Note 32 — INTERMENTS IN TOWNS. (continued 5)

Perpetuities in burial grounds may be said to have been declared illegal by Lord Stowell’s decision in the case of Gilbert v. the Churchwardens of St. Andrew’s, Holborn, on the use of iron coffins. His lordship, in his judgment in that case, remarked, that “All contrivances that, whether intentionally or not, prolong the time of dissolution beyond the period at which the common local understanding and usage have fixed it, is an act of injustice, unless compensated in some other way.”—Haggard’s Rep. v. 2, p. 353. Vide statement of the principle of this decision, in the extracts from the judgment given in the Appendix, No. 12.