Two parishes sought faculties approving bespoke regulations for their churchyards. The chancellor took the opportunity to give guidance to parishes when seeking such a variation of the diocesan churchyard regulations. He indicated that full reasons would need to be provided for the proposed changes and that there was no need to obtain a notification of advice from the Diocesan Advisory Committee (DAC). DAC consultation would be directed where appropriate. In determining the petition, the chancellor would give little or no weight to existing illegally introduced memorials but considerable weight to existing legally introduced memorials.

The chancellor emphasised that the churchyard regulations were an instrument of delegation from the chancellor's authority to permit memorials in churchyards. That authority was limited only by the court's inability to permit something which is contrary to, or indicative of any departure from, the doctrine of the Church of England in any essential matter. He reviewed the approach to the churchyard regulations in some other dioceses and rejected the suggestion that some substantial or exceptional reason was needed in order to justify a departure from the regulations. Rather, each case would be determined on its own merits, with the burden of proof resting on the petitioner. [RA]