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I've got one customer who has hundreds in her lawn, it looks very pretty for a few weeks, she's dug some out but they always come back.
I see it more with cowslips but they are not too fussy where they self seed.
Cow slips are nice in a large informal lawn, They work well in orchard areas and mixed in with some tares etc can make a nice rough area if the garden has enough space to justify it.
As Stuart says, it's a result of self-seeding. The plants produce thousands of seeds which disperse when they're ripe.
Thanks for all the replies. One of my sites they were planted in the beds, have moved to the lawn and now only come up in the lawns but never in the beds. Neither me nor my client can understand why they don't come up in the beds as well. :-s