The readings of Morrice and Snagg are evidence of a new kind of thinking about the common law's capacities. It was probably not just coincidence that both were produced by puritans of presbyterian leanings. From the perspective of such men, a constitutionalist approach was the most natural response to an anomaly: the fact that though Elizabeth in general deferred to the law, there was one sphere of national life – the church – in which she placed some emphasis on extra-legal power. By 1571, her spokesman Sir Nicholas Bacon felt able to tell parliament that ‘by religion we do not only know God aright but also how to obey the king or queen whom God shall assign to reign over us, and that not in temporal causes, but in spiritual or ecclesiastical, in which wholly her Majesty's power is absolute’.

As Bacon's audience must have realised, this somewhat shrill assertion was a piece of crown aggression, for there was every reason to believe that further reform of religion was parliament's responsibility. In its earliest formulations, Elizabeth's Supremacy was markedly less ‘personal’ than her father's. At the beginning of the reign, she cautiously placated both Protestant and Catholic opinion by dropping the title ‘Supreme Head’ in favour of the less offensive ‘Supreme Governor’, while her Injunctions put a moderate gloss upon the oath that recognised this status, describing it, in essence, as an acknowledgement of ‘sovereignty and rule over all manner of persons… so as no other foreign power shall or ought to have any superiority over them’.