"Section 36 of the Offences Against the Persons Act 1861 makes it an offence to, amongst other things, use "threats or force, obstruct or prevent or endeavour to obstruct or prevent, any clergyman or other minister in or from celebrating divine service or otherwise officiating in any church, chapel, meeting house, or other place of divine worship". There is ample authority for the proposition that the phrase "divine worship" extends beyond the services conducted by the Church of England and, given the Segerdal test noted in para 55 in relation to the 1860 Act, it may probably be argued that the phrase extends to all theistic, including probably polytheistic, religions. However the phrase seems to exclude from the protection of the Act both non-theistic religions where there is no worship of the divine and also religions, such as the Religious Society of Friends, that do have divine worship but do not have persons who are, or who are analogous to, clergymen or ministers. The exclusion of non-theistic religions may be problematic following the implementation of the Human Rights Act 1998. Granting special protection to clergymen and ministers but not to those, such as people attending a Quaker meeting, who are engaged in ministering without being formally designated as ministers, may not be acceptable under the 1998 Act."