Having reviewed recent decisions of consistory courts, the deputy chancellor concluded that, under the Court of Arches guidelines in Re Blagdon Cemetery [2002] Fam 299, the transfer of the remains of a family member to an existing family grave was capable of being an exception and constituting a special circumstance sufficient to outweigh the presumption of permanence of burial. A credible explanation was required for any lapse of time but that was not a determining factor. [Alexander McGregor]