The petitioner and her family objected to the enforcement by the incumbent and PCC of the chancellor's churchyard regulations in so far as that involved the removal of items, such as vases, that had been placed on the plot containing the cremated remains of the petitioner's late husband. The petitioner accordingly sought a faculty for the exhumation of the cremated remains on the basis that she would then retain them at her own home until she herself died. The deputy chancellor held that the petitioner's objection to the enforcement of the churchyard regulations did not amount to a special reason for departing from the norm that Christian burial was permanent. Even if, as the deputy chancellor was prepared to assume, the petitioner had been mistaken as to precisely what might be permitted in terms of the placing of flowers and containers in the churchyard, the churchyard regulations did not completely prohibit the placing of such items. The fact that what was permitted did not accord in all respects with what the petitioner and her family might have wished did not amount to a ‘mistake’ of the sort that would justify an exception from the presumption against exhumation. To grant a petition based on an objection to the enforcement of the churchyard regulations would not only undermine the principle of the permanence of burial but would also risk undermining the role of those responsible for enforcing the regulations. The deputy chancellor declined to grant a faculty. He went on to hold that, even if a case for exhumation had been made out, he would have been loath to grant a faculty permitting the exhumation of the remains when it was clear that the petitioner had no intention of arranging for them to be immediately re-interred elsewhere. The deputy chancellor went on to consider the application of various articles of the European Convention on Human Rights and associated case law and held that the relevant ecclesiastical law was consistent with the applicable articles of the Convention. [Alexander McGregor]