Terminology
In practice, legal jurisdictions exercise their right to determine who is recognized as being a lawyer. As a result, the meaning of the term "lawyer" may vary from place to place.
- In Australia the word "lawyer" is used to refer to both barristers and solicitors (whether in private practice or practising as corporate in-house counsel).
- In Canada, the word "lawyer" only refers to individuals who have been called to the bar or, in Quebec, have qualified as civil law notaries. Common law lawyers in Canada are formally and properly called "barristers and solicitors", but should not be referred to as "attorneys", since that term has a different meaning in Canadian usage. However, in Quebec, civil law advocates (or avocats in French) often call themselves "attorney" and sometimes "barrister and solicitor" in English.
- In England and Wales, "lawyer" is used to refer to practitioners such as barristers, solicitors, and licensed conveyancers, as well as people who are involved with the law but do not practise it on behalf of individual clients, such as judges, court clerks, and drafters of legislation.
- In India, the term "lawyer" is often colloquially used, but the official term is "advocate" as prescribed under the Advocates Act, 1961.
- In Scotland, the word "lawyer" refers to a more specific group of legally trained people. It specifically includes advocates and solicitors. In a generic sense, it may also include judges and law-trained support staff.
- In the United States, the term generally refers to attorneys who may practice law; it is never used to refer to patent agents or paralegals.
- Other nations tend to have comparable terms for the analogous concept.
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