In re St Chad, Bishop’s Tachbrook [2014] WLR (D) 24
‘The fact that a churchyard was still in use for burials and interments and that a proposed building would take up space which could otherwise be used for burials was a relevant factor but not necessarily determinative of a petition for a faculty. In an appropriate case permission could be given for a building even if it reduced space available for burials since there was now greater flexibility to permit the secular use of consecrated land. Not every secular use would be permissible; the decision whether to permit such use would be a matter of fact and degree with the nature, extent, and permanence of the proposed secular use all being relevant.’
WLR Daily, 9th January 2014
Source: www.iclr.co.uk