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Marta Sánchez Merino talks to Legal Women about her dual qualification journey
The different jurisdictions that I am qualified in
I am qualified in both Spain and England and Wales. This was particularly challenging because Spain is a civil law jurisdiction, while England and Wales is a common law jurisdiction. Think of civil law as following a detailed manual, as the law is mostly written down in codes (civil code, criminal code, etc.). Common law is more like building on a collection of past decisions based on precedent. That said, written laws (statutes) still come first in the UK, based on the principle of Parliamentary Sovereignty.
My dual qualification journey
Some careers are planned; others unfold naturally. To be completely honest, I don’t know if I chose the international legal path or if it chose me.
To become an international lawyer, it’s clear that you need to show both genuine interest in how others think and empathy to get what they really mean. I’ve always been fascinated by languages — probably because I grew up in a home where their importance was clear. So, in the end, I guess one only becomes a refined version of what one is.
I studied law, but because I was drawn to the international element, I ended up making decisions that ultimately led to me moving to London in 2020.
Before that, I had spent several years training for a judge position in Spain — a demanding process that requires full-time study and dedication for years. So when the pandemic brought everything to a halt and all exams were paused for an uncertain period, it became the beginning of something entirely new! Looking back, I suppose it happened the way it was really meant to be.
Once in London, even though my thinking was very much shaped by civil law, I began to realise that other legal realities were possible. And in time I also started to develop a genuine interest in the common law system.
After years of practising in the cross-border company, commercial, and insolvency field, dual qualification felt like the next natural step. So I began preparing for the Solicitors Qualifying Examination (SQE). Yes — while working full-time!
That meant a lot of early mornings and late nights, but it was absolutely worth it. Because in the process, I gained not just knowledge, but the skills to become a more well-rounded lawyer.
Similarities and Differences between the two jurisdictions legal systems
Both civil and common law systems share important foundations. They are based on the rule of law and the separation of powers. Also, access to justice and due process are core principles in both traditions, and lawyers from both systems must go through a very rigorous training before qualifying.
However, there are also significant differences. For example, in Spain, as well as in France, Germany, Italy, Portugal, and most of Latin America and Eastern Europe, the common law notion of equity is often confusing, which leads to misunderstandings around institutions such as Trusts.
On the other hand, in the United Kingdom (UK), United States (US), Canada, Australia, India, and Hong Kong, lawyers may find legal codes a bit limiting when trying to reach the best possible solution in a given case. However, codes do provide clients with a more reassuring legal framework, giving them a better idea of what to expect.
These differences shape the way we, as lawyers, practise across borders. In fact, we might find that a lawyer in a common law jurisdiction can have a broader impact through their work, potentially even changing the law itself. So, while as a client, you might prefer the certainty and possibly lower costs of a civil law system, as a lawyer, you may value the freedom and influence that a common law jurisdiction offers, particularly in terms of moral authority and legal creativity.
There are advantages and disadvantages, but both systems can work together and learn from each other. That’s one of the reasons I love being dual-qualified. It’s like speaking several legal languages, which can only broaden your perspective and sharpen your judgment!
But as I always say, it doesn’t all come down to the laws... There’s also — and above everything else — the culture. Law is shaped by social standards and always reverts back to the cultural context from which it emerged. This is an idea I’ve been dedicating quite a bit of time to raising awareness about — as a speaker, in roundtables, and at every opportunity I’ve had to share my opinion — because I firmly believe that there is no such thing as international law without cultural awareness.
Advice to those considering dual qualification
The way I see it, qualifying in multiple jurisdictions is essential for becoming a truly international lawyer. It’s not just about the title, but about gaining a deep understanding of different legal systems and how they interact. So for those considering it, I’d say: go for it!
While preparing for my SQE, I remember thinking: “Worst case scenario, I don’t pass — but all this knowledge will stick with me, so I’m gaining either way.” However, the truth is, when you’re fully invested in something, it’s just a matter of when, not if, you’ll get there. So I passed!
That said, it’s important to approach it with a clear strategy — so your time, energy, and money are well invested!
If you want to know more about dual qualification or how a dual qualified lawyer can help you, I’m always happy to share my experience — just reach out!
Marta Sánchez Merino
Abogado | Spain
Solicitor | England and Wales
https://www.linkedin.com/in/martasanchezmerino/