Well it wouldn't be at all uncommon for Gallows to return more cards than the player has hand space. Assuming the player has 5 available hand space, and there have been 10 creatures destroyed, Gallows would return the first 5 destroyed right? If on the next turn, the player has another 5 available hand space and another Gallows is destroyed, does it still return the first 5 creatrues that died that game or the next 5?