In Re Lambeth Cemetery [2025] ECC Swk 2, Petchey Ch. addressed the scattering of crenation ashes, [26] to [31], and whether it was unlawful for an Anglican minister to scatter cremated remains as opposed to strewing [1]. He noted that cremation is addressed in canon law by Canon 38 of which subsection 4 (b) states:
“The ashes of a cremated body should be reverently disposed of by a minister in a churchyard or other burial ground…or on an area of land designated by the bishop for the purpose of this sub-paragraph or at sea”.