Cemeteries

Cemetery

Name

The word coemeterium or cimiterium (in Gr. koimeterion) may be said in early literature to be used exclusively of the burial places of Jews and Christians. A single doubtful example (Corp. Inscript. Lat., VIII, n. 7543), where it seems to be applied to a pagan sepulture, can safely be disregarded, and though the word, according to its etymology, means sleeping place (from koimasthai, to sleep), its occurrence in this literal sense is rare. Moreover, the phrase "their so-called cemeteries" (ta kaloumena koimeteria), used in an imperial edict of 259, shows that it was even then recognized as a distinctive name. The word occurs in Tertullian (De anima, c. li) and is probably older. Let us add that though what we now understand by a cemetery is a separate, park-like enclosure not being the "yard" of any church, the word was originally of much more general application. It was applied either to any single tomb or to a whole graveyard, and was the usual term employed to designate those subterranean burial places now commonly known as the catacombs.

Early History

There can be little doubt that in the beginning of the preaching of Christianity the converts to the Gospel were content to be interred without distinction in the graves of their Jewish brethren (Acts, v, 6, viii, 2, and ix, 37). But it is also plain from the nature of things that this arrangement could not have been of long duration. To the Jew the dead body and all connected with it was an uncleanness. To the Christian it involved no contamination, but was full of the hope of immortality. (I Cor., xv, 43). The practice of separate interment must, therefore, have begun early both in Rome and in other places where there were large Christian colonies. It would seem that the earliest Christian burial places were family vaults (to use a rather misleading word) erected upon private property. But the desire to rest near those of their own faith who had passed away before must have been especially strong in Rome, where even artisans practising the same trade sought to be buried side by side with their fellow-craftsmen and formed associations for the purpose. Wealthy Christians accordingly enlarged their family burial places and admitted their poorer brethren to share them. "For himself, for his freedmen, and for charity" (sibi et libertis et misericordiæ) is an inscription found in a construction of this class. Partly owing to the nature of the soil, partly, no doubt, to the desire of imitating the burial places in the neighbourhood of Jerusalem, and in particular the sepulchre of Christ, the practice was largely followed of excavating a subterranean chamber or series of chambers in the recesses of which bodies could be laid and walled in with bricks or marble slabs. The need of interring a disproportionately large number of persons upon one small property probably led to the early development of a system of narrow galleries tunnelled through the tufa, with horizontal niches (loculi) scooped out in the walls on both sides. At the same time it would be a mistake to suppose that Christians throughout the Roman Empire were compelled to resort to great secrecy regarding their interments. On the contrary, the well-understood principle of law that a burial place was a locus religiosus and consequently inviolable seems at normal times to have guaranteed to the Christians a large measure of immunity from interference. The jurisdiction which the pagan College of Pontiffs possessed over all places of sepulture no doubt caused difficulties, especially at those epochs when active persecution broke out, but the general tendency of the Roman magistrates was to be tolerant in religious matters. Moreover it is probable that for many years after the Gospel was first preached in Rome the Christians were looked upon merely as a particular sect of Jews, and the Jews, as we may learn from Horace and other pre-Christian writers, had long held a recognized and assured position which excited no alarm.

