Bodies are being illegally shifted by councils to cover up burial errors, a Church of England court has heard.
A judge criticised councils who secretly correct their mistakes by "sliding" bodies across in the ground without lifting them out.
This is illegal as disturbing bodies buried in consecrated ground must be formally permitted by a church court.
Alexander McGregor, Chancellor of the Diocese of Oxford, said councils who were found to be doing this would be reported to the police.
He was commenting on a case where a man had been accidentally buried in the wrong plot in Fairmile Cemetery, Henley-on-Thames.
In 2015 Victor Miller was buried in a plot adjacent to the grave of Constandinos Leventis, who had died in 2012.
But unknown to his family, Mr Miller's plot had been reserved for Mr Leventis' son Alexis Leventis, and the error meant that his father's dying wish for his family to be buried together could not be fulfilled.
When Mr Leventis' daughter Chrysoulla Jackson met the town clerk to discuss the situation, he told her that Mr Miller's body could be "informally" moved sideways in the ground - a practice known as "sliding", the court heard.
In his judgment Mr McGregor said: "Such unlawful action by a burial authority is to be deprecated.
"Should cases of this happening become known to the court, I shall instruct the Registrar to report the matter both to the Archdeacon with a view to appropriate steps being taken to enforce ecclesiastical law, and to the police with a view to their investigating whether a criminal offence has been committed."
That clerk has now retired, but new Henley town clerk Janet Wheeler said: "I have heard suggestions that it has happened, but I have no first-hand knowledge. I've certainly never looked at doing it myself, here or in my other previous role," she said.
Mr McGregor said he was "concerned" to hear Mrs Wheeler's evidence "that the practice referred to as 'sliding' was one she was aware of being used in other cemeteries to correct mistakes".
In this case "sliding" did not happen, and Mr Leventis' family applied to the court for Mr Miller's body to be moved in the proper way.
However, their request was refused.
In a press release Henley Town Council said it had taken "full responsibility for the error".
Nicholas Leviseur, who acted for the council, said: “Whilst it was not possible to turn back the clock, Henley Town Council has taken immediate steps to ensure better management and new processes at the cemetery.
"The town clerk is currently conducting a robust and comprehensive review of all the records and registers for the last twenty years.
"She has also moved swiftly to ensure new processes to mitigate any future errors.“