Shall Women Cover Their Heads In Worship?
Head Coverings & The Westminster Standards
Introduction
The practice of women wearing cloth head coverings in worship may not be the most pressing theological issue for most. The topic is only broached once in Scripture (1 Cor. 11:2–16), and it is generally not a ubiquitous practice in our churches today. But the practice does have deep roots in history. Although it is more commonly practiced in some of our sister denominations, it has also more recently carved out a corner in some of our churches. Therefore, with the practice on the rise (anecdotally), together with 1 Cor. 11:2–16 itself, it merits the question, where does the practice of cloth head coverings fit in our theology of worship?
Categories of Worship
The regulative principle of worship, which, in summary, states that we do nothing in worship unless God prescribes it (WCF 21.1; BCO 47–6), categorizes our worship practices into elements and circumstances. (1) The elements of worship are the indispensable and prescribed parts, which include prayer, the reading of scripture, preaching, singing, and the proper administration of the sacraments (WCF 21.3–6). In agreement with WCF 21, the BCO observes that “The Bible teaches that the following are proper elements of worship service: reading of Holy Scripture, singing of psalms and hymns, the offering of prayer, the preaching of the Word, the presentation of offerings, confessing the faith and observing the Sacraments; and on special occasions taking oaths” (BCO 47–9).
Our standards also refer to the Lord’s prayer as a “form” (WLC 186), and the PCA’s BCO also mentions the category of “form”, noting that “The Lord Jesus Christ has prescribed no fixed forms for public worship” (BCO 47–6). A “form” refers to how the elements of worship are shaped in the worship service. For example, in the appendices to the PCA’s Directory of Public Worship, there are several optional “forms” one can utilize to shape a marriage service, a funeral service, or a service for the dedication of a church building. These “forms” do not introduce new elements; they simply suggest certain prayers to pray, Scriptures to read, and a general structure for the execution of those elements in a given service. Thus, the category of “form” does not subvert the general bifurcation of elements and circumstances; forms simply develop the elements further.
Circumstances are those items “concerning the worship of God, and government of the church, common to human actions and societies, which are to be ordered by the light of nature, and Christian prudence, according to the general rules of the Word, which are always to be observed” (WCF 1.6). Circumstances are not parts of worship (“matters that are necessary and proper in worship”); they only concern the worship of God (“matters that may be necessary or proper about Church worship”). (2) George Gillespie—who along with Samuel Rutherford, was a non-voting, though influential Scottish commissioner to the Westminster assembly—identifies three distinguishing marks of a circumstance of worship: (3) (1) circumstances have no sacred significance, and they are regulated by the church in the same way that any other society may regulate such matters. (2) Circumstances must not be determinable by Scripture. (3) Circumstances must be accompanied by good reason and warrant. (4)
To Which Category Do Head Coverings Belong?
Where does a cloth head covering fit among the categories above? It cannot be an element. That is precluded by WCF 21.3–6, where each Biblically prescribed element is listed (see also BCO 47–9). Moreover, the elements of worship are common throughout the covenant of grace (though, of course, their forms may change since the Old Testament sacraments reach their eschatological fulfillment in the New Testament; WCF 7.5–6). As far as I can tell, cloth head coverings are never associated with women in worship in the Old Testament, (5) an observation that leads at least one proponent of perpetual coverings to place the practice exclusively in the New Testament. (6)
The only way in which a head covering could, theoretically, be an element of worship would be if it were a third sacrament, which would clearly run afoul of our confessional standards (WCF 27.4; WLC 35, 164). Though one advocate of perpetual head coverings avoids labeling a head covering a sacrament, he does set head coverings alongside sacraments and a creation ordinance (marriage): “In the New Testament, water, bread and wine, and marriage act as visual pictures of spiritual truths…The doctrine of headcoverings falls squarely into this category.” (7) A head covering, however, is neither a sacrament nor a creation ordinance.
If a head covering is not an element, it cannot be a form. It was noted above that “forms” of worship are connected directly to the elements of worship. If it was a form, to which element of worship would it be directly connected? The Psalms and hymns are forms of song, and the Lord’s prayer is a form of prayer. A head covering simply does not fit the definition of a form. Moreover, the PCA’s BCO notes that “The Lord Jesus Christ has prescribed no fixed forms for public worship but, in the interest of life and power in worship, has given His Church a large measure of liberty in this matter” (BCO 47–6). Thus, if a proponent of perpetual head coverings were to label the practice a “form” of worship, it appears that this would create a unique case of a prescribed fixed form, which conflicts with our understanding of worship that Christ “prescribed no fixed forms.”
If a head covering is neither an element of worship nor a form of worship, then it must be a circumstance of worship. This appears to be confirmed by the use of 1 Cor. 11:13–14 as the prooftext for WCF 1.6. (8) This does not mean that one is prohibited from covering his or her head during the worship service — even reformed ministers throughout Europe preached with caps during the early reformation. (9) But it does belong to the church’s authority to regulate “according to the dictates of nature and reason, interpreted more especially by the apostolic canon.” (10)
What About Church History?
