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May 26 12:39
1 mo ago
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French term

de nationalité anglaise

French to English Law/Patents Law (general) Official document (Switzerland)
Vu etc. etc. etc.

LE JUSTICE DE PAIX:

I. institue une curatelle de représentation au sens de l'art. 394 al. 1 CC et de gestion au sens de l'art. 395 al. 1 CC en faveur de AAAA BBBB, née le xx yy zzzz, fille de CCCC et DDDD, veuve, de nationalité anglaise, domiciliée à ..... (Suisse)

This is from a document that has been certified by the court registrar, then by a notary and then further by an apostille (presumably for use in the UK). It's almost unbelievable that authorities at this level think there is such a thing (officially) as "English nationality". It's like the "Anglo-saxon legal system" thing, but I must resist the urge to rant about that.

I know of course that this would be the direct translation, and I am strongly inclined to use it.

However, I would like colleagues' opinions on this.

Is it best to translate as:

1. Of English nationality (on the basis that "nationality" relates to the country in which one is born and that England is indeed a country - within the UK)
2. Of English citizenship (which would be erroneous)
3. Of British nationality
4. Of British citizenship

3. and 4. would of course contradict what is written in French, which I don't see as the translator's responsibility to correct (if the Swiss want to call Welsh and Scottish people English, be it upon their own heads)

Or:
5. Of British nationality, with the dreaded "translator's note"
Proposed translations (English)
3 +4 English nationality (sic)
4 +3 English-born, UK nationality
4 +1 British citizen
4 British, British nationality
3 -1 a UK national
2 of Anglo-nationaility
3 -2 a citizen of the United Kingdom
4 -4 An Englishman / an English citizen
References
see

Discussion

AllegroTrans (asker) May 27:
Indeed... The usual suspects (minus one or two) all had their penny's/cent's worth - and on a Sunday followed by a (England, Wales & Scotland) bank holiday to boot!
Paul Adie May 27:
Agree to disagree. Different translators do it differently, that's all part of it. I'd go for British and others wouldn't. Nothing like a nationality question to get the Brits typing - never seen such a long discussion and happy for it!
AllegroTrans (asker) May 27:
patransword I respectfully think you've missed the point: this is from a document drawn up by a Swiss court official and I don't think the lady concerned was even consulted. It's a clear case of ignorance by the official.
My question didn't involve an inquiry into what was actually meant - almost without doubt a UK passport was seen as identity - my question was about translation methodology.
Paul Adie May 27:
. I'm surprised at others' options for this, but enjoying the discussion.
Why would we decide to narrow the pool instead of broadening it? British encompass everything, so if the person is a proud Englishwoman, Scot, Welsh or Northen Irish, they can all do so within the word British.
If it was just "anglaise", then of course you could put English. Along with "nationalité", it's clear that the original writer meant someone from up there in the islands. I don't think this person is pushing for English independence - just a bit clumsy and using the normal French word for "britannique". If someone was writing about "nationalité écossaise", then they're most likely pro-independence and then some kind of note would be necessary.
Do people actually think this person deliberately put "anglaise" instead of "britannique"? Come on...
Carol Gullidge May 27:
I see no problem with English Maybe the Deceased was proud of being English as opposed to merely “British” - which of course also encompasses the Welsh, the Irish, and my Scottish son-in-law.
The English nationality began with the Anglo-Saxons, so has been going for quite a while!
And anyway, since when have translators had the right to alter the text without first consulting the author? If the Deceased (or her relatives or representatives) thought of herself specifically as English, then who are we to high-handedly decide otherwise? And what harm could come of it?
writeaway May 27:
Another option Ask the client.
Daryo May 27:
The "agrees" are on a point of method i.e. "not being allowed to correct an obvious mistake" in a certified translation.
No one is "agreeing" that there is in law such thing as "nationalité anglaise / English nationality".
Paul Adie May 27:
Eh? I'm a bit flummoxed by the answers saying "English" gaining agrees. Anyone who has lived for any time in continental Europe will know that when the French or Spanish say "anglais/inglés", they mean "British" (up there where they speak English). Some even argue about Ireland being independent. English nationality doesn't exist. Even at university level I was called English, even after saying repeatedly that I was Scottish.
AllegroTrans (asker) May 26:
@ Bourth Yes, I'm sure britannique was meant but my question was more about correct translation methodology. Personally, I find it completely inexcusable for government and court officials to have this degree of ignorance. The general public I can forgive.
AllegroTrans (asker) May 26:
@ Bourth Yes, I'm sure britannique was meant but my question was more about correct translation methodology. Personally, I find it completely inexcusable for government and court officials to have this degree of ignorance. The general public I can excuse.
Bourth May 26:
British citizen Since I very much doubt anglaise was a deliberate choice, i.e. to avoid britannique for some reason, I think it is safe to assume that britannique is what is meant. You can hardly blame the French for not understanding these things when so many Brits don't know the geographical and/or political distinctions between Britain, Great Britain, the British Isles, and the UK.
Daryo May 26:
My mistake. Corrected.
Emmanuella May 26:
Daryo,
En effet, c'est une erreur manifeste du point de vue administratif.
De grâce, Royaume-Uni , sans 'e'.
Daryo May 26:
Exactly that's the correct "translation" for the extremely widespread everyday use of "... anglais" to "proper legalese".

