In 2013 we noted that in view of the diminishing availability of burial space in England and Wales, the reservation of graves is likely to become an increasingly important issue, Marriage and burial obligations of the Church of England. Local authority policies vary from sequential interments to the personal selection and reservation of specific plots. In the case of churchyards, however, a Faculty is required for such a reservation. Re All Saints Heathfield  Chichester Const Ct, Mark Hill Ch. addressed the issue of reservation when there were only “four or five” spaces remaining (at the time of the hearing). By contrast, the more recent case discussed below, Re St. Wilfrid Grappenhall  Chester Const Ct, David Turner Ch., considers the adoption of a “non-reservation” policy by a PCC well in advance of the situation becoming critical.