The Legal Profession In India

The modern legal profession in India has colonial roots, emerging with the advent of Mayor's Courts in Madras and Calcutta in 1726. However, it was not until 1846, through the Legal Practitioner's Act, that the doors of profession were thrown open to all those duly qualified, certified and of good character, irrespective of nationality or religion. Women were still excluded from the profession at this stage, to be thereafter admitted through the Legal Practitioner's (Women) Act, XXIII of 1923.

The legal profession in India, which includes both the practice of law as well as professional legal education, is regulated by the Advocates Act, 1961. The Bar Council of India (BCI) is envisaged under the Advocates Act as a body for regulating the minimum standards to be maintained by institutions imparting legal education in India. The reformation of legal education in India undertaken since the late 1980s at the initiative of the BCI, the University Grants Commission (UGC), the Law Commission of India and various state governments has led to the establishment of various national law schools in India in the last two decades. This movement which was pioneered by Professor N.R. Madhava Menon (who was instrumental in the setting up of the first National Law School in Bangalore) and other leading academicians in India has resulted in the establishment of around 17 national law schools and a few other new generation law schools in the public as well as the private sector.

India has the second largest population of lawyers in the world, second only to the United States.

History Of The Legal Profession in India
The timeline given below provides an overview of the history of the legal profession in India leading upto the enactment of the Advocates Act in 1961:

- 1726 and later, 1753: Mayor's Courts - There was no established legal profession until the establishment of the Mayor's Court. Those who practised law were devoid of legal training and some of the functionaries under the Mayor's courts were dismissed servants of the British East India Company.

- 1774: Supreme Court of Judicature established by a Royal Charter at Calcutta—Similar courts were established in Madras (1801) and Bombay (1823).
The Regulating Act of 1773 empowered the Supreme Court to 'approve, admit and enrol' Advocates and Attorneys-at-Law. 'Attorneys of Record' were authorized to 'appear, plead and act for the suitors'. Attorneys were not admitted without a recommendation from high officials in England or a Judge in India.

The term 'Advocate' at that time was extended only to the English and Irish Barristers and members of the Faculty of Advocates in Scotland. 'Attorneys' similarly referred to British attorneys and solicitors only. The Calcutta Supreme Court therefore appeared to be the exclusive bastion of British Barristers, Advocates and Attorneys. The Charter introduced in India the British system of legal practice and profession. Indians had no right to appear before the Supreme Courts (this trend continued in Bombay and Madras as well although both these courts were established much later).

- 1793: The Bengal Regulation VII of 1793 created for the first time, a regular legal profession in the Company's Courts. The Regulation was one 'for the appointment of vakils or native pleaders in the Courts of Civil Judicature (Sadar Diwani Adalat) in Bengal, Bihar and Orissa. Only Muslims and Hindus could be enrolled as pleaders. The Regulation also provided for a Vakalatnama (a party would execute a Vakalatnama in favour of a pleader, authorizing him to represent the party, and act on his behalf in a matter). This was the genesis of the 'Vakalatnama' as we know today. The Bengal Regulation XXVII of 1814 consolidated the law on the subject. The pleaders were empowered to act as arbitrators and to give legal opinions on payment of fees. Thereafter, in 1833, The Bengal Regulation XII modified the provisions of earlier regulations regarding selection, appointment and remuneration of these pleaders. It permitted any qualified persons of any nationality and religion to be enrolled as a pleader in the Sadar Diwani Adalat.

- 1846: The Legal Practitioners Act of 1846, was the first pan-India law concerning the regulation of the Indian legal profession. A religious test for enrolment as a pleader was abolished, and persons of any nationality and religion could be enrolled as a pleader. Every Barrister enrolled in any of Her Majesty's Courts in India became eligible to plead in the Sadar Adalats subject to the rules of those Courts applicable to pleaders as regards language or any other matter. The Legal Practitioners Act also permitted Vakils to enter into agreements with their clients for their fees for professional services. 

- 1879: The Legal Practitioners Act of 1879 repealed the Pleaders, Mukhtars and Revenue Agents Act, 1865. 
During this time in British India, there were six grades of practitioners - Advocates, Solicitors (Attorneys) and Vakils of the High Court and Pleaders, Mukhtars and Revenue agents in the lower courts. Vakils became a distinct grade above the Pleader. The Act brought all six grades of legal practitioners into one system.

