness and a determined will an act cannot be said to be a 
human act. 
 Juridical act is also relational; it is social. It must relate with 
an external element. Thus a mere desire is not enough to place an act. 
A good example is marriage; it is not enough to desire to marry a 
person it must be freely expressed in a matrimonial consent by a 
person who is capable by law. It must also be legitimate, 

11positusadnormamiuris, following the stipulations of law.

63Resignation As a Juridic Act



Validity of a Juridical Act in Canon 124 § 1
Having described what a juridical act is, let us now take a look at the 
elements that make it valid. As noted above, Canon 124 § 1 only 
d e s c r i b e s  a  j u r i d i c a l  a c t  a n d  i t s  v a l i d i t y :  A d 
validitatemactusiuridicirequiriturut a persona habili sit positus, 
atque in eodemadsint quae actumipsumessentialiterconstituunt, 

12necnonsollenmiaet requisite iureadvaliditatemactusimposita.  The 
law thus proposes certain elements for a valid juridical act giving rise 
to an important distinction between a valid act, an invalid act and a 
non-existent act.
 A juridical act is said to be valid when it is efcacious; that is, 
it produces a juridical effect when it is placed by a legally qualied 
person with a capacity to act. The law says that only a validly 
ordained priest (male) can validly celebrate the Mass. If a female 
Religious celebrates the Mass she is not qualied (un-ordained) and 
so lacks the capacity to act. Such Mass is invalid and non-existent 
because it lacks the essential and constitutive element of a valid 

13
priestly ordination reserved only for viretbaptisatus (cf. Can. 1024) . 
A juridical act is said to be null when the constitutive element is there 
but the procedures and formalities requested by law are absent. 

RESIGNATION FROM ECCLESIASTICAL OFFICE: A 
CONSIDERATION OF CANON 188 CIC
Notion of Resignation from Ecclesiastical Ofce
Chiappetta describes resignation from ofce as the cessation of ofce 

14in a voluntary and free way  except when it is recommended by the 
15

law.  Here, also, the Code does not dene resignation. For Garcia 
Martin, resignation is the free cessation or legitimate removal from 
an ecclesiastical ofce made by a competent authority and accepted 

16by the same . His presentation of resignation is very interesting to us 
here because, as we shall see later, resignation from ofce can also be 
done by legitimate removal.  However, the decretalist Godefridus (de 
Tr a n o )  g i v e s  a  f a m o u s  d e s c r i p t i o n  o f  r e s i g n a t i o n : 
renunciatioestpropriaereiveliurisspontaneareutatio. 
 According to Wiecek, this denition offers us two elements of 

17resignation from ecclesiastical ofce; the object and the will.  The 
object of resignation is connected to the ecclesiastical ofce 

64 Ekpoma Review, Volume 9, 2022



adnormamcan. 145 § 1 CIC understood as “any post which by divine 
or ecclesiastical disposition is established in a stable manner to 
further a spiritual purpose.” For example, the ofce of a parish priest 

18is created ipso iure when a parish is created.  The object of the ofce 
is the parish while the subject of the ofce is the incumbent parish 
priest. In other words, the object of resignation is every ofce stably 
constituted for the spiritual good of the faithful while the subject is 
the holder of the ofce who resigns. 
 Let us now attempt an exegesis of Canon 188 CIC on 
resignation from ecclesiastical ofce bearing in mind that the Code 
recognizes the right of every ofce holder to freely, voluntarily and 
consciously resign from their ofce for a just cause ex can. 187 CIC. 
The wordings of Canon 188 CIC are highlighted below.

Canon 188 CIC (Latin)  Canon 188 CIC (English)  
Renuntiatio ex metu gravi, 

iniuste incusso, dolo vel errore 

substantiali aut simoniace facta, 

ipso iure irrita est.  

A resignation which is made as 

a result of grave fear unjustly 

inicted, or of deceit, or of 

substantial error, or of simony, 

is invalid by virtue of the law 

itself.
 

We have already said that resignation is a juridical act. This implies 
that it is regulated by the general norms on juridical act found in 
Canons 124-128 CIC. Having said that, it is important to bear in mind 
that Can. 125 § 2 CIC says that a juridical act placed out of grave fear 
is not invalid but Canon 188 says that a resignation that is a result of 
grave fear is invalid by virtue of the law itself. How can this 
divergence be explained canonically? 