You have the tricky problem of having to translate an official document where instead of using the technically correct term "...ressortissant du Royaume-Uni", this judge (or whoever drafted this legal document) used by pure force of habit the informal "de nationalité anglaise".

Or you could see it this way: as far a judge in Paris is concerned, what counts is to know from which internationally recognized state a party comes from, i.e. "nationalité" is determined by which passport this person holds, which "nation-state" issued it - and that would be the UK / a British passport.

The way French use and misuse " ... anglais/e" is the same as if they started calling anyone coming from USA "a Texan" or anyone coming from Germany "a Bavarian".

The same way almost no one in France goes to travel to "Royaume-Uni" only to "l'Angleterre".
AllegroTrans (asker) May 26:
@ Daryo So when they say informally of someone "... de nationalité anglaise" what they really mean is "a holder of a UK passport".
The problem here is that this is not being said informally, it's within a legal document certified by a court clerk and a notary and supported by an international apostille. And it says nothing whatever about a UK passport.
Daryo May 26:
The problem is that whatever French use **informally**for anyone holding a UK passport, from the point of view of international relations there is no "English nationality", no more than there is as of today any "Scottish nationality". The only certificate the Home Office is going to give you is a certificate of "British nationality".

For the purpose of this ST "nationalité" means "belonging to an internationally recognised state", NOT "being of a certain ethnic group", nor "living in a subdivision of an internationally recognised state".

The only reason the incorrect term "English nationality" has to be used here is that you can not correct of your own accord the ST when making a certified translation.

The correct term in French would have been "citoyenne du Royaume-Unie" or even better "ressortissant ..." i.e. "a UK national", possibly "a British citizen".

So it's got to be "English nationality (sic)".
ph-b May 26:
Agree with Keith Jackson's "English nationality (sic)"

"English nationality" is what the source text says and you're not supposed to change it unless your client allows you to do so. "(sic)" will alert them to something unusual and they'll decide what to do.
Jennifer White May 26:
as Phil and Keith say it has to be "of English nationality". That is what it says and that is what I have always used without questioning it. It's not British or UK. I really cannot see any problem here.
Daryo May 26:
What is wrong with good old plain “English”?

Absolutely nothing wrong. Only here "...anglaise" doesn't necessarily mean "English".

As far most people in France are concerned ils ne vont pas se casser la tête à couper les cheveux en quatre dans le sens de la longueur, ils vont simplement tout mettre dans le même panier.

So when they say informally of someone "... de nationalité anglaise" what they really mean is "a holder of a UK passport", no matter from part which of the UK they are. For all we know this widow could be from Scotland or Wales or ...
Charlie Bavington May 26:
True I'm very much inclined to let things pass in the course of idle conversation that I might challenge were they to be recorded in a legal document.

The point surely is, we all know how "anglais" gets used and abused - you even see stuff like "le gouvernement anglais" in fairly formal writing. Seems an interesting Q to ask how to deal with it here.
AllegroTrans (asker) May 26:
@ Keith (sic) - I like it. Please suggest as answer and let's see how the voting goes.
AllegroTrans (asker) May 26:
@ Phil and Carol As already said, I am strongly inclined to stick with exactly what is said - albeit technically incorrect and (probably) geographically correct. Unfortunately I haven't anything to show the person's place of birth. Phil, I was just interested to hear other views.
Carol Gullidge May 26:
What is wrong with good old plain “English”, which After all is what it says?
It doesn’t specify Brittanique, or talk about citizenship, etc, and least of all is there any mention of this widow being a man!
Emmanuella May 26:
https://commonslibrary.parliament.uk/nationality-and-passpor...
philgoddard May 26:
I'm surprised you're asking this You're always telling me that legal documents are sacrosanct and I should translate what they say rather than improving or interpreting. So it has to be 'English'.
Keith Jackson May 26:
Offend them all with "sic" English nationality (sic)

