auncient lawes, customes, rules, privileges and orders of armes." [Illustration: FIG. 28.--Taken from the tomb of Geoffrey Plantagenet, Count of Anjou.] 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 {62} alone considered. So that in the case of a grant to a bishop the crest is granted for his descendants in a separate clause, being depicted by itself in the body of the patent apart from the emblazonment "in the margin hereof," which in an ordinary patent is an emblazonment of the whole achievement. A similar method is usually adopted in cases in which the actual patentee is a woman, and where, by the limitations attached to the patent being extended beyond herself, males are brought in who will bear the arms granted to the patentee as their pronominal arms. In these cases the arms of the patentee are depicted upon a lozenge at the head of the patent, the crest being depicted separately elsewhere.