Glossary entry (derived from question below)
French term or phrase:
en la forme anglo-saxonne
English translation:
in Common Law (Anglo-American) form
French term
en la forme anglo-saxonne
par testament fait en la forme anglo-saxonne, rédigé en langue anglaise.....Madame XY a désigmé AB et CD aux fonctions d'exésuteurs testamentaires...
I have previously ranted on this forum about the notion of "Anglo Saxon" law, albeit francophone countries seem to like the term. Let us remember that the Anglo Saxons were Germanic tribes who invaded Britain in the 5th century. The amount of "Anglo Saxon law" remaining in the deposit of law and it is in fact Norman French law that had had the largest influence in shaping the law of England, USA etc.
However, the document is a formal certificate. My inclination is to translate as "in Anglo Saxon (sic) form" and to insert a translator's note (something that I hardly ever do) to the effect that this really means "in Common Law form".
Would be interested to know if anyone has alternative suggestions.
3 +2 | in English Common Law (Anglo-American) form | Adrian MM. |
4 +4 | in the form customary in (most) English-speaking countries | transatgees |
We've had this before | philgoddard |
Jun 23, 2022 15:53: Adrian MM. Created KOG entry
Non-PRO (1): Rachel Fell
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Proposed translations
in English Common Law (Anglo-American) form
No need to bring any other English-speaking countries - even British Commonwealth - into the equation.
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Note added at 1 day 3 hrs (2022-06-23 15:38:15 GMT) Post-grading
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Wilfægenimp hafa !
Channel Islanders don't have a problem with the Norman French connection - conveyances of land being written in the vernacular until 1974 - though French commentators do, insisting on references to the 'Anglo-Norman Isles'. One Daily Mail English reader asked: 'where are they?' https://en.wikipedia.org/wiki/Law_French
Otherwise, as Irish Solicitors are wont to point out or mock, Equitable Trusts - that English & Welsh lawyers are 'so proud of' - came into English law via Norman French.
IATE: source of law [LAW, sources and branches of the law] Consilium en Redirected from: Anglo-American law fr common law Consilium
I like "Anglo-American" when applied (strictly of course) to legal and governmental systems. Have never understood why the French shy away from the fact that a massive chunk of Common Law is of Norman French pedigree |
agree |
Conor McAuley
: Common or Anglo-American law, from Encyclopaedia Britannica: https://www.britannica.com/topic/common-law / No need to specify "English", by the way
45 mins
|
Thanks, Conor, and merci. I prefixed with English only to juxtapose the faux ami of 'de droit commun' and that is lost on most UK language (!) graduates running translation agencies: 'why doesn't the latter translate as Common Law? You are out on a limb.'
|
|
agree |
Steve Robbie
: Yes to "Anglo-American"
53 mins
|
Thanks, Steve. Anglo-American is more German / English 'conventional angelsächsisches wisdom' that is slow to trickle down and filter through to French and other languages.
|
in the form customary in (most) English-speaking countries
Thanks for this suggestion |
agree |
ezpz
: Sounds like a nice, self-explanatory (no need for a translator's note), alternative.
15 mins
|
agree |
Barbara Cochran, MFA
45 mins
|
agree |
philgoddard
2 hrs
|
agree |
Michael Meskers
11 hrs
|
Reference comments
We've had this before
Please check the glossary next time.
Thanks Phil but as Adrian says, we haven't had this term in the same "form" before |
I'm also very aware of the glossary having made several previous contributions (and rants) regarding this term |
neutral |
Adrian MM.
: That assumes a 'direct hit', rather than a series of misleading 'English-speaking' approximations. // Great colleagues, but not such great answers.
9 mins
|
agree |
writeaway
: Some really great colleagues there on that question
17 mins
|
Discussion
Concise Oxford, 1976 - "*[means chiefly US, also often Canadian, Australian, etc.] [in] modern English, (colloq.) [...] (person)of English descent (wherever found)
SOED, 1983 - "Used rhet. for 'English' in its ethnological sense [...] Hence 'Anglo-Saxondom' [...] rhet. for Great Britain and the United States"
Webster's New World Coll. - "4. a person of English nationality or descent"
With the same meanings when used adjectivally.
common law
Alternate titles: Anglo-American law
By Mary Ann Glendon See All • Edit History
Henry II and Thomas Becket
Henry II and Thomas Becket
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Key People: Sir William Blackstone Oliver Wendell Holmes, Jr. Sir Edward Coke Sir Matthew Hale James Kent
Related Topics: equity coverture feme sole stare decisis judicial lawmaking
Summary
Read a brief summary of this topic
common law, also called Anglo-American law, the body of customary law, based upon judicial decisions and embodied in reports of decided cases, that has been administered by the common-law courts of England since the Middle Ages. From it has evolved the type of legal system now found also in the United States and in most of the member states of the Commonwealth (formerly the British Commonwealth of Nations).
This is kind of hilarious.
I think in France, like in Spain and maybe other places too, when people say anglo-saxon they colloquially refer to Brits and Americans.
This being a formal document, I think it's best to contain your rage/laughter, and do the needful ;D