🤣

Proposed translations

+4
4 hrs
Selected

English nationality (sic)

see discussion
Note from asker:
This has to be an accurate translation. No adjustments, corrections, bells or whistles..
and "sic" is arguably better than a translator's note
Peer comment(s):
agree Daryo : That's what the ST says, wrongly but you can't change it, so you have to add "(sic)".
1 hr
Thank you. I'm warming to my answer! ;-)
agree ph-b : What the source text says is not supposed to be changed unless your client allows you to do so. "(sic)" will alert them to something unusual and they'll decide what to do.
2 hrs
Thank you, yes. No corrections or second guessing.
agree liz askew : Yes, really, we should stick to the source
3 hrs
I agree with your "agree"! Thanks!
agree Mark Nathan : Sic
5 hrs
Thanks!
neutral Annette Fehr : If you want to highlight the incompetence of the French civil service, this translation is perfect. (I'm no fan of the French civil service, myself, since I have to live here).
15 hrs
The French judiciary is a total technocratic black box.😟 However, in defence of the larger French civil service, my post Brexit citizenship was dealt with very smoothly and efficiently. 🤩
Something went wrong...
4 KudoZ points awarded for this answer. Comment: "The ayes have it. Thank you for the [sic] idea"
-4
25 mins

An Englishman / an English citizen

Voilà ma proposition
Note from asker:
No Etienne, this person is a woman. Also, when describing nationality in official documents, I have always seen the adjective used - not "man" or "woman" tagged onto it to make a noun
Peer comment(s):
disagree Paul Adie : What if the person was born in Scotland, Wales or Northern Ireland?
9 mins
disagree Margaret Morrison : Grammatically and legally incorrect- By grammatically, I mean, doesn't agree with the subject who it seems is female.
13 mins
agree philgoddard : Not 'Englishman', though, English citizen. And this is grammatically correct.
22 mins
disagree Carol Gullidge : A widow cannot be an Englishman - or vice versa!
1 hr
disagree Jennifer Levey : citizenship is NOT the same as nationality
1 hr
disagree Daryo : as far as international law is concerned there is no "English citizen", only "British citizen" / "UK nationals"
5 hrs
Something went wrong...
-1
28 mins

a UK national

Just an idea. As there is no adjective for "UK" and British might not apply, strictly speaking, if the person happens to be from NI.
Peer comment(s):
neutral Paul Adie : Think this is fine, but NI also have a British passport, so would include them under this.
6 mins
I've never really looked at the front but you're right, it does say "British" before expanding it to "UK of GB and NI" so fair point :-)
disagree Carol Gullidge : This wd also include Scots, Irish and Welsh, whereas the text quite specifically says “anglaise”
1 hr
I think most of us have seen "anglais" used to describe UK things, indeed things that are definitely NOT Eng. The Q is, what did the author mean? :-) My rule is better be generally right than specifically wrong.
neutral Daryo : Assuming that you should correct the ST, only this would be guaranteed to be correct, although this widow is most likely a UK citizen.
1 hr
Something went wrong...
-2
33 mins

a citizen of the United Kingdom

Should keep everyone happy

--------------------------------------------------
Note added at 1 hr (2024-05-26 14:17:57 GMT)
--------------------------------------------------

On second thoughts, better leave citizenship out of it.
Peer comment(s):
agree Margaret Morrison : With note perhaps just to make sure they don't "correct" it back again...
9 mins
disagree liz askew : https://www.economist.com/the-economist-explains/2017/07/09/...
50 mins
Thanks Liz, that is an interesting article.
disagree Jennifer Levey : citizenship is NOT the same as nationality
1 hr
Yes, I realise that now, hence my note.
disagree Carol Gullidge : I don’t believe the two are completely synonymous
1 hr
No, definitely not!
neutral Daryo : This would be correct IF correcting the ST was acceptable. // For the purpose of this ST, the only relevant reference is what the Home Office has to say.
1 hr
No, I don't think it would be correct - see liz askew's reference.
Something went wrong...
+3
33 mins

English-born, UK nationality

Covers it all?

