The gain of circularly polarised (CP) array antennas realised by proper phasing of sequentially rotated linearly polarised (LP) elements is compared to that of arrays using CP elements and demonstrated by calculations for microstrip patch elements. When element spacing is large and array size is small, the advantages of LP elements are offset by the significant reduction in gain due to high cross polarised lobes in the diagonal planes. For large arrays of closely spaced elements, this gain loss reduces to a negligible amount. However, for spacings above a critical value of about 0.7 wavelengths, unacceptably high gain losses will be incurred.