In his recent article on the issue of the proposed banning of conversion therapy published on the Via Media website, the Bishop of Manchester, David Walker, argues that in thinking about this issue we need to focus on the issue of harm. He calls for a ‘victim centred approach’ that focusses on ‘the severity and durability of the harm done, not whether that damage was done by prayer, hypnosis or psychological techniques.’ 
As I read it, his argument seems to be that there is ‘a massive pile of evidence’ that all forms of conversion therapy cause harm and that therefore we should simply get on and ban them.
I have two problems with this argument.
First, it is not clear that the massive pile of evidence to which he refers actually exists.
At the time of the General Synod debate on conversion therapy in 2017, Peter Ould pointed out that Synod members needed to be wary of the claims put forward in a paper from Jayne Ozanne about the harm done by Sexual Orientation Change Efforts (SOCE). Having surveyed the relevant evidence, his conclusion was that:
‘The overwhelming majority of ‘proof’ that is offered to support the idea that SOCE harm people is both anecdotal in nature and lacks any independent assessment of the alleged harm. Often, as in Shidlo and Shroder 2002, the raw data reveals more than the headlines and indicates complexity and nuance which needs to be taken into account. Finally, leading secular therapeutic organisations recognise that the level of research that is required to make a definitive declaration of the outcomes of SOCE has yet to be undertaken.’ 
In the four years since Ould’s article nothing seems to have changed. We simply cannot say that the evidence shows that conversion therapy in relation to sexual orientation is necessarily harmful. As Ould points out in another article, the one really rigorous study that has been undertaken to assess the impact of conversion therapy in relation to sexual orientation, the 2011 study by Stanton Jones and Mark Yarhouse, found that there was ‘no statistically significant evidence of harm, even in those for whom the therapy ‘failed’ or who dropped out.’ 
If we turn to the issue of conversion therapy in relation to gender identity, we find that there is a debate about whether such conversion therapy is happening at all and there does not seem to be any robust evidence that if it is happening it is causing harm. The ‘2020 Conversion Therapy and Gender Identity Survey’ claimed that there was evidence that ‘GICT is harmful and has negative effects on public health’ but as Michael Biggs notes in his review of the survey:
‘The research reported in the pamphlet has little, if any, scientific value. It reinforces the impression that the proposed legislation is motivated by the desire to further institutionalize gender ideology rather than the need to address a real social problem.’
If legislation is to be introduced making something illegal, then there has to be robust evidence that the practice concerned does serious harm. Bishop David does not produce such evidence in his article, and it is not clear that anyone else has yet produced it either.
My second problem with Bishop David’s argument is that he fails to address the issue of harm from a proper Christian theological perspective.
From a Christian perspective what is harmful to human beings is anything that prevents them from living in the way that God created them to live. For example, it is harmful to deprive people of food, because God has created human beings as biological organisms who need food in order to live at all. For another example, it is harmful to deprive people of education, because this will prevent the full development of the intellectual capacities that God has given them.
If we extend this understanding of harm to the issues of sexual identity and behaviour, we find that the witness of both nature and Scripture (Genesis 1:26-28) is that human beings have been created by God in two sexes, male and female, with the members of these two sexes being differentiated biologically by the fact that their bodies are ordered towards the performance of different roles in sexual reproduction and in the nurture of children once they have been born. Furthermore, Scripture teaches us that God has instituted marriage between a man and a woman as the context for sexual intercourse and for the begetting and raising of children (Genesis 2: 18-25).
If God has created human beings in this way, it follows that it is harmful for human beings to live in a way that contradicts this fact. It is harmful for a man to live as if he was a woman or vice versa, or for a man or woman to claim some form of alternative sexual identity. It is harmful for a man, or a woman, to have sex outside marriage, either with a member of the opposite sex, or with a member of the same sex.
As a result of the sinful disorder that in exist in all human beings as a result of the rebellion against God that took place at the start of human history and the idolatry that has been the fruit of this rebellion (Genesis 3:1-14, Romans 1:18-32) there are people who desire to live in these harmful ways. In this situation, Christian care for others requires that we seek to help those for whom this the case to control their desires in order that they may live in the way God created them to live. Such help will take the form of teaching, prayer, counseling and general pastoral support.
