The petitioner sought permission to exhume the body of his late wife for its re-burial in his back garden. He had been incorrectly advised at the time of the original burial that such burial would require both planning permission and a prohibitively expensive zinc-lined coffin. The chancellor refused to grant a faculty, observing that the future of the intended burial site was necessarily uncertain such that the ‘principles of security and safe custody’ of human remains were threatened and that the purpose of the re-burial of the remains was to satisfy the emotional needs of the deceased's daughter at this stage of the bereavement process. [RA]