Hence from Apostolic times down to the persecution of Domitian, the faithful were interred upon private burial allotments, situated like the pagan tombs along the border of the great roads and of course outside the walls of the city. Moreover, as Lanciani says, "these early tombs whether above or below ground, display a sense of perfect security and an absence of all fear or solicitude" (Lanciani, Pagan and Christian Rome, 309). The vestibule and crypt of the Flavians, members of Domitian's own family, afford a conspicuous example of this. The ground, bordering on the Via Ardeatina, belonged to Flavia Domitilla, the niece of Domitian. Here a catacomb was excavated, a portion of which seems to have been set aside for the interment of the family. The entrance can plainly be seen from the road, and the vestibule and adjoining chambers still remain in which, according to Roman custom, anniversary feasts took place in honour of the dead. In this case the feasts would have been the agapæ, or love feasts of the Christians, probably preceded or followed by the Holy Sacrifice of the Mass; but the custom of honouring the third, ninth (afterwards seventh), thirtieth, and anniversary day of the decease seems to have been borrowed from the religious observances of Greece and Rome and to date from the earliest times. In contrast to these original private tombs the portion of the catacomb excavated for the use of the Christian community at large consisted of a vast network of galleries dug at more than one level. For a while, like many other underground Christian cemeteries, this catacomb seems to have been known by the name of the donor, Domitilla, but later it was called after the holy martyrs Nereus and Achilleus, who were subsequently buried there. Further, towards the close of the fourth century a basilica in honour of these two martyrs was erected upon the spot. Their tomb was near the entrance and consequently it was not disturbed, but the ground was dug away and the church built immediately over the tomb, much below the level of the surrounding soil. On the other hand, through devotion to these saints interments multiplied and numerous fresh galleries for the purpose were excavated in the immediate vicinity of the church. All this is typical of what took place in many other instances. The early burial places, which were certainly in private ownership and confined to isolated plots of ground (areæ), seem in the third century to have often become property held by the Christian community in common, other adjoining allotments being bought up and the whole area honeycombed with galleries at many different levels. We learn from the "Philosophumena" that Pope Zephyrinus appointed Callistus (c. 198) superintendent of the cemeteries. So again we have distinct record of the restoration of the cemeteries to the Christians in 259 after the Valerian persecution. (Euseb., Hist. Eccles., VII, xiii.) According to De Rossi the freedom which the Church at normal times enjoyed in their possession was due to the fact that the Christians banded themselves together to form a collegium funeraticium, or burial society, such associations, of which the members paid a certain annual contribution, being expressly recognized by law. (See Roma Sotterranea, I, 101 sq.) For this view there is very good evidence, and though objections have been raised by such authorities as Monseigneur Duchesne and Victor Schultze, the theory has by no means been abandoned by later scholars. (See Duchesne, Histoire ancienne de l'eglise, I, 384; Marucchi, Eléments d'archéologie, I, 117-124.)

When martyrs were thus buried, crowds of their fellow-Christians desired to be buried near them; moreover, some sort of open space forming a small chamber or chapel was generally opened out where Mass could be celebrated upon or beside the tomb. Still, this was only an occasional use. The catacombs, owing to difficulties of light and ventilation, were not ordinarily used as places of Christian worship except at times of fierce persecution. After Constantine's edict of toleration (312), when peace was restored to the Church, basilicas were sometimes built over portions of the catacombs, especially over the known burial place of some favourite martyrs. At the same time, during the fourth century the eagerness to be interred in these subterranean galleries gradually waned, though the zeal of Pope Damasus in honouring the tombs of the martyrs seems to have revived the fashion for a few years at a later date. After 410, when Rome was sacked by Alaric, no more burials took place in the Roman catacombs, but the earlier spread of Christianity is well illustrated by the excavations made. Any accurate estimate is of course impossible, but Michael de Rossi calculated that in the zone of territory lying within three miles of the walls, more than five hundred miles of subterranean galleries had been tunnelled and that the number of Christians buried therein must have exceeded 1,700,000. The use of open-air cemeteries in place of catacombs had probably begun in Rome before Constatine. Many have been identified in modern times (De Rossi, Roma Sotterranea, vol. III, bk. III), though it is not always easy to determine exactly the period at which they started. In other parts of the world it is quite certain that innumerable open-air Christian cemeteries were in existence long before the close of the period of persecutions. We may cite as characteristic the discoveries of Dr. W. M. Ramsay in Phrygia, where many Christian graves clearly belong to the second century, as also those of Northern Africa, of which we hear already in Tertullian, and in particular those of Salona in Dalmatia (second to sixth century; see Leclercq, Manuel d' archéologie, I, 327-329). This last is particularly interesting because the surviving remains illustrate so clearly the extreme antiquity of the practice of interring the dead in the near neighbourhood of the oratories in which the Christians assembled to offer the Holy Sacrifice. It is probably to this custom that we may trace the origin of the lateral chapels which have become so notable a feature of all our greater churches No doubt the tendency to surround the church with graves was long kept in check by the Roman law forbidding the dead to be interred within the walls of cities; but this law at an early date began to be disregarded, and after the pontificate of John III (560-575) it would seem that burials at Rome generally took place within the walls.

As a rule the Christians, though their cemeteries were separate, accommodated themselves in things permissible to the burial usages of the peoples among whom they lived. Thus in Egypt the early Coptic Christians converted their dead into mummies with the use of asphalt and natron. Again, though catacombs existed far away from Rome in many places where the soil favoured such excavations, e.g. in Naples and Sicily, still, in certain tracts of country otherwise suitable, e.g. in Umbria, the early Christians abstained from this method of interment, apparently because it was not used by the pagan inhabitants (see N. Müller in Realencyklopadie f. prot. Theol., X, 817).

