Country-wise Glossary of Legal Professional Terms

 

🌍 Country-wise Glossary of Legal Professional Terms

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🇬🇧 United Kingdom (England & Wales)

Term	Meaning
Barrister	Specialist courtroom advocate; appears in higher courts; often instructed by solicitors.
Solicitor	Legal advisor handling client work, contracts, transactions; limited court rights unless accredited.
Solicitor-Advocate	A solicitor with extended rights to appear in higher courts, like a barrister.
Chartered Legal Executive	Qualified legal professional specializing in one area; regulated by CILEx.

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🇮🇳 India

Term	Meaning
Lawyer	General term for anyone with a law degree (LL.B.).
Advocate	Registered legal practitioner under the Advocates Act, 1961; authorized to appear in Indian courts.
Senior Advocate	Senior lawyer designated by the court, similar to a Queen’s Counsel (QC) in the UK.
Vakil/Pleader	Historical terms for legal practitioners before the Advocates Act unified the profession.

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🇺🇸 United States

Term	Meaning
Attorney / Attorney-at-Law	Licensed legal practitioner authorized to advise clients and represent them in court.
Lawyer	General term; same as attorney.
Counsel / Of Counsel	Senior lawyer or advisor associated with a law firm but not a partner or associate.
District Attorney (DA)	Public prosecutor representing the state in criminal cases.
Public Defender	Government lawyer representing defendants who cannot afford private counsel.

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🇨🇦 Canada

Term	Meaning
Lawyer	Qualified legal professional; combines roles of solicitor and barrister (no formal split).
Attorney	Less commonly used (mainly in formal/US-influenced contexts).
Crown Counsel	Government prosecutor.

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🇦🇺 Australia

Term	Meaning
Solicitor	Legal advisor handling client matters, transactions, and some advocacy.
Barrister	Specialist advocate, usually briefed by solicitors, with rights of audience in all courts.
Senior Counsel (SC)	Senior barrister (formerly Queen’s Counsel, QC) recognized for expertise and leadership.

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🇫🇷 France

Term	Meaning
Avocat	Licensed legal practitioner combining advisory and courtroom roles.
Notaire	Public official handling authenticated acts like wills, property transfers; no courtroom role.
Huissier de justice	Court officer handling service of documents, enforcement of judgments.

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🇩🇪 Germany

Term	Meaning
Rechtsanwalt	Qualified lawyer, authorized to advise and represent clients.
Notar	Specialized lawyer authorized to authenticate legal documents and transactions.
Staatsanwalt	Public prosecutor.
Richter	Judge.

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🇪🇸 Spain

Term	Meaning
Abogado	Lawyer authorized to advise and represent clients.
Procurador	Licensed professional handling procedural matters and filings in court; works alongside abogados.
Notario	Public official authenticating legal documents.

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🇳🇬 Nigeria

Term	Meaning
Legal Practitioner	General term; no split between barrister and solicitor (merged profession).
Senior Advocate of Nigeria (SAN)	Senior lawyer recognized for excellence, similar to UK’s QC/SC.

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🇿🇦 South Africa

Term	Meaning
Attorney	Handles client work, legal advice, and some litigation.
Advocate	Specialist courtroom lawyer, usually briefed by attorneys; similar to barristers.
Senior Counsel (SC)	Senior advocate recognized for expertise.

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🌍 International & General

Term	Meaning
Counsel	Can refer to a lawyer or legal advisor; often used for senior advisors or court advocates.
In-house Counsel	Lawyer employed directly by a corporation or organization.
Public Prosecutor	Government lawyer prosecuting criminal cases.
Legal Consultant	Lawyer or expert providing specialized legal advice (may not hold local practice license).

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📌 Key Takeaways

✅ Common law countries (UK, India, Australia, South Africa) → often have distinct advocate/barrister vs solicitor roles.
✅ Civil law countries (France, Germany, Spain) → combined roles under a general “lawyer” title like avocat or abogado.
✅ United States & Canada → unified system: lawyers/attorneys handle both advice and court work.