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Originally an official of the medieval European ecclesiastical courts, the notary developed into a noncontentious secular legal professional in France. In England, partly because the canon and secular laws were not on speaking terms, the notarial system never took deep root. For one thing, an important aspect of the notary’s duties, his authority to authenticate documents, was of little use to the English. The whole notion of a state-sanctioned authenticator of private acts was entirely foreign to English common law; whereas in France we see notaries making and passing contracts, the common law left that to the parties.

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