between a lioness and a pard," and like a mule incapable of reproducing, may be an appropriate charge for a person born of adultery or barred from reproducing (such as an abbot). As a general rule, English heralds tend to identify lions as rampant (upright, in profile facing dexter), and leopards as passant guardant (walking, head turned to full face), but the heraldic distinction between lions and leopards is often ambiguous and in some cases may be controversial (as in the case of the royal arms of England, discussed below). Part of the confusion arises from international differences in translation or in the defining characteristics of each, particularly in charges that show some characteristics of each. English herald Arthur Charles Fox-Davies asserted in 1909 that the leopard, denoting a lion passant guardant, was a term of French origin that had "long since become obsolete in English armory. In French blazon, however, the old distinction is still observed." Fox-Davies continued, "[French heralds] term our lion passant a léopard-lionné and our lion rampant guardant is their lion-léopardé." Dutch heraldist Johannes Rietstap, however, defined a Léopard lionné as a lion rampant guardant (i.e., upright like a lion with its head turned to full face like a leopard) and a Lion léopardé as a lion passant (i.e., walking like a leopard with its head facing dexter like a lion). German-American heraldist Carl-Alexander von Volborth agrees with Rietstap's translations, in contrast to those of Fox-Davies as stated above. As if to clarify the situation, English heraldist Hugh Clark wrote in his Introduction to Heraldry (1829): English heraldist Charles Boutell wrote in 1890 that the lions of England were generally termed leopards until the end of the 14th century, including in the roll of arms of Henry III of England, and in a statute of Edward I of England, dating to 1300, which made reference to "signée de une teste de leopart—marked with the King's lion." In English Heraldry (1867), Boutell explained: In Heraldry: Sources, Symbols and Meaning (1976), German heraldist Ottfried Neubecker explained: According to Neubecker, what in Old French is termed a léopard is always guardant (head turned toward the observer), thus the modern English heraldic terms "lion passant guardant", "lion passant", and "lion rampant guardant" correlate to the Old French terms léopard, lion léopardé, and léopard lionné'', respectively. Gallery Lions as heraldic charge Lions rampant A small group of examples is depicted listed