In Rees v Hughes [1946] KB 517 Scott LJ said, at 523-524: “There is an obligation at common law, in the nature of a public duty, which rests on certain persons in whose possession a dead body may be — a husband being one — to bury it … [W]here a man dies possessed of personal property, the duty of burying his body falls primarily on his personal representatives … and this duty entitles the personal representative to absolute priority of reimbursement out of the estate.”