“ At common law all seats in a parish church are for the common use of all the parishioners, and every parishioner has a right to a seat without paying for it. The disposition of the seats is in the discretion of the churchwardens acting for the ordinary for the purpose of orderly arrangement (as to the exercise of this discretion see Reynolds v. Monckton, 1841, 2 M. & R. 384) , and this can be exercised in cases where all the seats are free (Asher v. Calcraft, 1887, 18 Q.B.D. 607) . The right to a seat does not belong to a non-parishioner. ”

“ The large pews with high enclosures, curtains, &c, known familiarly as “horse boxes,” and common in English parish churches during the 18th and early part of the 19th centuries, have nearly all been cleared away. The parish church of Whitby, in Yorkshire, is perhaps the best surviving example of an unaltered interior. ”