--------------------------------------------------
Note added at 41 mins (2024-05-26 13:20:58 GMT)
--------------------------------------------------

Or British instead of UK. clearly British if English born

Yes, it does seem strange, and agree with you about the silly anglo-saxon thing.
Do you happen to have his place of birth anywhere just to confirm he is English?
In fact you might also say,
English with British passport (and omit "nationality")


--------------------------------------------------
Note added at 1 hr (2024-05-26 14:09:32 GMT)
--------------------------------------------------

Sorry HER

--------------------------------------------------
Note added at 2 hrs (2024-05-26 15:20:23 GMT)
--------------------------------------------------

Yes, I realised that afterwars. Read too fast and saw you had her date of birth so assumed too much.
But came to conclusion it should be "English" on its own probably as anyone from these islands who speaks English is often considered as such without other distinctions
Note from asker:
Thanks Y, my only reservation is that I don't actually know where this person was born!
Nor do I know whether she holds a British (UK) passport. For all I know she may have been born in Wales!
Peer comment(s):
agree writeaway : English nationality, holder of British passport /I think that keeping the word nationality is good idea given the context
54 mins
Thanks. I think, as per last line, "English" is OK on its own ( without "nationality"?
disagree philgoddard : We don't know where she was born.
1 hr
Why not read on? I changed it. Yet you agree with totally wrong answer? Typical!
agree Daryo : yes for "UK national", but "English-born" is surplus to requirement. // Assuming, of course, that you decide on your own initiative to correct the obvious mistake in the ST.
2 hrs
Thank you:-)
agree Lara Barnett
4 hrs
Thank you:-)
agree Carol Gullidge : Agree with your final conclusion: simply “English”. I see no problem with being English, but British when it suits me (such as queuing for passing control)! British is merely an umbrella term for all 4 nationalities/i meant PASSPORT control of course
23 hrs
Thank you. Yes, indeed
Something went wrong...
2 hrs

of Anglo-nationaility

This is my own fudge I have used with 'impunity' before now for (witless) Franco- and Hispanic consumption.

Funnlily enough, my Austrian dentist & wife asked me just other week what 'Sassenach' in Scottish Nextflix films meant.

Anglo-Saxon is arguably on the right lines, though most online deifntions include Scottish for Anglo, but do not subsume Welsh and boraden out the definition to include British and even Northern Irish (gulp!)

Cut to the the Welsh FA refusing in the Olympics to field any Welsh players in the GB 'amateur/ professional' team squad.

Otherwise, my Welsh mates and sister-in-law squeal with protest at being labelled 'English' : quaere 'Anglo' and the late and great actor Sean Connery strongly objected to being called an 'English' James Bond- hence my law CL / confidence level.

--------------------------------------------------
Note added at 3 hrs (2024-05-26 15:40:33 GMT)
--------------------------------------------------

5th option, permutation & combination: of Anglo-*nationality*.

LE JUSTICE DE PAIX: BTW, better translatable as District Judge in a civil context ('formerly District Judge or Court, Bridge'), Justice of the Peace being mainly criminal - and always picked up a such at the Bar - in E&W.
Example sentence:

In Australia, Anglo is used as part of the terms Anglo-Australian and Anglo-Celtic, which refer to the majority of Australians, who are of English, Scottish, Welsh and Irish descent.

Anglo- combines with adjectives indicating nationality to form adjectives which describe a person who has one British parent and one non-British parent.

Reference:

http://www.ldoceonline.com/Nationality%2B%26%2Brace-topic/anglo#google_vignette

http://en.wikipedia.org/wiki/Anglo

Note from asker:
So I presume a Welsh person is of Cambro-nationality, and an Irish person Hiberno-nationaility?
Something went wrong...
33 mins

British, British nationality

Our European cousins use this to refer to being British. As a Scot I would correct them, but that's what they mean. I even had a university professor in Catalonia (!) call me English.

Sometimes you really can't teach an old dog new tricks.

--------------------------------------------------
Note added at 4 hrs (2024-05-26 17:22:44 GMT)
--------------------------------------------------

@Carol - it seems my times in Catalonia are repeating themselves...
Peer comment(s):
agree liz askew : Whats my nationality? The Student Room https://www.thestudentroom.co.uk › showthread English and Welsh aren't nationalities. Your nationality is British, under the British Nationality Act. A nation is generally considered to be an entity formed ...
47 mins
Thanks!
disagree Carol Gullidge : The text quite specifically states “anglaise”, I.e., English and not Scottish etc. This isn’t about the passport but the nationality. The English nation has been around quite some time - as have the Scots, Irish and Welsh. Of course, all also Brits
1 hr
I have to disagree with your disagree. There is no English passport or citizenship, just British. The French say "anglais" meaning anything from England, Scotland, Wales or Northern Ireland - essentially "up there where they speak English".
neutral Daryo : "British citizen" says the Home Office https://i0.wp.com/apostillelondon.com/wp-content/uploads/202...
2 hrs
It also says "British nationality" on it, sweetie.
Something went wrong...
+1
9 hrs

British citizen

I've just realized this is not in the already long list.

