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.[4]
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 wh
o 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 persons who provide reserved legal activities and includes practitioners such as barristers, solicitors, registered foreign lawyers, patent attorneys, trade mark attorneys, licensed conveyancers, commissioners for oaths, immigration advisers and claims management services [Legal Services Act 2007] 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.[citation needed]
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. 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]
Other nations tend to have comparable terms for the analogous concept.
