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Attorney General

From England and the common-law world

Legal professionsConstitutional and public law

What it means

A senior law officer of the state. The role varies widely, from the government's legal adviser to the head of the justice ministry to a chief prosecutor.

Why it travels badly

The English 'Attorney General' is a legal adviser to the government, who is also a political appointee. In the United States he or she heads the Department of Justice, and each state has its own. In civil-law countries the closest posts are the justice minister or the chief public prosecutor, which are different jobs.

How other systems say it

England and Wales

Attorney General

The government's chief legal adviser, who also has certain public-interest duties in court.

United States

Attorney General

The head of the federal Department of Justice, a member of the President's cabinet. Each state also has an attorney general.

India

Attorney General for India

The Union government's chief legal adviser, appointed under Article 76 of the Constitution.

France

garde des Sceaux (Minister of Justice)

A member of the government who is responsible for the justice system. The chief prosecutors are separate officers.

Spain

Fiscal General del Estado

The head of the public prosecution service, not a government legal adviser.

Tip for translators and students

Keep 'Attorney General' as a title and add a short gloss, such as 'the government's chief legal adviser', whenever the reader may expect a prosecutor or a minister.

Related: Prosecutor, Barrister and solicitor

Updated October 2026. Spotted a mistake? Tell us.

TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.