Civil Law Jurisdictions
The role undertaken by notaries in civil law countries is much greater than in common law countries. Notaries in the former countries frequently undertake work done in common law countries by the Titles Office and other Government agencies. The qualifications imposed by some countries is much greater. In France and Greece, for example, a practitioner must choose to be either a solicitor or a notary.
This should be contrasted with the Spanish American notario who may be similar to an attorney at law or lawyer. In Mexico, notaries are specialized lawyers acting as public officers with jurisdiction over voluntary, non-contentious private law such as real estate transactions, incorporation of corporations and legal entities, wills and successions among other acts. They are appointed after a competition between various candidates for the same position. A French notaire, a German Notar and an Italian Notaio register wills and other documents, and authenticates transactions of real estate.
In the few United States jurisdictions where trained notaries are allowed (such as Puerto Rico), the practice of these jurists is limited to non-judicial legal advice, property conveyencing and legal drafting.
Read more about this topic: Notary Public
Famous quotes containing the words civil and/or law:
“At Hayes’ General Store, west of the cemetery, hangs an old army rifle, used by a discouraged Civil War veteran to end his earthly troubles. The grocer took the rifle as payment ‘on account.’”
—Administration for the State of Con, U.S. public relief program (1935-1943)
“The Reverend Samuel Peters ... exaggerated the Blue Laws, but they did include “Capital Lawes” providing a death penalty for any child over sixteen who was found guilty of cursing or striking his natural parents; a death penalty for an incorrigible son; a law forbidding smoking except in a room in a private house; another law declaring smoking illegal except on a journey five miles away from home,...”
—Administration for the State of Con, U.S. public relief program (1935-1943)