My read, which is indirect because it is only news reports, is that he can obey the court order and avoid communicating with the Schindlers by having no plan. He is required to report his plans (and I assume also that the court order expects his actions in the burial and services will comport with his plans). As long as he plans nothing, and just leaves her remains "wherever," he has not violated the court order.
We've already had one poster on this thread state that he/she would like to dig the remains up.
There have been memorial services for Terri. She's gone. Arguing about ashes just a cover story for arguing about the other issues.
I tend to agree with your assesment. So in effect, if he's planned no service, he's not violating the law as the Schindlers report.