The California Corporations Code allows for the incorporation of a corporation sole by the bishop, chief priest, presiding elder, or other presiding officer of any religious denomination, society, or church, for the purpose of administering and managing the affairs, property, and temporalities thereof.  Cal. Corp. Code § 10002.   William Blackstone explained the purpose of a corporation sole as follows:

Corporations sole consist of one person only and his successors, in some particular station, who are incorporated by law, in order to give them some legal capacities and advantages, particularly that of perpetuity, which in their natural persons they could not have had.

1 W. BLACKSTONE, COMMENTARIES, Ch. 18.  Historically, the King of England was considered a corporation sole as were bishops, parsons and vicars.   Lacking a monarch, California limits corporations sole to the religious.

I was surprised to come across a California statute that on its face grants access to the books of a corporation sole to any Superior Court judge: 

Any judge of the superior court in the county in which a corporation sole has its principal office shall at all times have access to the books of the corporation.

Cal. Corp. Code § 10009.  Notably, this statute imposes no conditions or limits upon a judge's access.  Nor does the statute require that the judge have any particular purpose  of accessing the books of a corporation sole.  These deficiencies apparently haven't proved to be much of a problem.  The statute has been on the books for three quarters of a century without being cited in any reported decision.  While some religious organizations are incorporated under California's corporation sole laws (e.g., the Roman Catholic Bishop of Orange) many are incorporated under California's separate Nonprofit Religious Corporation Law.  

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