By degrees, also, the relations of colonial churches to the Archbishop of Canterbury have changed. Until 1855 no colonial bishop was consecrated outside the British Isles, the first instance being Bishop MacDougall of Labuan, consecrated in India under a commission from the Archbishop of Canterbury; and until 1874 it was held to be unlawful for a bishop to be consecrated in England without taking the suffragan's Oath of Due Obedience. This necessity was removed by the Colonial Clergy Act of 1874, which permits the Archbishop of Canterbury at his discretion to dispense with the oath.