for we find in the Royal Warrants of Queen Elizabeth commanding the Visitations that the King of Arms to whom the warrant was addressed was to "correcte, cumptrolle and refourme all mann' of armes, crests, cognizaunces and devices unlawfull or unlawfully usurped, borne or taken by any p'son or p'sons within the same p'vince contary to the due order of the laws of armes, and the same to rev'se, put downe or otherwise deface at his discrecon as well in coote armors, helmes, standerd, pennons and hatchmets of tents and pavilions, as also in plate jewells, pap', parchement, wyndowes, gravestones and monuments, or elsewhere wheresoev' they be sett or placed, whether they be in shelde, schoocheon, lozenge, square, rundell or otherwise howsoev' contarie to the autentiq' and auncient lawes, customes, rules, privileges and orders of armes."
The Act 32 & 33 Victoria, section 19, defines (for the purpose of the taxation it enforced) armorial bearings to mean and include "any armorial bearing, crest, or ensign, by whatever name the same shall be called, and whether such armorial bearing, crest, or ensign shall be registered in the College of Arms or not."
The shape of the shield throughout the rest of Europe has also varied between wide extremes, and at no time has any one particular shape been assigned to or peculiar to any country, rank, or condition, save possibly with one exception, namely, that the use of the cartouche or oval seems to have been very nearly universal with ecclesiastics in France, Spain, and Italy, though never reserved exclusively for their use. Probably this was an attempt on the part of the Church to get away from the military character of the shield. It is in keeping with the rule by which, even at the present day, a bishop or a cardinal bears neither helmet nor crest, using in place thereof his ecclesiastical mitre or tasselled hat, and by which the clergy, both abroad and in this country, seldom made use of a crest in depicting their arms. A clergyman in this country, however, has never been denied the right of using a crest (if he possesses one and chooses to display it) until he reaches episcopal rank. A grant of arms to a clergyman at the present day depicts his achievement with helmet, mantling, and crest in identical form with those adopted for any one else. But the laws of armory, official and amateur, have always denied the right to make use of a crest to bishop, archbishop, and cardinal.
At the present day, if a grant of arms is made to a bishop of the Established Church, the emblazonment at the head of his patent consists of shield and mitre only. The laws of the Church of England, however, require no vow of celibacy from its ecclesiastics, and consequently the descendants of a bishop would be placed in the position of having no crest to display if the bishop and his requirements were
