In 1888 Lloyd George won on appeal, to the Divisional Court of Queens Bench, the Llanfrothen Burial case which established the right of Nonconformists to be buried according to their own denominational rites in parish burial grounds, a right given by the Burial Act 1880 that had hitherto been ignored by the Anglican clergy. The prime motive of the Burial Laws Amendment Act 1880, was to remove a grievance felt by non-conformists, especially in rural districts. The Act granted facilities to non-conformist ministers to carry out burials in the C of E churchyard, not using the rites of the Church of England, but those of the particular denomination involved.
An 1823 statute legalized the burial of suicides in unconsecrated ground, but religious services were not permitted until 1882. In the year 1823 it was enacted that the body of a suicide should be buried privately between the hours of nine and twelve at night, with no religious ceremony. In 1882 this law was altered by the Internments (felo de se) Act, 1882. where every penalty was removed except that internment could not be solemnised by a burial service, and the body could now be committed to the earth at any time, and with such rites or prayers as those in charge of the funeral thought fit or may be able to procure.