- 1923: Barristers of England had come to occupy a predominant position in the legal profession. The Government of India in 1923 appointed the Indian Bar Committee, popularly known as the Chamier Committee to address the existing disparities in the Legal profession. It was chaired by Sir Edward Chamier, a retired Chief Justice of the Patna High Court. The Committee in its report stated that it was not practical at that time to organize the Bar on an all India basis. However, the Committee suggested the establishment of Bar Council for each of the High Courts. The Committee suggested that a Bar Council should have power to make rules in matters such as qualifications and admission of persons to be Advocates of the concerned High Court, legal education, discipline and professional conduct of Advocates, terms on which Advocates of another High Court could appear occasionally in the concerned High Court or any other matter prescribed by the High Court.

- 1926: Giving effect to the Chamier Committee recommendations, the Central Legislature enacted the Indian Bar Councils Act, 1926. The Act was to provide for the constitution and incorporation of Bar Councils, to confer powers and impose duties on the Bar Councils and to consolidate the regulations pertaining to the legal profession. The Bar Councils could, with the consent of the High Court, make rules for: (a) the rights and duties of Advocates of High Court and professional conduct; and (b) legal education and examinations. The Act eliminated the two grades of practitioners, the Vakils and the Pleaders by merging them in the class of Advocates who were 'entitled as of right to practice' in the High Court in which they were enrolled and in any other Court in British India, subject to certain exceptions. The High Courts occupied considerable influence in these matters and the Legal Practitioners Act, 1879 remained intact. Pleaders, Mukhtars etc. who were practicing in mofussil courts remained out of the scope of the Act.

Classification Of Lawyers: Roles And Functions
Legal practitioners in India were segregated into different categories under the British India. The following chart illustrates the different classes:
- Attorneys: Attorneys previously only referred to British attorneys or solicitors but now this definition is sometimes used to refer to advocates.
- Solicitors: Prior to the enactment of the Advocates Act, solicitors referred to British solicitors who were permitted to practise in the High Courts in pre-Independence India. Today, in the Bombay and Calcutta High Courts there is a separate class of legal practitioners, known as solicitors, who prepare the case, but do not argue in court.
- Barristers: Barristers of England had come to occupy a predominant position in the legal profession in the British India. On the Original Side of the Calcutta High Court, only Barristers could practice even though the distinction between Barristers and Vakils had been removed by other High Courts.
- Pleaders: Law graduates who did not possess the additional qualification for enrolment as vakil of the High Court and non-law graduates who could pass the pleadership examination held by the High Court were given certificates enabling them to act and plead as pleaders in the district and subordinate Courts. The pleaders had entry into the High Court only after gaining an experience of a certain number of years as pleaders. There were different grades of pleaders as well. This class of practitioners also does not exist today in Indian courts.

- Vakil: Vakils were native practitioners who were qualified to appear and practise in the High Courts of pre- Independence India. The Legal Practitioners
Act had laid down additional requirements for a law graduate to be eligible to qualify as a vakil. This class of practitioners does not exist now.
- Mukhtars: Mukhtars were another class of practitioners in the subordinate courts. They were persons who had after passing the Entrance Examination corresponding to the Matriculation Examination of the later times passed the Mukhtarship Examination held by the High Court. Although their sanads or licences permitted them to practice in all subordinate courts, they were by reason of the High Court Rules and Orders, mainly confined to acting and pleading in the criminal courts in the mofussil. These mukhtars were not permitted to plead in any subordinate civil court.
- Revenue Agents: Revenue Agents were certificated and enrolled under rules made by the Chief Controlling Revenue Authority under section 17 of the Legal Practitioners Act, 1879. Their practise was confined to revenue offices mentioned in their certificates and other offices subordinate to them.

