The petitioners sought a faculty for the introduction of a memorial, including the words ‘Dad’ and ‘Granddad’. The chancellor had, at an earlier stage, indicated that the proposed words did not fall foul of the diocesan churchyard regulations, which required inscriptions to be ‘simple, dignified and reverent’; however, the incumbent had (as he was entitled to do) refused permission for it on the grounds that the Parochial Church Council (PCC)’s churchyard policy meant that the proposed words were not allowed. The policy provided that the list of relationships on a memorial would be limited to four, and must come from an identified list which included ‘Father’, ‘Mother’, ‘Grandfather’, ‘Grandmother’ and so forth.

Due weight must be given to policies properly adopted by the PCC, provided they were clearly formulated and adopted, and reasonable in substance (see, for example, re St Wilfrid, Standish [2017] ECC Bla 2, (2019) 21 Ecc LJ 110). The court considered that the PCC's policy was ambiguous, referring to relationships rather than the words used to refer to those relationships; it was therefore not clear that ‘Dad’ and ‘Granddad’ did not conform to the policy. Further, the policy was not reasonable (in the sense of there being a good reason for it). If the policy was thought necessary to give effect to the diocesan regulations, this was incorrect: the words were in common use, they spoke meaningfully to future generations and they did not lack dignity or reverence. If there was a wider justification, it had not been provided to the court. There were several examples of memorials bearing those or similar words in the same churchyard. Given that, and the lack of fundamental objection to the proposals, it would be unfair not to permit the proposed wording in this case. [DW]