Burial in Churches

The fact that the tombs of the martyrs were probably the earliest altars (cf. Apoc., vi, 9), together with the eager desire to be buried near God's holy ones, gradually led up to the custom of permitting certain favoured individuals to be interred not only near but within the church. It may be said that the Roman emperors led the way. Constantine and Theodosius were buried under the portico of the church of the Apostles in Constantinople. At Rome, when the restrictions against burial within the city began to be set aside, the entrance of St. Peter's became the usual place of interment for the popes and other distinguished persons. It was no doubt in imitation of this practice that King Ethelbert of Canterbury was persuaded by St. Augustine to dedicate a church to Sts. Peter and Paul outside the town, with the intent "that both his own body and the bodies of his episcopal successors and at the same time of the kings of Kent might be laid to rest there". They were in point of fact buried in the vestibule. Probably a varying phase of the same tendency may be recognized in the practice of erecting little shelters or oratories, basilicæ, over certain favoured graves in the open. The Salic law prohibited outrages upon such basilicas under heavy penalties: "Si quis basilicam super hominem mortuum exspoliaverit 1200 denarios culpabilis iudicetur", i.e. "If any one shall plunder a basilica erected over the dead he shall be fined 1200 denarii" (cf. Lindenschmidt, Handbuch d. deutsch. Alterthumskunde, I, 96). But interment within the church itself had been known from an early date in isolated cases. St. Ambrose allowed his brother Satyrus, although he was a layman, to be buried within the church beside the tomb of the martyr. As for himself, he wished to be buried under the altar of his own basilica. "Hunc ego locum (sc. sub altari) praedestinaveram mihi. Dignum est enim ut ibi requiescat sacerdos ubi offerre consuevit", i.e. "This place (beneath the altar) I had chosen for myself. For it is fitting that where the priest has been wont to sacrifice, there should he rest (Migne, P. L., XVI, 1023). In the earlier periods, however, when we hear of burial in churches we may as a rule presume that the cemetery basilicas are meant (cf. De Rossi, Roma Sotterranea, III, 548 sq.), and for a long time the resistance made to the growing practice of burial in churches was very determined. Of the numerous conciliar decrees upon the subject that of Vaison in 442 may be taken as a specimen. "According to the tradition of our ancestors", it says, "measures must be taken that on no account should anyone be buried within the churches, but only in the yard or in the vestibule or in the annexes [exedris]. But within the church itself and near the altar the dead must on no account be buried." This decree with others of similar purport was afterwards incorporated in the canon law. As may be learned from St. Gregory of Tours it was frequently disregarded in the case of bishops and royal personages, but on the other hand we have record of many other bishops, abbots, and other distinguished men both in the sixth century and later who were buried juxta urbem, or in campis, or in communi coemeterio. St. Acca (q.v.) might be mentioned as an English example in point. None the less in the first half of the ninth century the serious abuses attendant upon the neglect of this prohibition were constantly complained of. The passage in the capitularies of Theodulfus (c. 790) is particularly interesting because it was afterwards translated into Anglo-Saxon (c. 1110) in the following form:

It was an old custom in these lands often to bury departed men within the church and to convert into cemeteries [lictunum] the places that were hallowed to God's worship and blessed for offering to Him. Now it is our will that henceforth no man be buried within a church unless it be some man of the priesthood [sacerdhades] or at least a layman of such piety that it is known that he by his meritorious deeds earned when living such a place for his dead body to rest in. It is not our intention however that the bodies which have been previously buried in the church should be cast out but that the graves which are seen therein be either dug deeper into the earth or else be levelled up and the church floor be evenly and decently laid so that no grave [ nan byrgen] be any longer apparent. But if in any place there be so many graves that it is impossible to effect this, then let the place be left as a cemetery [ Thonne læte man tha stowe to lictune] and the altar be taken from thence and set in a clean [i.e. new] place and a church be there raised where people may offer to God reverently and decently. (Thorpe, Eccles. Institutes and Laws, 472)