As I put first under Discussion, since I very much doubt anglaise was a deliberate choice, i.e. to avoid britannique for some reason, I think it is safe to assume that britannique is what is meant.
You can hardly blame the French for not understanding these things when so many Brits don't know the geographical and/or political distinctions between Britain, Great Britain, the British Isles, and the UK.
As for whether one mentions the UK, nationality etc., I think the answer can be found in the liminary pages of British passports: "British citizens have the right of abode in the United Kingdom". Citizenship and nationality are not the same since one can be a British national but not a British citizen: "No right of abode in the United Kingdom derives from the status, as British nationals, of British Dependent Territories citizens, British Overseas Territories citizens, British Nationals (Overseas), British Overseas citizens, British protected persons and British subjects".
Even if the notaire were to have intended to deliberately use nationalité to cover one of the cases above (which would imply greater than usual knowledge of such things), they would presumably have known enough to say britannique, not anglaise.


--------------------------------------------------
Note added at 9 hrs (2024-05-26 21:55:01 GMT)
--------------------------------------------------

Politically (as opposed to geographically), and whether they like it or not, the Northern Irish are British, this being the qualifier for 'United Kingdom of Great Britain and Northern Ireland'.

It's interesting that TTBOMK at least, the French have not come up with the equivalent for the UK of their Etatsunien for the USA.
Note from asker:
Good to see you again
Discussion (for another time): https://fr.wikipedia.org/wiki/D%C3%A9nomination_des_%C3%89tats-Unis_et_de_leurs_habitants
Peer comment(s):
agree Annette Fehr : Since this is for a legal document, and "english nationality" doesn't exist, I think "British citizen" is the most appropriate translation.
10 hrs
Something went wrong...

Reference comments

1 hr
Reference:

see

https://www.economist.com/the-economist-explains/2017/07/09/...

--------------------------------------------------
Note added at   1 godz. (2024-05-26 14:05:15 GMT)
--------------------------------------------------

IN OCTOBER, when Theresa May’s political future still looked bright, the British prime minister chastised her opponents: “If you believe you’re a citizen of the world, you’re a citizen of nowhere. You don’t understand what the very word ‘citizenship’ means.” In their defence, the concept of citizenship is complex, especially when compared with the similarly complicated idea of nationality. What is the difference between the two?

In general, to be a national is to be a member of a state. Nationality is acquired by birth or adoption, marriage, or descent (the specifics vary from country to country). Having a nationality is crucial for receiving full recognition under international law. Indeed, Article 15 of the Universal Declaration of Human Rights declares that “Everyone has the right to a nationality” and “No one shall be arbitrarily deprived of his nationality nor denied the right to change his nationality” but is silent on citizenship. Citizenship is a narrower concept: it is a specific legal relationship between a state and a person. It gives that person certain rights and responsibilities. It does not have to accompany nationality. In some Latin American countries, for example, such as Mexico, a person acquires nationality at birth but receives citizenship only upon turning 18: Mexican children, therefore, are nationals but not citizens.

--------------------------------------------------
Note added at   1 godz. (2024-05-26 14:08:02 GMT)
--------------------------------------------------

I would go with "English".

http://projectbritain.com/nationality.htm

--------------------------------------------------
Note added at   1 godz. (2024-05-26 14:10:20 GMT)
--------------------------------------------------

Also:

Whats my nationality?
The Student Room
https://www.thestudentroom.co.uk › showthread
English and Welsh aren't nationalities. Your nationality is British, under the British Nationality Act. A nation is generally considered to be an entity formed ...
Peer comments on this reference comment:
agree Mark Nathan
14 mins
neutral Daryo : The internationally recognised state is "UK" // there is no English/Scottish/Welsh ... passport nor nationality. What the Home Office has to say is relevant for this ST./?? your link is only about things "British" not "English", so confirming what I said.
1 hr
https://immigrationlawyers-london.com/blog/british-nationali...
Something went wrong...
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