Liverpool Consistory Court: Hamilton Ch, October 2001
X was buried with his late wife and deceased daughter, Miss X. X's other daughter, W, sought a faculty for the exhumation of X's body for the purposes of re-interment in the place of his birth or burial at sea because X had sexually abused Miss X and another sister. The chancellor granted the faculty on the basis that X would be re-interred elsewhere with a simple headstone and gave permission to remove X's name from the existing headstone by alteration or replacement. The chancellor noted the extreme facts in this case but held that one purpose of a grave was to provide a focus for peaceful and quiet mourning and that X's presence in the grave prevented this.
(2002) 6 Ecc LJ 413
