John Suta, a solicitor representing family of the infamous bushranger, said he would recommend his clients pursue a pardon “on the grounds that he didn’t get a fair trial”.

The North East outlaw was executed in November 1880 for the murder of a police officer.

Kelly’s great-grand-niece, Joanne Griffiths, yesterday said it wasn’t a day to be talking about a potential new legal battle but she confirmed the family would continue fighting for “equality and fairness” for their most famous relative.

About 200 people attended the private family burial at Greta cemetery yesterday morning.

Ms Griffiths said the day came as a relief for the descendents of Kelly’s siblings who, after 132 years, were able to fulfil his dying wish to be buried in consecrated ground alongside family.

“It’s been a massive effort for all involved in this process, it’s taken up a large proportion of our lives but it’s a fantastic achievement,” Ms Griffiths said.

Mr Suta was among a handful of members of the public at the cemetery for the historic occasion.

He said during the 18 months he represented the family he had learnt a lot about the Kelly case and was confident he could get Kelly’s murder conviction quashed in an “absolutely unprecedented” Supreme Court appeal.

“Self-defence was never put to the judge on the basis that judge Redmond Barry never let it go to the jury ... and on the basis that Ned’s barrister Henry Bindon was the most inexperienced barrister going around at the time,” Mr Suta said.

“My view is that we would get it overturned because none of the witnesses are alive.”

Other notable attendees were members of the Tramps Motorcycle Club, volunteering as security.

The bushranger’s coffin was enclosed in cement in a grave close to where the bodies of his mother Ellen and brother Jim lie.

Kelly’s skeleton was interred with just a small fragment of his skull and Ms Griffiths said she thought it unlikely the rest would ever turn up.

“He had a price on his head, even in death,” she said.