- Advocates: Prior to the enactment of the Advocates Act, the term 'advocates' referred only to English and Irish barristers and members of the Faculty of Advocates in Scotland. This class was permitted to practise in the Supreme Court of Judicature in Bengal, to the exclusion of native practitioners. However, today this term is used to refer to lawyers qualified to practise in the Courts of India. An advocate is a person authorized to appear in a legal matter on behalf of a party. An advocate possesses a law degree and is enrolled with a Bar Council, as prescribed by the Advocates Act, 1961. Advocates are the only class of persons legally entitled to practice law or to provide legal advice. After being authorized to appear in a case by a client who has signed a vakalat, advocates prepare cases and argue them in Court. When appearing in a courtroom, an advocate usually dresses in black and white, and wears a band and gown.
Advocates will have to enrol with a state Bar Council.In addition to advocates, lawyers with special knowledge or ability are designated as Senior Advocates. A Senior Advocate, is an advocate who has been officially designated as such by either the Supreme Court or the High Court.

A Senior Advocate cannot file a vakalatnama, appear in the court without another advocate or advocate-on-record, cannot directly accept an engagement to appear in a case or draft pleadings. A Senior Advocate argues cases in court upon instructions from another advocate. Senior Advocates wear gowns that have flaps on the shoulders. An Advocate on Record (AOR) is an advocate who has passed a qualifying examination conducted by the Supreme Court. The examination is taken by an advocate who has been enrolled with a Bar Council for at least five years and has completed one year training with an AOR of not less than five years standing. Only an AOR can file a vakalat, a petition, an affidavit or any other application on behalf of a party in the Supreme Court. All the procedural aspects of a case are dealt with by the AOR, with the assistance of a registered clerk. It is the AOR's name that appears on the cause list.

The AOR is held accountable, by the Supreme Court, for the conduct of the case. Any notice and correspondence from the Supreme Court are sent to the AOR, and not to the party. AORs can argue matters, but frequently they serve in a solicitor like role.
Legal officers who act as advisors to the Central Government include the Attorney General of India, the Solicitor General of India and the Additional Solicitor General of India. The state government similarly has Advocate Generals. The office of the Attorney General for the Union of India and the Advocate General for the concerned States are Constitutional offices. The Constitution of India has also laid down the qualifications necessary for being considered for the position of the Attorney General and the Advocate General.

The Advocates Act, 1961
After the enactment of the Advocates Act, 1961 all the old categories of practitioners (vakils, barristers, pleaders of several grades, and mukhtars) were abolished and consolidated into a single category called 'advocates' who enjoy the right to practice in courts throughout India. The Advocates Act also established an All India Bar Council for the first time, with the Attorney-General and Solicitor General of India as ex-officio members of the Bar Council. The All India Bar Council has one member elected to it by each State Bar Council and it elects its own Chairman and Vice Chairman. The Act has created a State Bar Council in each State with the Advocate General of the State as an ex-officio member, and 15-25 Advocates elected for a period of five years. The State Council's main functions include: admitting law graduates on its Roll, determining cases of misconduct against Advocates on the Roll and organizing legal aid, among other functions. Application for enrolment is therefore made to the State Bar Council. The Bar Council of India regulates the content, syllabus, duration of the law degree, subject to which every University can lay down its own provisions. The Council has a Legal Education Committee for this purpose. State Council rules need to be approved by the Bar Council, however the Central Government has overriding power to make rules.In order to be eligible for enrolment, an Advocate must be: a citizen of India, at least 21 years of age and must have an LL.B degree from an Indian University. A foreign national may be enrolled on a reciprocal basis with the country of his citizenship, and his foreign degree may be recognized by the Council for the purpose. In the absence of such reciprocity, foreign nationals cannot practice law in India. The Council has released a list of foreign degrees that it recognizes. There is an additional requirement of an All India Bar Examination since 2010, which Advocates must clear in order to be able to start practice.
The Act recognizes only one class of practitioners, that is, Advocates. An Advocate on the State Rolls is entitled to practice as of right before any tribunal, or authority of India, or any court including the Supreme Court. Advocates have been classified as Senior Advocates and other Advocates.

The designation of an Advocate as a Senior Advocate is the responsibility of the Supreme Court or High Court based on the ability, experience and standing in the Bar of the Advocate in question. In 1977, the provisions relating to dual system (Advocates and Attorneys) in the Bombay and Calcutta High Courts were deleted. Any advocate enrolled in the State Rolls is entitled to practice in the Supreme Court. The Advocate-on-Record (AOR) is another category of Advocate in the Supreme Court.

