The Commissary Court ruled that the emotional distress caused to David John Woods’s family by his being interred in a plot alongside an individual who, they allege, had financially abused and exploited them justified a departure from the presumption of the permanence of Christian burial. Mrs Woods made the petition for exhumation and reburial, alleging that X had financially abused and exploited their daughter many years ago, causing distress to their family, and that Mr Woods had spent many years paying off the debts incurred as a result of X’s conduct. She said that, had the clergy known about the Woods family’s feeling towards X at the time of Mr Woods’s burial, X would not have been interred beside him.