“the Catholic Church spread over the world believes in the resurrection of the bodies of the dead. These have been sanctified by the reception of the Sacraments, and are consequently buried, not in profane places, but in specially enclosed and consecrated cemeteries, or in churches, where with due reverence they are kept, like the relics of the Saints, till the day of the resurrection.” The trees that grew within the precincts of the cemetery were at times a fertile cause of dispute between the priest and his people. Were they the property of the parson or of the parish? And could they be cut down at the will of either? In the thirteenth century, when the charge of looking after the churchyards was regarded as weighing chiefly on the clergy, it was considered that to repair the church--either chancel or nave--the trees growing in them might be cut. Otherwise, as they had been planted for the purpose of protecting the churches from damage by gales, they were to be left to grow and carry out the end for which they had been placed there. Archbishop Peckham had previously laid down the law that, although the duty of keeping the enclosure of the cemetery rested upon the parishioners, what grew upon holy ground being holy, the clergy had the right to regard the grass and trees and all that grew in the cemetery as rightly belonging to them. In cutting anything, however, the archbishop warned the clergy to remember that these things were intended to ornament and protect God’s house, and that nothing should be cut without reason. However the question of the ownership of the trees growing in churchyards may have been regarded by the parishioners, there are evidences to show that they did not hesitate to adorn their burial-places with trees and shrubs when needed. At St. Mary’s, Stutterton, for instance, in 1487, the churchwardens purchased seven score of plants from one John Folle, of Kyrton, and paid for “expenses of settyng of ye plants, 16_d._” The sacred character of consecrated cemeteries was recognized by the law. Bracton says that “they are free and absolute from all subjection, as a sacred thing, which is only amongst the goods of God--whatever is dedicated and consecrated to God with rites and by the pontiffs, never to return afterward to any private uses.” And amongst these he names “cemeteries dedicated, whether the dead are buried therein or not, because if those places have once been dedicated and consecrated to God, they ought not to be converted again to human uses.” Indeed, “even if the dead are buried there without the place having been dedicated or consecrated, it will still be a sacred place.”