Could well be correct. On this page:
http://www.genuki.org.uk/big/eng/LIN/nonconformist.html
is this:
"To be buried "under Burial Laws Amendment Act 1880" means that the person buried was a non-conformist; the burial service was performed by a Non-Conformist minister, but in a Church of England church as the burial was going to take place in the churchyard (consecrated ground). Many non-conformist church members had to be buried in unconsecrated ground, as their religion was not recognised as such by the established church."

Mike