Head of the Church time of the English Reformation, Henry VIII took for himself the title of Supreme Head of the Church of England, which was theologically problematic; his daughter Elizabeth I changed this to Supreme Governor of the Church of England. The Presbyterian system, codified in the Westminster Standards, outlines teaching elders (Ministers) and ruling elders, and courts presided over by Moderators sitting "primus inter pares", and gives practical effect to the concept of the equal status of all believers behind the one and only head of the church - Jesus Christ. This gives rise to the famous (or infamous) section of the
Governor General of Canada exercising the Crown's powers with its permission; a fact the Constitution Act, 1867 left unchanged. Among other duties, the monarch retains the sole right to appoint the governor general. It is also stipulated that the governor general may appoint deputies—usually Supreme Court justices and the Secretary to the Governor General—who can perform some of the viceroy's constitutional duties in his or her stead, and the Chief Justice of the Supreme Court (or a puisne justice in the chief justice's absence) will act as the Administrator of the Government upon the death or removal, as well as the incapacitation, or absence