Since the establishment of Baháʼu'lláh's Covenant, a few individuals have rejected the appointment and authority of the head of the Baháʼí Faith, and sought to promote their own leadership; all have failed.[184] Some describe those involved in such attempts (known as covenant-breakers by Baháʼís) as "sects" of the Baháʼí Faith. However, a distinguished legal scholar explains they cannot be correctly described as Bahá’í "sects" or "schisms" since none have ever successfully established a genuine "rival community". Udo Schaefer points out, "One cannot speak of a 'schism' when a division is of merely ephemeral significance since it did not result in the formation of a rival community. (Just as one does not speak of an ecclesiastical schism every time an individual member of a church performs an action constituting the ecclesiastical offence of 'schism'.)"[185] For further consideration of these and related points, see Heller (2022, pp. 414–421). Heller, Wendy M. (2022). "Ch. 34: The Covenant and Covenant-Breaking". In Stockman, Robert H. (ed.). The World of the Bahá'í Faith. Oxfordshire, UK: Routledge. pp. 409–425. ISBN978-1-138-36772-2.