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.
[Illustration: 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.