19
 The eminent canonist, Chiappetta explains that the will  of 
the ofce holder is very important; he must be free and responsible for 

20
his act of resignation with a capacity to will . Grave fear affects the 
will of the person and inhibits his ability to freely and deliberately 
place an act as serious as resignation from ofce. 
 Also, based on Canon 125 § 2 CIC, an act of resignation 
would be valid but become rescindable; that is it can be challenged. 

65Resignation As a Juridic Act



Canon 188 CIC does not speak of force inicted externally because 
such act would be absolutely null, in existent. It rather speaks of 
moral force which acts within the person; it touches on the person's 
state of mind in the form of psychological pressure or grave threat 
which results in apprehension thereby pushing the person to do 
something they would ordinarily not do, as the only available means 

21to free themselves from the threat.  Ancient Roman law denes this 
kind of fear, metus as trepidation of the mind caused by instant or 

22future danger.  Placed side-by-side, therefore, it can be seen that Can. 
188 CIC makes exception to Can. 125 § 2 CIC. It is, however, an 
exception which is in conformity with the ipsissimaverba of Can. 125 
§ 2 CIC: “unless the law itself provides otherwise.” Thus Can. 188 
CICis a fantastic example of a case where the law provides 

23
otherwise.  
 Furthermore, the will or voluntariness must be manifested 
and remain in existence at the moment of the act of resignation. So if a 
gun is put to his head, coercing him to resign his ofce as Parish 
priest, if he writes the letter and signs it while the gun is still placed to 
his head, his resignation is invalid.
 Thus, based on Can. 124 § 1 CIC and Canons 187 CIC and 
188 CIC as analysed above, we can say that the requisite elements for 
a valid resignation include:

1. It must be according to the norm of law, ad normamiuris. For 
example where the law says the resignation must be accepted by 

24
the competent authority

2. It must be based on a deliberate will on the part of the subject 
who resigns, he/she must be responsible for the act

3. The will to resign must be freely manifested
4. It must be for a just cause. The crux of this paper is a canonical 

evaluation of the concept of just cause in relation to resignation 
from ofce.

JUST CAUSE AND VALIDITY OF RESIGNATION
At this point, it is imperative to note that Canon 188 CIC falls within 
the scope of loss of ecclesiastical ofces. It would be noted also that 
resignation can also come about through legitimate removal as found 
in Can. 1742 § 1 CIC for example. It sufces to add that removal from 

66 Ekpoma Review, Volume 9, 2022



ecclesiastical ofce (cf. Can. 192) is not a penal act as in deprivation 
of ofce (cf. Can. 196); it is never for punishment. It is a pastoral and 
disciplinary act of a competent authority, aimed at the salvation of 
souls. It is different from transfer (Cf. Can.190). Canons 192-195 CIC 
and Canon 1740 CIC provide for canonical procedures for removal 

25
from ecclesiastical ofce.  
 Our focus is on just cause. In what way can it be said that the 
cause or reason for resignation is just? If Canon 188 CIC says that the 
grave fear which leads a person to resign must be justly inicted for 
the resignation to be valid, how does one measure or determine a 
justly inicted grave fear? In fact, the process of removal of a parish 
priest by resignation, stipulated by Canon 1742 § 1 CIC, states that 
the bishop must “persuade him in a fatherly manner to resign his 
parish within fteen days.” This paternal persuasion is required ad 

26validitatem . Should this persuasion include some modes perceived 
by the parish priest to be threats or unjustly inicted grave fear, would 
we say the resignation is invalid, if the parish priest resigns? What if 
the persuasion includes some threat, can there be a form of just threat 
that does not diminish the sufciency of personal freedom?
 We say that a cause is just when the act is voluntary and is 
based on a specic and known cause or ratio and it is determined by 

27
the competent authority according to canonical norms . A just cause 
could be those subjective elements such as the necessity and 

28
exigencies of the ofce holder and his peculiar subjective conditions  
like sickness or ineptitude. It could also be objective such as those 
elements that concern the ofce itself, the needs of the Church, the 
salvation of souls or other external elements which do not depend on 

