Comparing American and British Legal Education Systems: Lessons for Commonwealth African Law Schools
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Comparing American and British Legal Education Systems: Lessons f ...

Chapter 2:  Primary university qualifications to become a lawyer in the USA, the UK and South Africa
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But, is a JD a true Doctorate? The polemics surrounding the switch from the LLB title to the JD have filled the pages of several American journals and commentaries. It is, however, not the purpose of this book to revive such debates.

Suffice it to say, unlike the introduction of the title ‘JD’ in the US, UK law schools and those in other parts of the Commonwealth have retained the title ‘Bachelor of Laws’ degree for their primary law degree. Further, it normally takes three to four years of undergraduate study for a student to graduate as a lawyer in the UK and other parts of the Commonwealth. But, while the UK has retained the distinction between a barrister and a solicitor, many Commonwealth African States have now fused the roles of a barrister and a solicitor into one office. In these countries, the officeholder is usually referred to as an advocate.

2.2 Academic Developments in Canada, China, Australia and South Africa

Typically, while a law student in the US has to complete a Bachelors degree before he or she can be admitted to law school, this is not necessarily the case in the UK and other Commonwealth countries. As Richardson observes:

As you are probably aware, the United States is composed of fifty states. Canada is composed of ten provinces and three territories. With the exception of the province of Quebec in Canada and the state of Louisiana in the US, the North American legal system is historically based on the system of common law that originated in England. This means that in many respects, law school curriculum in Canada and the US is similar to law school curriculum in the UK, Australia and New Zealand. In Canada and the US students normally enter law school after earning a bachelors degree. This is not so in the UK…, law school in the US is a three year academic programme which is undertaken after the completion of a bachelors degree.21