This decree plainly shows both that the law against burying within the churches had often been disregarded in the past and also that any attempt to enforce it rigidly was looked upon as impracticable. No one could determine the precise degree of piety which merited a relaxation, and in most countries those whose dignity, wealth, or benefactions enabled them to press their claims with vigour had little difficulty in securing this coveted privilege for themselves or for their friends. The English liturgist, John Beleth, seems to admit that any patronus ecclesiæ, i.e., the patron of a living, could claim to be buried in the church as a right, and his words are adopted by Durandus, though possibly without a full appreciation of their meaning. Still, such lay interments within the sacred building and especially in the chancel always stood in contradiction to the canon law, and some show of resistance was generally made. In particular, it was insisted on that tombs should not project above the pavement or should at least be confined to the side chapels. The ecclesiastical legislation of the seventeenth and eighteenth centuries continued to recognize the right of the clergy to be buried within the sacred building, but it need hardly be remarked that the intervention of state legislation in almost all modern countries has deprived these decrees of much of their practical importance.

Medieval Cemeteries

When the tribes of the North were first converted to Christianity an effort was generally made to restrain the converts from being buried in the barrows used by the pagans. This does not seem to have been the case to the same extent when the Gospel was preached to the Romanized Gauls. There, says Boulanger (Le mobilier funeraire gallo-romain et franc, 27), the pagan and the Christian Roman will often be seen resting side by side. "Glass with biblical subjects or pottery bearing Christian inscriptions may be found next door to a grave which contains the obol intended for Charon." In the Frank and Saxon interments there is not usually this confusion of pagan and Christian. At the same time, the national burial custom, which required the warrior to be buried with his arms and the girl with her ornaments and the implements of her daily occupation, was long observed even by Christians. The temptation which this custom offered for the rifling of graves was viewed with much disfavour by the Church, and under Charlemagne an ecclesiastical council passed a decree which seems to have been effective in putting an end to this burial with accoutrements (Boulanger, op. cit., 41). Still Hincmar, Archbishop of Reims, in 857, found it necessary to issue a whole series of instructions De sepulcris non violandis. In all these early Christian cemeteries the orientation of the tombs was carefully attended to. Each corpse was laid with its feet to the east, though it has been remarked as a curious fact that pagan Frankish sepultures also commonly exhibit the same peculiarity (Boulanger, op. cit., 32). With regard to England it may probably be assumed, though clear evidence is lacking, that separate Christian graveyards were formed almost from the beginning in all those places where the faithful were numerous. It would seem that even before a church was built it was the practice of our Saxon forefathers to set up a cross, which served as a rendezvous for the Christians of the district. An instance may be quoted from the almost contemporary life of St. Willibald, born in 699, who when he was three years old was consecrated to God at the foot of such a cross in a remote part of Hampshire. The suggestion has been recently made with much plausibility that round such a cross the Christian converts loved to be laid to rest, and that these primitive crosses marked a site upon which church and churchyard were established at a later time (see Baldwin Brown, Arts in Early England, I, 254-266). Certain it is that the churchyard cross was always a conspicuous feature of the consecrated enclosure and that the churchyard usually afforded sanctuary as secure as that of the church itself for those who were fleeing from justice or private vengeance. Numerous ecclesiastical ordinances enjoin that the churchyard was to be surrounded by a wall or other boundary sufficient to keep out straying cattle and to secure the area from profanation. As a specimen we may take the following ordinance of the Bishop of Lincoln in 1229: "Regarding the arrangements of a church-yard [ coemeterium] let the ground be properly enclosed with a wall or a ditch, and let no part of it be taken up with buildings of any kind, unless during time of war. There should be a good and well-built cross erected in the church-yard to which the procession is made on Palm Sunday, unless custom prescribes that the procession should be made elsewhere" (Wilkins, Concilia, I, 623). This churchyard procession on Palm Sunday, in which, as early as the time of Lanfranc, the Blessed Sacrament was often carried in a portable shrine, as well as all the relics of the church, was a very imposing ceremony. Many descriptions of it have been left us, and traces still survive even in Protestant countries, where, as for example, in Wales, the country people to this day often visit the churchyard on Palm Sunday and scatter flowers on the graves (see Thurston, Lent and Holy Week, 213-230; The Month, April, 1896, 378). Less admirable was the use of the churchyard in medieval times as a sort of recreation ground or market-place. Numerous decrees were directed against abuses, but it was difficult to draw a clear line between what was legitimate and permissible and what was distinctly a profanation of the sacred precincts. The very fact that people congregated in the churchyard on the way to and from service on Sundays and holidays made it a convenient place of assembly. Down to modern times the day of the village feast or fair is often found to coincide with the sometimes forgotten original dedication of the church or with the festival of its patron saint. Moreover, there was a tendency to regard the church and its precincts as a sort of neutral ground or place of security for valuables. Hence ancient contracts often include a clause that such and such a sum of money is to be paid on a certain date in a particular church or churchyard. In any case it cannot be denied that the erection of stalls and booths for fairs in the churchyard persisted in spite of all prohibitions (Baldwin Brown, op. cit., 274-364).