29the ofce holder . In addition, a just cause can also be the right to 
defend oneself, which has been well defended by Rotal 

30jurisprudence,  and to protect one's good fame (cf. Cann. 220; 1745, 
n. 1). We also see just cause in the law giving the ofce holder time to 

31decide  such that the resignation remains the free choice of the ofce 
holder.
 There are two ways of assessing an  unjust cause. The rst is 
quoadsubstantiam. That is the threatened evil touches on the right of 
the person, the passive subject in an unjust way. The second is 
quoadmodum which is a type of unjust cause that takes place when 

67Resignation As a Juridic Act



the threatened evil touches on the concrete circumstances in which 
the threat is made. Using these modes to determine a just and unjust 
cause, we may then re-evaluate the resignation process with Can. 
 1742 § 1 CIC as an example. A bishop, having followed the 
canonical process stipulated by the Code, can tell a parish priest to 
write a letter of resignation from ofce within fteen days or face 
being removed. If the diocesan bishop accompanies this with a threat 
that violates the rights of the parish priest, the threatened fear is just 
all the same because it is just substantially related to the ofce which 
needs to be vacated and because it is within norms of the law ex Can. 
1742 § 1 but the manner (mode) of ensuring the resignation or placing 
the threat could be unjust. 
 Thus the canonical doctrine in Can. 188 CIC is that for a 
resignation to be free, valid and just, it must not be the result of an 
unjustly inicted grave fear except such grave fear can be justied by 
the fact that the threatened evil is for a good cause. This view is well 

32supported by a number of eminent canonists.  It can be seen, 
therefore, that resignation as a result of grave fear could be just if the 
threat is carried out in the exercise of right and obligation. The bishop 
who asks a parish priest to resign or be removed ex Can. 1742 § 1 is 
exercising his right and duty as bishop of the diocese who exercises a 
power of jurisdiction and governance. The threat is also just because 
the removal is aimed at a just end which is the good of the faithful, 
salus animarum. 

CONCLUSION
We have, so far, analyzed the canonical concept of resignation 
keeping in mind that every ecclesiastical ofce has a spiritual nality. 
Our analysis of Canon 188 CIC was embarked upon with a 
justication of the fact that resignation is a juridical act; it is a human 
act that must be deliberately and freely placed for it to be valid. A 
further credence is the grounds that the norms which regulate 
cessation or loss of ecclesiastical ofces are meant to protect the right 
of the ofce holder and to preserve the dignity of the ofce itself. 
Hinged on this, we hold that a resignation from ofce could result 
from grave fear but the fear must never be unjust if the resignation is 
to be valid. The fundamental question was then raised: when is grave 

68 Ekpoma Review, Volume 9, 2022



fear unjust? Our undertaking of the study of Can. 188 CIC, in relation 
to Can. 1742 § 1 CIC, revealed that a threat that inicts grave fear is 
just provided that it is inicted for the exercise of a right or an 
obligation: to attain a just end, the good of the Church and the 
salvation of souls.

1 Cf. Christus Dominus on the pastoral ofce of bishops; 
SacrosanctumConciliumon the Sacred Liturgy: A. Flannery (ed.), 
Vatican II: Conciliar and Post-Conciliar Documents (New York: 
Costello Publication Co., 1992).

2 M. Thierault, “Juridical Acts”, Exegetical Commentary on the Code of 
Canon Law prepared under the responsibility of the Martin de 
Azpilicueta Institute(Pamplona: Faculty of Canon Law, University of 
Navarra), p. 797.

3 V. De Paolis, “L'atto giuridico”, Atto giuridico nel diritto canonico: 
Studi Giuridici LIX,(Vatican City: Libreria Editrice Vaticana, 2002), 
pp. 23-42.

4 P.J. Pinto, Commento al Codice di Diritto Canonico, (Rome: Urbaniana 
University Press, 1985), p. 74; M. Hughes, “A New Title in the Code: 
On Juridical Acts”, Studia Canonica 14 (1980), pp. 396-397.

5 For instance, age is a juridical fact. By it a person can claim access to 
certain rights such as marriage (14/16 years) or priestly ordination (25 
years). But it does not depend on the will of the person, the subject. You 
do not choose when and where to be born and your being born in a 
certain place and at a given time has inevitable juridical effects 
independent of your choice and whim.

