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A "shallow grave" is informally used to indicate any kind of illicit grave dug by an individual. It is especially applied to graves that are just a few inches deep, although might sometimes be used for a grave of a couple feet, even where that might fulfill local burial requirements.
There is a popular conception that a grave should be at least six feet deep, a perception which seems to stem from London's Great Plague in 1665. During the Great Plague, London's mayor was said to have required all burials to be at least six feet deep to prevent any chance of the spread of disease. By this standard, many legal burials might be called "shallow." For example, California requires that a grave allow eighteen inches of dirt above the coffin.
Given the use of concrete liners, heavy coffins and chemical embalming, there is very little health requirement for a deep burial.
The "shallow grave" is more an indication of a hasty, furtive burial than the actual depth of the grave.
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