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Use of the term "notarised signature"?
When the word "notarised signature" is used, is this
a term that has been tested against the legal meaning
of the words?
Specifically, the term has quite different significances
under civil code and common law. In the civil code, a
notary is a very important person, perhaps more significant
than an attorney. He or she has to study for 6 years to
obtain their qualification, and it is a tightly constrained
field (at least in the country I'm mildly familiar with).
When a notary notarises a document in a civil law country,
he is inherently taking some view on the document. In
some cases, a notary refuses to participate on some
arbitrary grounds such as an unfamiliar document or a
person not within jurisdiction. Signatures also may be
meaningless unless notarised.
This seems to be in complete contrast to the common law
view, where only the signature is notarised and the signer
My question then would be, has anyone tested this notion
of implying a notary function with a civil law expert?
If not, as a minimum, it might be a good idea to add
a statement that the use of the term is not meant to
draw from the legal definition(s) of same.
Or, describe the feature as potentially providing a
feature useful for notaries, rather than calling it
The main issue here is that if someone does use OpenPGP's
new notarised signature form, will that imply an
unexpected legal meaning in the wrong country? I know
some countries are very jumpity about the misuse of
terms, and at least one big/rich country in particular
puts people in jail for misrepresenting their status.
(Apologies for jumping in late and briefly on this one.)