The common historiography advanced today is that head coverings for women were the universal practice of the church for nearly the entirety of church history. (11) This claim received a notable challenge in a study report on “The Practice of Headcoverings in Public Worship” that was issued by the Reformed Presbytery in North America in 2001. This report spotlights the views of Scottish commissioners to the Westminster Assembly, George Gillespie and Samuel Rutherford, neither of whom understood head coverings to be morally prescriptive. The views of other significant figures are surveyed as well, such as Calvin and Turretin, and the position articulated in the Geneva Bible notes and in the Augsburg Confession. Each of these sources, according to the report, contradict the commonly advanced historiography.
In addition to those cited in the report above, the Presbyterian Westminster Divine Daniel Cawdrey refers to head coverings in worship as “things in their owne nature indifferent”. (12) He asks whether a synod has the power to enjoin (i.e., require) that which is indifferent in nature and use, and then treats head coverings and ministerial gowns side-by-side. Both, he concludes, are indifferent by nature. To make head coverings into a “morall duty” is something that “no Interpreters upon that Text doe”. A Synod may, however, require or forbid their use, but only as a matter of order.
Additionally, William Whitaker explains Paul’s instructions about coverings “are not of a perpetual obligation.” (13) William Perkins places the issue of preaching with head covered or uncovered in the same non-moral category as sitting or standing while preaching. (14) In another work Perkins refers directly to 1 Cor. 11 and concludes that Paul’s command that the women cover their heads was “according to the custome of their countrey in other assemblies” and notes that the practice carried a different meaning at that time than it did in Perkins’ own day. (15) Herman Witsius opines that Paul, in 1 Cor. 11, “did not intend to lay down a universal law which should be everywhere observed. He merely accommodated himself to a custom of civil life observed, at that time, by those to whom he was writing.” (16)
The purpose of this brief historiography is not to present a unanimous perspective on head coverings in reformation history — and certainly not all of church history. Rather, the purpose is to demonstrate a consistency in the logic of the confession and the logic of several notable, and in certain cases, influential voices on the proper category to which head coverings ought to be assigned. Nevertheless, even with these important voices, our church courts are not bound by a certain historiography of WCF 1.6 nor even the specific views of Divines on this section (i.e., Animus Imponentis). (17)
Conclusion: Perpetual Head Coverings Is a Difference from the Confession
Thus far we have concluded that (1) our confessional standards understand head coverings to be a circumstance of worship, and therefore (2) neither perpetual nor binding on believers across time and culture. What may we conclude, then, with respect to (1) the place of ordained officers who hold to a perpetual head covering view in our system of doctrine, and (2) the role and power of the church in the ordering of head coverings in corporate worship?
First, if the confessional understanding advanced above is correct, it seems to me that ministers, licentiates, transfers, and candidates for ordination who hold to a perpetual head covering view should state this as a difference from the confession. If the perpetual head covering position does, as the argument above suggests, conflate a circumstance with an element, it is difficult to see how this could not be a difference to the confession.
Second, the Session has authority to oversee corporate worship in the church (e.g., BCO 12–5 (e)) and to “set down rules and directions for the better ordering of the public worship of God” (WCF 31.2). This means that a church Session may forbid its use (though wisdom and prudence ought to factor into any decision such as that; and as a conscience issue for some, it would be unwise to leverage such authority heavy handedly) if it does not contribute to the proper ordering of worship (cf. 1 Cor. 14:40). As Bannerman writes, “In what belongs to the circumstances of worship necessary to its being dispensed with propriety, and so as to avoid confusion, the Church has authority to regulate them as nature and reason prescribe.” (18)
But may a Session require the practice? It may theoretically do so, but only insofar as it touches upon the proper ordering of the church. If, however, the practice were understood by a Session to carry special, spiritual significance (i.e., if it were treated, functionally speaking, as an element), this would seem to transgress the power of the church. As Bannerman writes, “So soon as you attach a spiritual meaning, a sacred significance, to anything connected with worship, it becomes eo ipso a part of worship.” (19)
If this practice is on the rise in Presbyterian and Reformed churches today (of which I have heard reports), it is important for ministers and churches to study how this practice fits within our system, and to be prepared to teach our congregations if and when our churches are faced with the issue. I hope this article begins those conversations, if they have not already begun, even if this article’s argument is modified or rejected.
(1) “Whatever is done in worship must either be an element (Word and prayer) or a circumstance.” R. Scott Clark, Recovering the Reformed Confession: Our Theology, Piety, and Practice (Phillipsburg, NJ: P&R Publishing Co., 2008), 267.
(2) James Bannerman, The Church of Christ, rev. ed. (Carlisle, PA: Banner of Truth, 2015), 374, 377.
(3) George Gillespie, A dispute against the English-popish ceremonies, Book 3, 112–15. https://quod.lib.umich.edu/e/eebo/A01760.0001.001?rgn=main;view=fulltext. See comments by James Bannerman, The Church of Christ, 373–6.
