This study is an examination of Li Tongxuan’s understanding of Queen Māyā 摩耶夫人. Li Tongxuan has a unique understanding of good teachers in the Gaṇḍavyūha-sūtra. He refers to Guanyin 観音 Bodhisattva as “the head of great compassion” 大悲之首 and to Queen Māyā as “the head of great kindness” 大慈之首. This study focuses on his understanding of Queen Māyā. By understanding this point, we will be able to understand the characteristics of Li Tongxuan’s Huayan thought. In previous studies, Li Tongxuan’s understanding of Queen Māyā has not been discussed. Through a comparative study of the data of Zhiyan 智儼, Fazang 法蔵, and Li Tongxuan, we clarify that for Li Tongxuan, Queen Māyā is the perfect practitioner of the practice of Samantabhadra （Puxian 普賢）, understood as the head of great compassion, and that Queen Māyā has the same status as Guanyin Bodhisattva.