A curious feature found in many churchyards from the twelfth to the fourteenth century, especially in France, is the so-called lanterne des morts, a stone erection sometimes twenty or thirty feet high, surmounted by a lantern and presenting a general resemblance to a small lighthouse. The lantern seems to have been lighted only on certain feasts or vigils and in particular on All Souls' Day. An altar is commonly found at the foot of the column. Various theories have been suggested to explain these remarkable objects, but no one of them can be considered satisfactory. Besides the churchyard cross and the lanterne des morts, cemeteries, especially when not attached to the parish church, frequently contained a mortuary chapel similar to those with which modern usage is still familiar. Here, no doubt, Mass was offered for the souls of the departed, and the dead were on occasion deposited, when for some reason the service at the graveside was delayed. These mortuary chapels seem usually to have been dedicated to St. Michael, probably from the function attributed to him of escorting the dead to and from the judgment seat (cf. the Offertory in the requiem Mass: "Signifer sanctus Michael repraesentet eas in lucem sanctam". In other graveyards a "lych-gate", i.e., a roofed gateway to the cemetery, served to afford shelter to the coffin and mourners when waiting to proceed to the graveside. Provision was also generally made, and some such arrangement is recommended by the decrees of more modern times, for the bestowal of bones which might be dug up in making new graves. Most churchyards possessed something in the nature of a charnel house or ossuary, and in many parts of the world, where for various reasons space had to be economized, a principle was recognized that after a certain term of years graves might be emptied to make room for new occupants, the remains thus removed being consigned to the charnel house. This was and is particularly the case in regions where, owing to the unsuitable nature of the soil, e.g. in the City of Mexico, the dead are built into oven-like chambers of solid masonry. When these chambers are cleared at intervals to receive another occupant, it is not unusual to find here and there a body which instead of falling to dust has become naturally desiccated or mummified. Such gruesome specimens have not unfrequently been sold and without a particle of foundation exhibited as "walled up nuns" or "victims of the Inquisition". (See The Month, Jan., 1894, pp. 14, 323, 574, and April, 1904, p. 334.) Among the Capuchns and some other orders in Southern Europe charnel houses are often constructed with the most fantastic elaboration, the bodies, dried to the consistency of parchment, being arranged around the chamber in niches and robed in their religious habits. Moreover, even here, secular persons, following medieval precedents, have been admitted in some cases to share the sepulture of the religious. The curious practices observed in many ancient cemeteries, for instance in the arcade known as the Charnier of the Cemetery of the Innocents at Paris, would afford much matter for discussion, but lie outside the limits of the present article. A very favourite decoration for such erections or for cemetery walls was the Dance of Death, otherwise known as the Danse Macabre. The frescoes of this character, however, seem none of them to be older than the fourteenth century.

Monastic Cemeteries

From an early date every religious house possessed a cemetery of its own. An interesting discovery of such a graveyard belonging to Anglo-Saxon nuns of the eighth century was made a few years ago near Hull. It is possible that these monastic cemeteries in early missionary days often formed the nucleus of a churchyard intended for all the faithful. In any case it became the ardent desire of many pious persons to be laid to rest among the religious of monastic institutions, and they often sought to purchase the privilege by benefactions of various kinds. Formal compacts dealing with this matter are to be met with among early charters, e.g. those of Anglo-Saxon England; and the question, as will easily be understood, led to much friction at a somewhat later date, between the religious orders and secular clergy, resulting in a great deal of ecclesiastical legislation upon the right of choosing a sepulture and the claims of the parish priest.