(4) Samuel Rutherford further clarified that circumstances may be (1) “either meerly Physicall” (2) “meerly Morall,” or (3) “mixt, partly Morall, partly Physicall”. That which is merely physical, Rutherford explains, includes “1. Time: 2. Place, 3. Person, or Agent: 4. Name. 5. Family: 6. Condition, as Country, Family, House: 7. Habits or Garments: 8. Gestures, as sitting, standing, lifting of the eyes or hands, knocking on the breast, kneeling…” (Samuel Rutherford, The divine right of church-government, 3). Rutherford places head covering, “head covered, or not covered,” in the first category, “meerly Physicall”. Samuel Rutherford, The divine right of church-government, 4, https://quod.lib.umich.edu/e/eebo/A92138.0001.001?rgn=main;view=fulltext. John Allen Deljuk, “Biblical Authority and the Proof of the Regulative Principle in the Westminster Confession,” WTJ 58 (1996): 251.
(5) Rebekah wears a veil (צָעִיף; LXX: θέριστρον) to cover (כסה; LXX: περιβάλλω) herself when she meets Isaac (Gen. 24:65), and Tamar likewise wears a veil (צָעִיף; LXX: θέριστρον) with which she covers (כסה; LXX: περιβάλλω) herself to appear as a prostitute (Gen. 38:14). These, however, involve coverings within a public setting. As far as I can tell, the only peripheral reference that involves a woman’s covering in an OT liturgical context occurs in Num. 5. When a woman is suspected of adultery, the priest must set her before the Lord and unbind (פרע) her hair. While the Hebrew suggests a loosening of the hair, the LXX may suggest an unveiling or uncovering (i.e., ἀποκαλύψει τὴν κεφαλὴν). This, however, is no ordinary liturgical setting.
(6) Dale Patridge, A Cover for Glory (Prescott, AZ: Relearn Press, 2023), 173.
(7) Dale Partridge, A Cover for Glory, 13.
(8) “The light of nature”, both first order and second order, distinguishes male and female (v. 14), which governs the context specific practice of head coverings (v. 13).
(9) For example, Jeremiah Burroughs observes “As now, the French ministers they preach with their hats on, it is the custom there; and no question, if any one were to go among them it were fit they should observe the customs that they have: and so here, to sit down, and in other churches to stand.” Jeremiah Burroughs, “Sermons on Christ’s Sermon in the Mount,” in The Saints’ Happiness, 6, https://www.digitalpuritan.net/Digital%20Puritan%20Resources/Burroughs,%20Jeremiah/The%20Saints’%20Happiness%20(Ind%20Works)/[JB]%20The%20Saints’%20Happiness.pdf. See Travis Fentiman, 1 Corinthians 11 Head-Coverings are Not Perpetual & they were Hair-Buns, with or without Cloth Material: Proven, 65–8, https://reformedbooksonline.com/wp-content/uploads/2022/11/Fentiman-Travis-1-Corinthians-Head-Coverings-are-Not-Perpetual-and-they-were-Hair-Buns-with-or-without-Material-Proven.pdf.
(10) James Bannerman, The Church of Christ, 379.
(11) E.g., Dale Partridge, A Cover for Glory, 1–46. Jeremy Gardiner, Head Coverings: A Forgotten Christian Practice for Modern Times, 9–17.
(12) Daniel Cawdrey, Vindiciæ clavium: or, A vindication of the keyes of the kingdome of Heaven, 57, https://quod.lib.umich.edu/e/eebo2/A78437.0001.001?rgn=main;view=fulltext. For a more thorough and robust review of the historical treatment of head coverings and the regulative principle of worship, see Travis Fentiman, 1 Corinthians 11 Head-Coverings are Not Perpetual & they were Hair-Buns, with or without Cloth Material: Proven, 72–90.
(13) William Whitaker, A Disputation on Holy Scripture (West Linn, Oregon: Monergism Books, 2025), 797.
(14) William Perkins, A godly and learned exposition of Christs Sermon in the Mount, 8, https://www.monergism.com/thethreshold/sdg/perkins/Sermon%20on%20the%20Mount%20-%20William%20Perkins.pdf
(15) William Perkins, A godly and learned exposition or commentarie vpon the three first chapters of the Reuelation, 70, https://quod.lib.umich.edu/e/eebo/A09443.0001.001?rgn=main;view=fulltext.
(16) Herman Witsius, Sacred Dissertations on the Lord’s Prayer, 82, https://www.monergism.com/thethreshold/sdg/witsius/Lord’s%20Prayer%20-%20Herman%20Witsius.pdf.
(17) The Animus Imponetis refers to the intention of the imposing body. With respect to the Westminster Standards, the historical intent of any given proposition in the Standards is, of course, important. But for confessional subscription, the understanding of the ecclesiastical body imposing the Standards takes precedence. In other words, a minister does not subscribe to the particular views of the Westminster Divines on any given topic, only how the imposing body has understood that topic as taught in the Standards.
(18) James Bannerman, The Church of Christ, 371.
(19) James Bannerman, The Church of Christ, 374n.