Particular Consecrations
When it declared devoid of canonical effect the consecration ceremony conducted by Archbishop Pierre Martin Ngô Đình Thục for the Carmelite Order of the Holy Face group at midnight of 31 December 1975, the Holy See refrained from pronouncing on its validity. It made the same statement with regard also to later ordinations by those bishops, saying that, "as for those who have already thus unlawfully received ordination or any who may yet accept ordination from these, whatever may be the validity of the orders (quidquid sit de ordinum validitate), the Church does not and will not recognise their ordination (ipsorum ordinationem), and will consider them, for all legal effects, as still in the state in which they were before, except that the ... penalties remain until they repent" (Sacred Congregation for the Doctrine of the Faith, Decree Episcopi qui alios of 17 September 1976 - Acta Apostolicae Sedis 1976, page 623).
A similar declaration was issued with regard to Archbishop Emmanuel Milingo's conferring of episcopal ordination on four men - all of whom, by virtue of previous Independent Catholic consecrations, claimed already to be bishops - on 24 September 2006: the Holy See, as well as stating that, in accordance with Canon 1382 of the Code of Canon Law, all five men involved incurred automatic ("latae sententiae") excommunication through their actions, declared that "the Church does not recognise and does not intend in the future to recognise these ordinations or any ordinations derived from them, and she holds that the canonical state of the four alleged bishops is the same as it was prior to the ordination."
In contrast, the Holy See has not questioned the validity of the consecrations that the late Archbishop Marcel Lefebvre performed in 1988 for the service of the relatively numerous followers of the Traditionalist Catholic Society of St. Pius X that he had founded, and of the bishops who, under pressure from the Chinese Catholic Patriotic Association, "have been ordained without the Pontifical mandate and who have not asked for, or have not yet obtained, the necessary legitimation", and who consequently, Pope Benedict XVI has declared, "are to be considered illegitimate, but validly ordained".
Some have questioned the mental capacity of Archbishop Ngô to form the requisite intention to consecrate. On this question it would be extremely difficult to obtain a definitive objective judgement. Ngô was advanced in age and was reportedly experiencing a dementia at the time of his actions in question.
Read more about this topic: Episcopi Vagantes