by the norm of the Code of Canon Law of 1917, confirmed in the 1983 Code, the tribunal of second instance for appeals from a metropolitan tribunal is "the tribunal which the metropolitan has designated in a stable manner with the approval of the Apostolic See".

The closest equivalent position in the Eastern Churches in 1911 was an Exarch.

The Holy See has continued in modern times to grant the title of Primate. With the papal decree Sollicitae Romanis Pontificibus

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