In a series of Rules published by the Sacred Congregation of Bishops and Regulars in 1901, concerning the approval of new institutes with simple vows, it is stated that the constitutions of these institutes are to express that they do not bind under pain of sin. Similarly, an Instruction of the Sacred Congregation for the Propagation of the Faith concerning the foundation of religious Congregations in missionary territories insists that: ‘Since these Constitutions are to be observed not out of fear but out of love, they do not of themselves bind under pain of sin …’ And the ‘Statutes to be observed by External Sisters of Monasteries of Nuns’ (1931) affirm that nothing in these statutes, apart from what has been drawn from the Code of Canon Law or other laws of the Church, binds under pain of sin, though the Sisters are obliged to accept the penance imposed for infractions of their constitutions.