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One of his most important works, the Missa Papae Marcelli ( Pope Marcellus Mass ), has been historically associated with erroneous information involving the Council of Trent.
According to this tale, it was composed in order to persuade the Council of Trent that a draconian ban on the polyphonic treatment of text in sacred music ( as opposed, that is, to a more directly intelligible homophonic treatment ) was unnecessary.
However, more recent scholarship shows that this mass was in fact composed before the cardinals convened to discuss the ban ( possibly as much as ten years before ).
Historical data indicates that the Council of Trent, as an official body, actually never banned any church music and failed to make any ruling or official statement on the subject.
These stories originated from the unofficial points-of-view of some Council attendees who discussed their ideas with those not privy to the Council's deliberations.
Those opinions and rumors have, over centuries, been transmuted into fictional accounts, put into print, and often incorrectly taught as historical fact.
While we do not know Palestrina's compositional motivations, he may have been quite conscious of the need for intelligible text, however, this was not to conform with any doctrine of the Counter-Reformation, because no such doctrine exists.
His characteristic style remained consistent from the 1560s until the end of his life.
Roche's hypothesis that Palestrina's seemingly dispassionate approach to expressive or emotive texts could have resulted from his having to produce many to order, or from a deliberate decision that any intensity of expression was unbecoming in church music has not been confirmed by historians.

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