Let crests be shown as crests, properly set upon practicable helms, and with competent mantlings treated with all the freedom that they are capable of.
It may here be noted that it has not been customary, nor is it logically correct, for ladies and other non-combatant persons, such as the ministers of the Church, to use crests; arms they have ever been allowed to bear. Examples, however, of the breach of the rule as to crests even by bishops are afforded by several of their privy seals. Thus Henry le Despenser bishop of Norwich (1370-1406) has his differenced shield of arms surmounted by a mantled helm upon which a mitre, with a griffin's head and wings issuing therefrom, is placed as a crest (fig. [84]); and Alexander Nevill archbishop of York (1374) shows his shield hanging below a crowned helm surmounted by the bull's head crest of his house and supported by two griffins.
Fig. 84. Privy seal of Henry le Despenser bishop of Norwich, 1370-1406.
William Courtenay, as archbishop of Canterbury (1381-96), similarly displays a shield of his arms, ensigned by a helm surmounted by a cap of estate with a dolphin on top. A helm crested with a lovely bunch of columbines is also carved with his arms above the tomb of James Goldwell bishop of Norwich (ob. 1498-9) in his cathedral church.
Robert Nevill on his privy seal as bishop of Durham (1438-57) surmounts his shield with a beautiful labelled mitre, from which issues a bull's head with a scroll lettered en grace affie.
Many of the bishops of Durham, on their great seals in chancery, in virtue of their secular palatinate jurisdiction, are represented as riding in complete armour with helms on their heads. The first to be so represented was Thomas Hatfield (1345), who wears a large crowned helm surmounted by a mitre, from which issues a bush of feathers. John Fordham (1381) also surmounts his crowned helm with a mitre, on which is perched a bird. Walter Skirlaw (1388) and Thomas Langley (1406) set within the crowns crests without mitres; in one case the bust of an angel, in the other a bush of feathers. Robert Nevill (1438) surmounts his crowned helm with a mitre, from which issues a bull's head, as on his privy seal above noted. Cuthbert Tunstall (1530) has a mitre alone upon his helm.
The usual practice in displaying a bishop's arms has been, for a long time, to ensign them simply with his own official headgear in the shape of a mitre, and the same custom prevailed with regard to the arms of mitred abbots and priors. Robert Nevill's privy seal is an early example.
Cardinals ensigned their shields with the tasselled hat of their order, as may be seen on the seal-of-arms of Henry Beaufort bishop of Winchester (1405), and in a carving of his arms in Southwark cathedral church. A cardinal's hat is displayed, with his rebus and sundry royal badges, on the arch about the cenotaph of John Morton archbishop of Canterbury and cardinal in the undercroft of his cathedral church.