Prior to the establishment of Glasnevin Cemetery, Irish Catholics had no cemeteries of their own in which to bury their dead and, as the repressive Penal Laws of the eighteenth century placed heavy restrictions on the public performance of Catholic services, it had become normal practice for Catholics to conduct a limited version of their own funeral services in Protestant churchyards or graveyards. This situation continued until an incident at a funeral held at St. Kevin's Churchyard in 1823 provoked public outcry when a Protestant sexton reprimanded a Catholic priest for proceeding to perform a limited version of a funeral mass.