How do legal systems differ in balancing a lawyer’s duty to a client against a duty to justice?

Legal systems balance a lawyer’s duty to a client against their duty to justice based on the underlying premises of their legal tradition.1

In democratic countries with common law traditions, such as the United States, lawyers are viewed as "officers of the court" who hold a dual responsibility: they must advocate zealously for their client's private interests while simultaneously upholding the integrity of the legal system. In this adversary procedure, the lawyer is expected to present the client’s case in the most favorable light permitted by law, provided they do not misrepresent facts or the law.123

Conversely, other systems may prioritize a lawyer’s duty to the state to ensure the proper administration of justice. In these jurisdictions, the conception of the lawyer’s role may shift, sometimes requiring the disclosure of information if it is deemed to be to the state’s advantage. Furthermore, while confidential communications are generally protected across many systems, the specific scope of this privilege—and whether it serves the client or the legal process—varies significantly between Anglo-American and continental European practices.145