6 Canon Law also attempts a response to the philosophical question, what 
is man? Who is a human being? who is a person in law? See J.T. 
McHugh, “What is the Difference between a “Person” and a “Human 
Being” within the Law”, The Review of Politics 54 (1992) 3, pp. 445-
461; C. Paternak, What makes us Human (England: Oxford, 2007). See 
also Canon 96 CIC.

7 M. Thierault, “Juridical Acts”, Exegetical Commentary on the Code of 
Canon Law, p. 797: “a social human act placed and declared in a 
legitimate manner and of which a determined juridical effect is 
recognised by the law in as much as the effect is intended by the agent”.

8 V. De Paolis & A. D'Auria, Le Norme Generali. Commento al Codice di 
Diritto Canonico, 2nd Edition(Vatican City: Urbaniana University 
Press, 2014), p. 358.

9 For example, one may be aware of one's palpitations or heartbeat but 

ENDNOTES

69Resignation As a Juridic Act



one may not be able to prevent the heart from beating. It is the same 
thing with sneezing; a person may be conscious that they want to sneeze 
but they are unable to prevent it.

10 J. Osterle, “Human Acts”, New Encyclopedia, Vol. 7 (New York: 
McGraw-Hill Book Co., 1967), p. 208.

11 E. Roelker, Invalidating Laws (Patterson: St. Anthony Guild Press, 
1955), p. 160.

12 Can. 124 § 1 CIC: For the validity of a juridical act, it is required that it 
be performed by a person who is legally capable, and it must contain 
those elements which constitute the essence of the act, as well as the 
formalities and requirements which the law prescribes for the validity 
of the act.

13  The same applies to a Mass celebrated by a deacon. It is non-existent. 
There was no Mass atall, it lacks juridical effect because he lacks the 
capacity which can only be obtained by a valid priestly ordination.

14 L. Chiappetta, Il Codice di Diritto Canonico, Commento Giuridico-
Pastorale, Vol. I (Bologna: EdizioneDehoniane, 2011), n. 1219.

15 Francis, Apostolic Letter, Imparare a Congendarsi, Governing 
Resignation, for Reasons of Age, of Holders of Certain Ofces Subject 
to Papal Appointment, 12/02/2018 (Rome: LibreriaEditriceVaticana, 
2018).https://www.vatican.va/content/francesco/en/motu_proprio/do
cuments/papa-francesco-motu-proprio-20180212_imparare-a-
congedarsi.html; See also Canon 186, for example, which talks about 
automatic loss of ofce conferred for a determined time when the time 
stipulated has elapsed.

16  G.J. Garcia Martin, Le Norme Generali del Codex Iuris 
Canonici(Rome: Editiones Institutum Iuridicum Claretianum, 2002), 
p. 663.

17 J. Wiecek, La Natura della Rinuncia all'Ufcio Ecclesiastico nella 
Normativa Canonica Vigente (Rome: Ponticia Studiorum Universitas 
S. Thoma AQ in Urbe, 2011), pp. 89-90.

18 J.H. Provost, “Ecclesiastical Ofces (cc. 145-196)”, in J.P. Beal et al 
(eds.)  New Commentary on the Code of Canon Law, (Bangalore: 
Theological Publications in India, 2010), p.197.

19 In our analysis of Godefredus we cited two key elements of resignation 
from ofce; the object of resignation and the will of the subject who 
resigns.

20 L. Chiappetta, Il Codice di Diritto Canonico, Commento Giuridico-
Pastorale, Vol. I (Bologna: Edizione Dehoniane, 2011), n. 1222.

