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In Australia, the word "lawyer" is used to refer to both barristers and solicitors (whether in private practice or practicing 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, being a person appointed under a power of attorney. However, in Quebec, civil law advocates (or avocats in French) often call themselves "attorney" and sometimes "barrister and solicitor" in English, and all lawyers in Quebec, or lawyers in the rest of Canada when practicing in French, are addressed with the honorific title, "Me." or "Maître".
In England and Wales, "lawyer" is used to refer to persons who provide reserved and unreserved legal activities and includes practitioners such as barristers, attorneys, solicitors, registered foreign lawyers, patent attorneys, trade mark attorneys, licensed conveyancers, public notaries, commissioners for oaths, immigration advisers and claims management services. The Legal Services Act 2007 defines the "legal activities" that may only be performed by a person who is entitled to do so pursuant to the Act. 'Lawyer' is not a protected title.
In India, the term "lawyer" is often colloquially used, but the official term is "advocate" as prescribed under the Advocates Act, 1961.[5]
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[6] or paralegals.[7] In fact, there are regulatory restrictions on non-lawyers like paralegals practicing law.[8]
Other nations tend to have comparable terms for the analogous concept.
Responsibilities
In most countries, particularly civil law countries, there has been a tradition of giving many legal tasks to a variety of civil law notaries, clerks, and scriveners.[9][10] These countries do not have "lawyers" in the American sense, insofar as that term refers to a single type of general-purpose legal services provider;[11] rather, their legal professions consist of a large number of different kinds of law-trained persons, known as jurists, some of whom are advocates who are licensed to practice in the courts.[12][13][14] It is difficult to formulate accurate generalizations that cover all the countries with multiple legal professions, because each country has traditionally had its own peculiar method of dividing up legal work among all its different types of legal professionals.[15]
Notably, England, the mother of the common law jurisdictions, emerged from the Dark Ages with similar complexity in its legal professions, but then evolved by the 19th century to a single dichotomy between barristers and solicitors. An equivalent dichotomy developed between advocates and procurators in some civil law countries; these two types did not always monopolize the practice of law, in that they coexisted with civil law notaries.[16][17][18]
