Cultural anisomorphism and variation in legal translation. The case of the person accused in France, Spain and Chile

This work aims to link two phenomena that are very present in legal translation: cultural anisomorphism (i.e. cultural asymmetry) and linguistic variation. In fact, law is a discipline strongly linked to a society, which means that it has a national character where, consequently, concepts will rarely cross borders. Moreover, while this national character of law is quite noticeable in two cultures with distinct languages, such as France and Spain, it is also present in legal cultures that have the same official language, like Chile and Spain. The translation of a French legal terms into Spanish will vary depending on the target country (Spain, Chile, Mexico, etc.). Thus, in order to proof his reality, in this work, a general concept such as personne mise en cause will be analysed differently in France, Spain, and Chile. We will therefore be looking at how the materialisation that these countries make of this general concept gives rise to cultural anisomorphisms and problems related to linguistic variation (more precisely, geographical variation) in the Spanish-speaking countries that are the subject of this study.