In the NSW Supreme Court decision of Anglican Development Fund Diocese of Bathurst v Palmer [2015] NSWSC 1856 (10 Dec 2015) (the Bathurst Diocese case), a single judge of the Court held that a large amount of money which had been lent to institutions in the Anglican Diocese of Bathurst, and guaranteed by a “Letter of Comfort” issued by the then Bishop of the Diocese, had to be repaid by the Bishop-in-Council, including if necessary by that body “promoting an ordinance to levy the necessary funds from the parishes”. The lengthy judgment contains a number of interesting comments on the legal personality of church entities and may have long-term implications for unincorporated, mainstream denominations and their contractual and tortious liability to meet orders for payment of damages. The paper discusses the decision and some of those implications.