In legal translation, certain untranslatable legal expressions have no direct equivalent from one language to another. These terms represent a real headache for legal specialists: a word-for-word translation can lead to misunderstandings and even errors of legal judgment. In the context of these challenges, a universal answer is not enough. That's where Lexa, our machine translation specialist, comes in: it identifies these specific legal terms and translates them accurately in line with the relevant legislation, using multilingual legal databases and sector-specific glossaries.
Why are some expressions untranslatable in law?
Law is a discipline deeply rooted in a nation's culture, history and institutions. Each legal system operates according to its own set of rules. This is why an expression, even if frequently used in one language, may be completely absent in another legal tradition. This is known as a conceptual gap.
For example, French civil law places great emphasis on concepts such as cause, fraud and the private deed, while Anglo-Saxon common law shapes its contracts around principles such as consideration and trust. A simple discrepancy between these systems can compromise a contract clause, alter a procedure or even call into question the legitimacy of a document.
In legal translation, therefore, a considered interpretation is essential, based not only on linguistic considerations but also on the logic of the source and target law. Lexa enables this level of analysis.
7 untranslatable legal expressions and their translation by Lexa
Here's an overview of the most complex cases and how Lexa provides legally relevant translations, bilaterally or trilaterally, depending on the language combination.
| Untranslatable expression | Legal system | Translation problem | Lexa proposal |
| Private deed | French law | No exact equivalent in Common Law | Agreement executed under private signature + context note |
| Consideration | Common Law (UK/US) | Concept absent from civil law | Retention of term + explanatory reformulation(counterparty) |
| Common law / Civil law | EN/FR comparison | Confusion with "common law" or "civil law". | Retention of original terms + adapted structure |
| Punitive damages | Common Law (US) | Non-existent in French law | Punitive damages + explanatory note |
| Dol | French law | "Fraud" too vague or inaccurate in English | Misrepresentation, fraudulent inducement, deceit according to context |
| Invitation to tender | Public law / contracts | Procedures vary widely from country to country | Call for tenders or RFP, depending on geographical context |
| Legal privilege | Common Law (UK/US) | Major differences from professional secrecy | Retention of term + comparative annotation on scope |
Practical consequences of poor translation
Mistakes resulting from poor legal translation are not theoretical. They can have real repercussions, including
- Contractual disputes arising from a misinterpreted clause;
- Rejection of a document by a foreign court for lack of validity ;
- A risk of regulatory non-compliance, in terms of public procurement or confidentiality.
For example, confusing legal privilege with "professional secrecy" can lead a French client to believe that all his exchanges with his lawyer are protected in the United States... which is not necessarily the case. Such an error could result in the disclosure of sensitive documents to the court.
Lexa: legal intelligence first and foremost
Unlike general-purpose artificial intelligence, Lexa is specifically designed for legal professionals such as jurists, lawyers, notaries and legal departments. It does more than simply translate words: it grasps concepts, detects cultural and systemic pitfalls, while proposing a translation appropriate to the legal framework in question.
Lexa has been trained using official bilingual corpora, comparative legal texts and specialized glossaries by sector (contract law, taxation, litigation, public procurement, etc.). It is capable of managing documents in several languages, taking into account the legal system of origin as well as that of destination, a considerable advantage for international exchanges.
Intelligent multilingual document management
In the legal field, many files contain multiple languages in a single document: contracts in two languages, annotated international court decisions, correspondence with English clauses, internal memos written in French. Unlike traditional tools, Lexa automatically detects segments in different languages, without the need for manual processing. It manages each section according to the language identified and the legal field determined, ensuring terminological uniformity and a fluid editorial style throughout the document. This capability is especially beneficial for comparative legal documents or simultaneously written contract clauses.
An engine adapted to the complexity of legal contexts
Lexa can also automatically identify the context: type of document (contract, court decision, notarial deed), jurisdiction involved, language combination, etc. It modifies its recommendations according to the purpose of the text: literal translation, editorial adaptation or equivalent transposition. It modifies its recommendations according to the purpose of the text: literal translation, editorial adaptation or equivalent transposition.
It also offers post-editing legal annotations, to underline a term to be checked or explain a formulation. This level of precision is unattainable with generalist tools, even if they are fed by important language models.
Case study: a law firm faced with the translation of court rulings
A firm specializing in international arbitration regularly calls on Lexa to translate court decisions and arbitration awards, which are generally long, technical and written in complex legal language. Before Lexa, these documents were distributed in multiple versions and checked manually by various legal experts. Today, thanks to batch translation and Lexa 's particular expertise in litigation, the firm is able to obtain a consistent version within 24 hours, with modifications focusing only on the tricky passages. The result: time savings of over 60%, and improved traceability of legal equivalents between legal systems.
Why is this essential in your contracts and legal documents?
Failure to translate a concept such as consideration, punitive damages or legal privilege can lead to tangible legal consequences: contract annulment, misunderstanding of clauses, jurisdiction disputes. This is why the use of a specialized tool such as Lexa ensures greater reliability, security and credibility, particularly in cross-border or multilingual communications.
To sum up, in a world where documents move from country to country in a matter of seconds, it's no longer enough to translate: you need to translate accurately. This calls for a tool developed specifically for the law.
Test Lexa on your complex documents
Do you regularly come across this type of expression in your contracts, clauses or decisions? Take the test. Lexa automatically detects sensitive wording and suggests reliable solutions, which you can then adjust with your legal advisor or translator.
