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Barrister and solicitor

From England and Wales (and other common-law systems)

Legal professions

What it means

In England and Wales a barrister specialises in advocacy in the higher courts and in giving opinions, and a solicitor deals with clients directly and prepares cases. Other systems have one profession, or different splits.

Why it travels badly

Most countries have a single legal profession, and the American 'attorney' or 'lawyer' covers both jobs. Others, such as Spain, have a different split altogether. A word-for-word translation of 'barrister' or 'solicitor' therefore suggests a division that may not exist in the target system.

How other systems say it

France

avocat

One profession, since the merger of the avocat and the conseil juridique in 1990. A small group of specialist advocates, the avocats aux Conseils, appear before the highest courts.

Germany

Rechtsanwalt

One profession. A small number of specially admitted lawyers handle civil appeals at the Federal Court of Justice.

Spain

abogado and procurador

The abogado advises and argues. The procurador represents the party in court proceedings. They are different professions.

United States

attorney / lawyer

One profession for all legal work, admitted state by state.

Tip for translators and students

Use a neutral word such as 'lawyer' or 'advocate' unless the exact role matters, and then describe it ('a lawyer who argues in the higher courts').

Related: Notary, Prosecutor

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.