The petitioner sought a faculty for the exhumation of his father's cremated remains in order for them to be scattered, together with the remains of the petitioner's mother, in Skerray in Scotland. The petition was refused on two grounds: first, there had simply been a change of mind as to the intended interment of the remains, which did not amount to a special reason that would provide an exception to the presumption of permanence; second, the remains had been committed to the protection of the church and the intention to scatter the remains was inconsistent with their continued security and safe custody. The chancellor found it difficult to envisage circumstances in which it would be appropriate to allow remains to be exhumed for the purpose of their subsequent scattering. [RA]