The danger with the proposal to ban conversion therapy is that it may result in such care for others being against the law.
For example, the campaign group Ban Conversion Therapy declare that:
‘Any form of counselling or persuading someone to change their sexual orientation or behaviour so as to conform with a heteronormative lifestyle or their gender identity should be illegal no matter the reason, religious or otherwise – whatever the person’s age.’ 
What this means is that they want it to be illegal for Christians to try to persuade people to refrain from same-sex sexual activity, or to live according to their sex, or support them in trying to do so. This could mean, for instance, that a member of the clergy could be breaking the law if they preach a sermon saying that sex should only take place within heterosexual marriage, or that a Christian youth worker could be breaking the law if they seek to help a young person struggling with whether to adopt a transgender identity.
The Church of England activist Jayne Ozanne even wants to go so far as to forbid prayer. In an article in The Guardian, Bishop David suggested that a ban on conversion therapy would still allow ‘gentle non-coercive prayer’ but Ozanne rejects this idea, stating that:
‘All prayer that seeks to change or suppress someone’s innate sexuality or gender identity is deeply damaging and causes immeasurable harm, as it comes from a place – no matter how well meaning – that says who you are is unacceptable and wrong.’ 
As the Evangelical Alliance explained in a letter to the Prime Minister on the issue, a ban on conversion therapy thus has the potential to:
‘….threaten everyday practises of churches church leaders and Christians across the UK. An expansive definition of conversion therapy, and a ban along such lines, would place church leaders at risk of prosecution when they preach on biblical texts relating to marriage and sexuality. It would place ministry leaders at risk of arrest for encouraging young people to maintain chastity until marriage. And it would criminalise a member of a church who prays with another member when they ask for prayer to resist temptation as they are attracted to someone of the same sex but do not wish to act on it.’
In such a situation Christians would be faced with a choice of either ceasing to help others who are living in harmful ways, or who are tempted to do so, or breaking the law. In his Via Media article Bishop David is totally silent about this issue
In summary, Bishop David is calling for a ban on conversion therapy in order to prevent harm even though the evidence for the existence of such harm is unclear. In addition, he ignores the need for Christians to help others to avoid living in ways that are clearly harmful because they are contrary to the way God created his human creatures to live, and he is silent about the danger that a ban on conversion therapy would make giving such help illegal.
 David Walker, ‘Banning Conversion Therapy Must “Focus on the Victim Not the Perpetrator” Via Media.News 9 June 2021.
 Peter Ould, ‘Do sexual orientation change efforts cause harm? Possibly, but….’ athttps://www.psephizo.com/sexuality – 2/do-sexual-orientation-change-efforts-cause-harm-possibly-but.
 Stanton Jones and Mark Yarhouse, ‘A longitudinal study of attempted religiously mediated sexual orientation change,’ Journal of Sex and Marital Therapy, Vol.37. Issue 5, 2011.
 Peter Ould, It’s easy to talk about banning gay conversion therapy. But how to do it – and where’s theevidence?’ Christian Today, 23 June, 2017.
 See Shelley Charlesworth ‘Is Gender identity conversion therapy taking place in the UK?’ at https;//www.transgendertrend.com/gender-identity-conversion-therapy-uk.
 Michael Biggs, ‘Conversion Therapy’ & Gender Identity Survey: an analysis by Michael Biggs’ athttps://trangendertrend.com/conversion -therapy-gender-identity-survey-analysis.
 Ban Conversion Therapy quoted by Danny Webster in ‘The challenges a around conversion therapy’ at https://www.eauk.org/news-and-views/the-challenges-around-conversion-therapy
 Harriet Sherwood, ‘’C of E bishops backs prosecution of those who defy ‘gay conversion’ ban,’ The Guardian,9 June 2021.
 The Evangelical Alliance, letter to the Prime Minister, 15 March 2021 a https://www.eauk.org/assets/files/downloads/Evangelical-Alliance-letter-on-conversion-therapy-15-March 2021.pdf