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. 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; 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. 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.
Notably, England, the mother of the common law jurisdictions, emerged from the Middle Ages with similar complexity in its legal professions, but then evolved by the 19th century to a single division between barristers and solicitors. An equivalent division 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.
Several countries that originally had two or more legal professions have since fused or united their professions into a single type of lawyer. Most countries in this category are common law countries, though France, a civil law country, merged its jurists in 1990 and 1991 in response to Anglo-American competition. In countries with fused professions, a lawyer is usually permitted to carry out all or nearly all the responsibilities listed below.
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