21 V. De Paolis & A. D'Auria, Le Norme Generali. Commento al Codice di 
Diritto Canonico, 2nd Edition(Vatican City: Urbaniana University 
Press, 2014), p. 377. A Rotal jurisprudence on marriage nullity 

70 Ekpoma Review, Volume 9, 2022



says,“…nam ratio nullitatisconiugiiobmetumgraveminitireponendaest 
n o n  t a m  i n  r e p a r a t i o n e  g r a v i s  i n i u r i a e ,  q u a m  i n 
defectusufcientislibertatiselectionis.” It then cites Thomas Aquinas: 
“Quare quod ex metuagiturest  ' s implici tervoluntarium' 
quamvissecundum quid involuntarium (S. Thomas, Suppl. q. XLVII, 
art. 1).” This reiterates the fact that fear itself does not invalidate a 
juridical act like matrimonial consent or resignation because it does not 
take away free will, it does not remove the person's capacity to decide 
but it is involuntary because whatever the person decides to do, though 
accidental, they do because they are constrained to do so. Grave fear 
restricts the will; it renders personal freedom insufcient to place an act. 
See Coram Boccafola (21/01/1991) RRJan.,as cited in V. Vondenberger 
(ed.), Rotal Jurisprudence. Selected Translations (Washington DC: 
Canon Law Society of America, 2011), p. 23.    

22 See Ulpian, L. 1, D., IV, 2.
23 Another good example in the Code where the law provides otherwise is 

Canon 172 § 1, n. 1 on the invalidity of a vote cast through grave fear. If 
a person is forced to vote against his choice, their vote is invalid and 
would not count.

24  Resignation of a parish priest lawfully placed and freely manifested, for 
example, must be accepted by the bishop. If not accepted, the 
resignation is invalid (cf. can. 189 § 3). See also can. 332 § 2 which 
gives exception to can.189 § 3 in the case of the resignation of the 
Roman Pontiff.

25 See Francis, Apostolic letter Come una madre amorevole (4/6/2016), in 
AAS 108 (2016), pp. 715-717.

26 An ofce created ad beneplacitum, like the ofce of the Bishop's 
Chancellor or of the Notary of the Curia does not require this procedure 
before the ofce holder is removed (cf. can. 485). The ofce of a parish 
priest, however is stably constituted and must follow this procedure (cf. 
cann. 522; 193 §§ 1-3.

27 Can. 1740 outlines fundamental reasons/causes (harmful or ineffective) 
for removal of a parish priest. The specic reasons/causes listed in can. 
1741 are not exhaustive, they only serve to amplify can. 1740. In fact 
they are meant to be read in unity. See F. Coccopalmerio, “De 
CausisadAmotionemParochorumRequisitis”, Periodica75 (1986), p. 
275; G.P. Montini, “La rimozione del parrocotralegislazione, prassi e 
giurisprudenza”, Quaderni di DirittoEcclesiale 24 (2011) p. 113; T.J. 
Paprocki, “Method of Proceeding in Administrative Recourse and in the 
Removal or Transfer of Pastors (cc. 1732-1752)”, J.P. Beal et al (eds.), 
New Commentary on the Code of Canon Law, p. 1838. 

28 L. Chiappetta, Il Codice di Diritto Canonico, Commento Giuridico-

71Resignation As a Juridic Act



Pastorale, Vol. I (Bologna: Edizione Dehoniane, 2011), n. 1220.
29  Ibid.
30 See Coram Burke, “Jurisprudence: Apostolic Tribunal of the Roman 

Rota, November 15, 1990 – Incidental Question: Nullity of a 
Sentence”,  in Studia Canonica 25 (1991), p. 511; M. del Pozzo, 
“Rilievi costituzionalistici a proposito della nuova disciplina per la 
rimozione del Vescovo”, in Ius Misionale 11 (2017), p. 262.

31 For example fteen days as in can. 1742 § 1.
32 R. A. Hill, “Commentary on Canon 188”, J. A. Corridenet al (eds), The 

Code of Canon Law: A Text and Commentary (New York: Paulist Press, 
1985), p. 109: “in order that a resignation be truly free it cannot be the 
result of unjustly inicted grave fear…Grave fear is caused by the 
threat of a serious evil, the threat being made to bring about the 
resignation. The grave fear, however, could also be caused by a justied 
threat of a serious evil, as in the case of threatening removal from ofce 
for a justifying cause if the person does not resign”. See alsoA. D'Auria, 

ndIltimore grave nell'attualelegislationecanonica, 2  Edition (Vatican 
City: Urbaniana University Press, 2003), p. 103-104; P. Bealet al (eds.), 
New Commentary on the Code of Canon Law, p. 222.

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