Coventry Consistory Court; Gage Ch. September 1996

The Chancellor refused a faculty for the introduction of a memorial slab into an area of the churchyard reserved for the cremation of human remains. Whilst acknowledging that the widow of the deceased might have been misled by what was said by a retired priest who conducted the service some five years earlier and that elsewhere in the churchyard memorials abounded, the diocesan Guidelines and Rules for the Care and Maintenance of Churchyards (of which the widow was ignorant) provided at D9 that, 'The Chancellor will normally require a condition for any new reserved area that limits commemoration solely to a book of Remembrance in the church and prohibits memorials within the Churchyard.' There was no exceptional reason for not applying the Guidelines. Indeed to do so, he said, "might be regarded as breaking faith with some of those bereaved who complied with the Guidelines".

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(1998) 5 Ecc LJ 66