Consecration of Cemeteries

The practice of blessing the grave or the vault in which any Christian was laid to rest is extremely ancient, and it may be traced back to the time of St. Gregory of Tours (De Gloria Conf., c. civ). In many early pontificals, e.g. those of Egbert of York and Robert of Jumièges, a special service is provided with the title Consecratio Cymiterii, and this, with certain developments and additions, is still prescribed for the blessing of cemeteries at the present day. According to this rite five wooden crosses are planted in the cemetery, one in the centre and the others at the four points of the compass. After the chanting of the Litany of the Saints with special invocations, holy water is blessed and the bishop makes the circuit of the enclosure sprinkling it everywhere with this water. Then he comes to each of the crosses in turn and recites before it a prayer of some length, these five prayers being identical with those appointed for the same purpose in the Anglo-Saxon pontificals of the eighth century. Candles are also lighted before the crosses and placed upon them, and this feature, though not so ancient as the prayers, is also of venerable antiquity. On each of these occasions incense is used, and finally a consecratory preface is sung at the central cross, after which the procession returns to the church., where solemn Mass is celebrated. A cemetery which has thus been consecrated may be profaned, and it is in a measure regarded as losing its sacred character when any deed of blood or certain other outrages are committed within its enclosure. For example, as the ground has been blessed for those who are in communion with the Church, the forcible intrusion of someone who had died under the Church's ban is looked upon as a violation which unfits it for the purpose for which it was designed. Innocent III decided that in such a case, if for any reason it was impossible to exhume the remains and cast them out of the enclosure, the cemetery must be reconciled by a form of service specially provided for the purpose. In a celebrated instance, known as the Guibord Case, which occurred in Montreal, Canada, in 1875, the bishop, seeing the civil law uphold the intrusion, laid the portion of the cemetery so profaned under an interdict. Finally we may note the quasi-consecraton imparted to the famous Campo Santo of Pisa, as well as to one or two other Italian cemeteries, by the alleged transference thither of soil from Mount Calvary.

For other points not touched upon here, see the article BURIAL.

For general works see Permandeder, in Kirchenlex., VII, 718; Ruland, Gesch. der kirchlichen Leichenfeier (Ratisbon, 1901); Lek, Das kirchliche Begrabnissrecht (Ratisbon, 1904); Bertrand, De la législation de la Sepulture (Paris, 1904); Archiv für k. Kirchenrecht, I, 25 sq., LXXVIII, 171 sq; Moulart, De Sepultura et Coemeteriis (Louvain, 1862), and in L'Eglise et L'Etat (Louvain, 1896), 512-29.
For the Catacombs and early Middle Ages see Leclercq, Manuel d'archéol. chrét. (Paris, 1907), I, 217-234, a very satisfactory discussion of the subject; Müller in Realencyklopadie f. prot. Théol., X, 814 sqq., also an extraordinarily full and elaborate article; Lanciani, Christian and Pagan Rome (London, 1892), 305-361; Brown, From Schola to Cathedral (London, 1893); Marucchi, Elements d'archéol. (Rome, 1901), especially I; Lindenschmidt, Handbuch der deutschen Alterthumskunde, I, 64-146; Cochet, La Normandie Souterraine (Paris, 1860); Brown, The Arts in Early England (London, 1902), I, 253-270; Kraus, Real-Encyklopadie, I, 307 sq.; Boulanger, Le mobilier funéraire gallo-romain et franc (Paris, 1905); Murcier, La Sépulture Chret. (Paris, 1855).
On the Canon Law see Wernz, Jus Decretalium (Rome, 1902), III, 464-71; Zema, Quoestiones Canonico-Liturgicoe (Rome, 1903); Cavagnis, Institut. Jur. Pub. Eccles. (Rome, 1889), II, 289 sq; Ferraris, Bibliotheca, s. v. Sepultura.
For the Liturgy see Martene, De Antiquis Ecclesioe Ritubus (Bassano, 1788); Cabrol, Le livre de la priere antique (Paris, 1900), 326-32.
For the ecclesiastical discipline of the Province of Quebec see Gignac, Compend. Jur. eccl., etc. (Quebec, 1903), De rebus, etc., Nos. 773, 774, 778, 783; also Discipline Eccl. du Diocese de Quebec, s.v. Sepulture; and for the Civil Law, Weir, The Civil Code of Lower Canada (Montreal, 1888).
For the cemetery legislation of the Province of Quebec, see Mignault, Le Droit Paroissial, etc. (Montreal, 1893), in Index s.v. Cimetieres; Dorais, Code Civil de la Province de Quebec (2nd ed., Montreal, 1905), nos. 53 b. and 66 sqq.; Tyler, American Eccl. Law, Ch. 71-85; American and English Encycl. of Law, V, 781-98; Desmond, The Church and the Law (Chicago, 1898), c. xvi.

J.J. CURRAN