Worcester Consistory Court: Mynors Ch, September 1999
In the course of a judgment, the facts of which are immaterial, the chancellor observed that he would wish to expand the third guideline commended by the Chancery Court of York in Re Christ Church A hager [ 1999] Fam 142 (noted at (1999) 5 Ecc LJ 214) so as to read:
'3. In other cases, it will not normally be sufficient to show:
(a) a change of mind on the part of the relatives of the deceased;
(b) that some or all of those relatives are no longer able conveniently to visit the grave;
(c) that the spouse or another close relative of the deceased has subsequently been buried elsewhere;
(d) that a surviving spouse or other close relative wishes to be buried (in the future) in the same place as the deceased-but that a further burial at the same location as that which has already taken place is either for some reason now impossible or else considered to be undesirable.
Some other circumstance must usually be shown.'
Applying such expanded guideline, the chancellor refused the petition.
(2000) 5 Ecc LJ 391
