I am looking for correct translations of English legal terms. Any language is welcome as target language, but let me ask just for French. (Maybe somebody from Canada knows very well and can help easily).

I wish to know which English legal terms are such that it is indeed difficult to translate them into French because the French legal system does not include a piece of institution that is analogous to whatever the English term denotes.

Terms of interest:



due process,


fair trial,










burden of proof,




claimant and respondent,

to sue,





civil vs. criminal



  • This is extremely broad. In terms of the site's scope you're probably better off asking a separate question for each term (or group of closely related terms) and target language. That's a lot of work, but law and translation are both complex things that are difficult to get right.
    – phoog
    Jan 12, 2016 at 17:34
  • Let me see if anybody helps. I am asking for layman translations.
    – mario
    Jan 12, 2016 at 17:39
  • These do not all mean the same thing in the many different English speaking jurisdictions, let alone all of the different French, Spanish, Thai etc. ones.
    – Dale M
    Jan 12, 2016 at 19:17
  • 3
    This is far, far too broad. You're asking for something closer to a term paper of 3000+ words, if you want answerers to compare each of these aspects of law in the English and French legal systems.
    – jimsug
    Jan 12, 2016 at 20:45
  • 1
    Actually, I think French is a bad language to think about for this, since many English legal terms have origins in Norman French and the nature of Canadian bilingualism has provided plenty of time for courts to "figure out" appropriate French words for all but the most obscure legal situations. You might want to consider a language associated with a country with a vastly different legal system, such as Chinese or Persian. Dec 5, 2022 at 15:14

2 Answers 2


Any of these terms has a very specific legal meaning. In another country, there may be no legal thing with exactly the same meaning. You can translate as much as you like, but the closest matching word will not have exactly to same meaning.

For example, instead of trying to translate "prosecutor" you might try to translate "US prosecutor". For example in a French translation, combining "American" with the word closest to "prosecutor" would quite clearly exactly express a US prosecutor.

Another example, try translating "First degree murder", "second degree murder", "manslaughter" into German. There they are different classes of illegally and non accidentally killing a person, but the definitions of each class won't match exactly the US definitions. I'd translate "First degree murder" als "Mord ersten Grades nach US Gesetz", making up a term that doesn't legally exist in Germany (there is nothing matching "first degree murder"), and add "US law" because that way the exact meaning is clear.

  • in German, are there words which correspond to the English words murder and manslaughter? IATE seems to suggest Tötung, resp. fahrlässige Tötung. I see your point anyway, and I am starting to think that my underlying question is rather about - let me say - legal ontologies: whether or not to a piece of a legal system corresponds something which has the same function in the foreign legal system.
    – mario
    Jan 18, 2016 at 15:22
  • Tötung is a general term causing somebody to die. Fahrlässige Tötung is negligent manslaughter. Another close word would be Totschlag (voluntary manslaughter). In Germany, killing somebody is "Totschlag" unless you were motivated by evil intent (then it is "Mord", which would translate to murder). In Austria, killing somebody is "Mord" unless your motivation came from an understandable motivation - then it is "Totschlag". No idea about Switzerland and other countries, though.
    – elaforma
    Jan 19, 2016 at 15:44
  • There is no "first degree" and "second degree" distinction (but sentencing will depend on the circumstances), and unless rules for Totschlag (quite similar to manslaughter) are literally the same as in US law, there will be cases that would fall into that category in one country but not in the other.
    – gnasher729
    Jan 19, 2016 at 23:52
  • 1
    Exactly. This is due to the nature of legal terms of art as highly specific. This would even apply without translation. For example, the Australian concept of Native Title doesn't exist in the UK, so the concept could be described to a UK solicitor as "Australian Native Title" or "the Australian concept of Native Title (cites)". Dec 5, 2022 at 15:17

IATE lists official EU translations, including their sources. For "trial" in French, 350 references are given. Narrowing the search to domain 12 (law), we still have 130 references. These are certainly not unique translations, mostly minor contextual differences. It's fairly obvious that the primary translation is "procès".


Not the answer you're looking for? Browse other questions tagged .