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A solicitor is a lawyer who traditionally deals with most of the legal matters in some jurisdictions. A person must have legally defined qualifications, which vary from one jurisdiction to another, to be described as a solicitor and enabled to practise there as such. For example, in England and Wales a solicitor is admitted to practise under the provisions of the Solicitors Act 1974. With some exceptions, practising solicitors must possess a practising certificate. There are many more solicitors than barristers in England; they undertake the general aspects of giving legal advice and conducting legal proceedings. In the jurisdictions of England and Wales and in Northern Ireland, in the Australian states of New South Wales, Victoria, and Queensland, Hong Kong, South Africa (where they are called attorneys) and the Republic of Ireland, the legal profession is split between solicitors and barristers (called advocates in some countries, for example Scotland), and a lawyer will usually only hold one of the two titles. However, in Canada, Malaysia, New Zealand, Singapore and the remaining Australian states and territories, the legal profession is now for practical purposes "fused", allowing lawyers to hold the title of "barrister and solicitor" and practise as both. Some legal graduates will start off as one and then also qualify as the other. In the United States, the barrister–solicitor distinction never existed.