British and American legal terminology: a cross-cultural perspective
British and American legal terminology: a cross-cultural perspective

Author(s): Nicoleta Baghici
Subject(s): Language and Literature Studies, Law, Constitution, Jurisprudence, Theoretical Linguistics, Applied Linguistics, Comparative Linguistics, Descriptive linguistics
Published by: Biblioteca Ştiinţifică a Universităţii de Stat Alecu Russo
Keywords: legal terminology; british law, american law; comparative law; legal translation; common law systems; contract law; terminological divergence
Summary/Abstract: This article looks at the similarities and differences between british and American legal terms, focusing on how history, culture, and language have shaped the way each system uses legal language. Both systems come from the same English common law roots, but their legal terms have changed over time to fit their unique needs. The article compares areas like contract law, tort law, property law, and criminal law, with examples such as "consideration," "duty of care," and "freehold." It also talks about how hard it can be to translate legal terms between the two systems, especially for tricky concepts like trusts and criminal pleas. Using ideas from experts like Hart and Gadamer, the article explains why understanding the meaning behind legal terms is so important. Finally, it highlights how technology and teamwork can help make legal terms more consistent around the world, showing how these systems can connect while keeping their own unique features.

• Details
• Contents