Dictionary of differences Austrian and German law

Wörterbuch rechtsterminologischer Unterschiede Österreich–Deutschland (Österreichisches Deutsch – Sprache der Gegenwart, Band 16) von Rudolf Muhr (Autor), Marlene Peinhopf (Autor)

This book contains 2000 Austrian legal terms with their German equivalents and much more. There are English and French translations too. You can look inside the book at amazon. 

The German-law equivalent is given if there is one. 43 Austrian terms and 492 German terms have no equivalent in the other legal system. 

For example: for Abfertigung we find it is a statutory term – the German equivalent is Abfindung, the English severance pay and the French indemnité(s) de licenciement. There are definitions for both the Austrian and German terms. Where a term doesn’t exactly exist in German law, there  is still a note explaining the situation in more detail. 

I’ve only skimmed the book so far. the use of English translations is of great interest. My eye fell on Landesgericht – circuit court (UK) / regional court, and Landbutter: country butter – I’m not too sure about those, but most of the English looks good.

There are other books in the series, in particular Heidemarie Markhardt’s Wörterbuch der österreichischen Rechts-, Wirtschafts- und Verwaltungsterminologie – see earlier post.

MORE DETAILS ADDED THE NEXT DAY

I have now had a closer first look at the dictionary. It arises from work on Austrian German and ‘Bundesdeutsch’ in the EU after Markhardt, whose work on Austrian German for the EU was up to 2007. It is also to be seen as an attempt to show how terminology work can be constructed in pluricentral languages such as German, where two legal systems are based on the same language, within the EU. That is the case also for English, French, Greek, Dutch, Portuguese, Swedish and Spanish. The first version of the dictionary was produced between 2007 and 2010, with the support of the Austrian government. About 1000 of the terms later entered IATE. The project was fully revised between 2014 and 2015. 

The emphasis of the dictionary is Austrian law, and therefore the German legal terms which have no equivalent in Austrian law have not been treated in detail. 

The English is described as based on English and Commonwealth law and was reviewed by Carmen Prodinger (Canberrra/Klagenfurt), hence I think the ‘circuit court’. 

The dictionary contains full details of the terminological entries, which contain definitions, sources, equivalents and in fact much more information than we usually get in a legal dictionary. At the back there is an alphabetical list in table form of German legal concepts with their Austrian counterparts, followed by a list of all the Austrian terms which lack a German equivalent. 

I think the dictionary will be extremely useful. It does contain some food vocabulary, not a big percentage though. 

4 thoughts on “Dictionary of differences Austrian and German law

  1. I gather that Landbutter means “farm butter” (since “land butter” is nonsense in English), but either way: what’s it doing in legal dictionary?
    Making everything greasy, undoubtedely!

  2. I wouldn’t like to come down too hard on it without knowing the book better. A lot of Austrian-German discussion has related to foodstuffs and EU definitions. I read that there are some Austrian farmers who would like to export Johannisbeermarmelade (?) not Ribislmarmelade. My problem is with the English translation. It is a type of butter made from unpasteurised milk and defined in legislation, and there is no direct German equivalent. So it is a term defined in law, but ‘countryside butter’ is not (as far as I know!). I also see no need for a translation of Landesgericht. But as I said, I have just skimmed it so I know nothing about the origin of the English and French translations.
    At the back of the book there is a long table of all the German terms to which there is an Austrian equivalent, in alphabetical order, and there is a shorter list of all the Austrian terms to which there is no German equivalent. I can’t see that many food terms.

  3. No doubt the Landesgericht – circuit vs. regional court being a mix- up with a circuit judge, Notarial or Bar Circuit/Circuit Barrister – is a country dish lovingly prepared with Landbutter (possibly a misprint for a handwritten entry like Lastenblatt?) obtained on a Butterfahrt, though unmentioned as an ‘Austrian term’ in Protocol no. 10 on use of specific Austrian (culinary) terms in the EU on the handout from Mag. Dr. Heidemarie Markhardt at the end of the memorable AIIC comparative Austrian-German law seminar held at the Translators’ and Interpreters’ Institute at Vienna Uni. at the start of July 1997. https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10007687

    Coincidentally, Sprengelrichter (eines Oberlandesgerichtssprengels) in Austria – dangerously close to Sprengstoffrichter (exploding judges) – seemed, at the seminar at which one of them gave a (non-violent) paper, to be one of the recurrent ’Circuit Judge’ terms causing much merriment to those of us weaned on German law.

    • I’ve added more detail to the entry. I am sorry if my reference to two English terms that struck me on a first read-through has given commenters here the impression that it is a silly dictionary or not an update on Heidemarie Markhardt’s work of some years ago.
      Thanks for the link. Those terms will be in there.
      I’ve written about Heidemarie Markwardt before. She also kindly gave me a copy of her 2005 book Das Österreichische Deutsch im Rahmen der EU – the editor of the series include Rudolf Muhr, the co-author of this new (2015) dictionary.

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