What is a solicitor in UK ?

A solicitor is a type of practicing lawyer who handles primarily office work. The UK has two types of practicing lawyers: solicitors and barristers. Solicitors generally handle office work, whereas barristers plead cases in court. Barristers depend on solicitors to provide them with trial work because they are not allowed to accept work on their own.

The distinction between solicitors and barristers was originally based on their roles in the English court system. Solicitors were lawyers who were admitted to practice in Equity courts, whereas barristers were lawyers who practiced in common-law courts. The modern English judicial system has abolished this distinction. Barristers may appear in legal and equitable court proceedings, and solicitors handle out-of-court lawyering.

The role of the solicitor is similar to that of a lawyer in the United States who does not appear in court. The solicitor meets prospective clients, hears the client's problems, gives legal advice, drafts letters and documents, negotiates on the client's behalf, and prepares the client's case for trial. When a court appearance appears inevitable, the solicitor retains a barrister on the client's behalf. The solicitor instructs the barrister on how the client wishes to proceed in court.

What is an “Avocat” in France ?

France is a civil law country, opposed to common law countries such as the UK and the USA.

The French legal system is based on the civil law tradition. France has a monist civil code legal tradition with a Latin notarial system. This system was principally introduced under Napoleon following the French Revolution.

A French Avocat, compared to his UK counterpart, meets clients, gives legal advice, drafts letters, contracts, prepares the clients’s case for trial but also is allowed to appear before a judge.
The French profession of avocat stood at 60,223 on January 1st, 2014 (54 % are women and the average age is 43.5 years). Almost half of the profession practise in the Paris region. The number of avocats increased of 41 % in the past ten years.

An avocat must be registered before a local bar association; registration is mandatory to be able to practice. There was 179 local bar associations on January 1st, 2009.

French avocat and notaire are slightly different.

French notaires are lawyers of voluntaryprivatecivil law who draft, take, and record legal instruments for private parties, provide legal advice and give attendance in person, and are vested as public officers with the authentication power of the State.

They are mainly involved in property issues and succession law. Unlike avocat, they have no authority to appear in court on their client's behalf.