In 1857 it was decided, in "Regina v. Eton College", that the Crown could not claim the presentation to a living when it had appointed the former incumbent to a colonial bishopric, as it does in the case of an English bishopric. In 1861, after some protest from the crown lawyers, two missionary bishops were consecrated without letters patent for regions outside British territory: C. F. Mackenzie for the Zambezi region and J. C. Patteson for Melanesia, by the metropolitans of Cape Town and New Zealand respectively.