Translating the workings of a civil law system into English (common law) terminology can be extremely difficult, as all those who have ever attempted it will know. The reason for the complexity is simple; translating from one system to another system is far from straightforward. When, for example a Dutch lawyer has to explain his legal system to a common law lawyer, it is not simply a matter of replacing Dutch words with English words. The Dutch system is not a carbon copy of the English system, which means that there will not always be equivalent English terminology at hand for translation purposes. In order to use English legal terminology correctly and effectively, the practitioner must not only be familiar with his own legal system, but also have a basic grasp of the structure of the common law system.
Source: Helen Gubby, English legal terminology: Legal concepts in language (Boom Juridische Studieboeken)
by Eva Angelopoulou