The Bar Council Of India
The Bar Council of India was established by Parliament under the Advocates Act, 1961. It performs the regulatory function by prescribing standards of professional conduct and etiquette and by exercising disciplinary jurisdiction over the bar. It also sets standards for legal education and grants recognition to universities whose degree in law will serve as qualification for enrolment as an advocate.In addition, it performs certain representative functions by protecting the rights, privileges and interests of advocates and through the creation of funds for providing financial assistance to organise welfare. The regulatory and representative mandate of the Bar Council for the legal profession and legal education in India is reflected by its statutory functions which are as follows:
- To lay down standards of professional conduct and etiquette for advocates.
- To lay down procedure to be followed by its disciplinary committee and the disciplinary committees of each State Bar Council.
- To safeguard the rights, privileges and interests of advocates.
- To promote and support law reform.
- To deal with and dispose of any matter which may be referred to it by a State Bar Council.
- To promote legal education and to lay down standards of legal education. This is done in consultation with the universities in India imparting legal education and the State Bar Councils.
- To recognise universities whose degree in law shall be a qualification for enrolment as an advocate. The Bar Council of India visits and inspects universities, or directs the State Bar Councils to visit and inspect universities for this purpose.
- To conduct seminars and talks on legal topics by eminent jurists and publish journals and papers of legal interest.
- To organise legal aid to the poor.
- To recognise on a reciprocal basis, the foreign qualifications in law obtained outside India for the purpose of admission as an advocate in India.
- To manage and invest the funds of the Bar Council.
- To provide for the election of its members who shall run the Bar Council.

Lawyers And Professional Ethics
The Bar Council of India Rules encompass professional standards for lawyers, as laid down by the Bar Council.

The key duties and responsibilities of an Advocate can be summarised as follows:

Professional Duties of an Advocate

An Advocate has a duty to act in a dignified manner, to respect the court, not to communicate with a judge in private and impair impartiality, not to act in an illegal manner towards the opposition, to refuse to represent clients who insist on adopting unfair means. In addition, being an office of the court, an advocate is expected to uphold and maintain the values of the profession.
Furthermore, an advocate's duty towards the client include being bound to accept briefs, not to withdraw from service, not to appear in matters where he/she is a witness, not to suppress material or evidence. An advocate also had to maintain client confidentiality and not to instigate litigation or to charge contingency fee (fee depending on success or favourable result of matters). There is a general duty to ensure that his/her duties do not conflict with the client's interests. An Advocate is also expected not to negotiate directly with the opposing party (only through the opposing advocate) and to carry out legitimate promises made. Breach of these rules and standards of conduct lead to disciplinary action against advocates which may result in suspension or debarment.

Advertising By Lawyers
The right of advocates to advertise their services or solicit clients has been a controversial issue in the field of legal ethics and professionalism. In India advertising by lawyers has been strictly restricted by the Bar Council of India. An advocate is prohibited from promoting himself through circulars, advertisements, touts, personal communications, interviews other than through personal relations, furnishing or inspiring newspaper comments or producing his photographs to be published in connection with cases in which he has been engaged or concerned. An amendment to this rule allows advocates to furnish certain information on their websites after intimating and taking approval from the Bar Council of India. However, only 5 pieces of information can be put up on the internet, i.e., (i) the name of the advocate or the firm, (ii) the contact details, (iii) details of enrolment with the Bar, (iv) his professional and academic qualification and (v) the areas of practice. However, different countries across the world allow advertising by lawyers to varying degrees. The position in the USA is different from that in India, where lawyers have a right to advertise but subject to reasonable restrictions. There are different rules of professional ethics for different states and there is also the Model Rules of Professional Conduct which serves as an indicative reference point. Rule 7.1 of the Model Rules prohibits false and misleading communication about services, rule 7.2 addresses advertising and referrals, rule 7.3 articulates no-solicitation periods (e.g., families and victims of mass disasters are off limits for 30-45 days). Lawyers in the US can provide information about class actions, can approach clients by handing out business cards and can advertise on internet forums. For class actions, solicitation through referrals is permissible, newspaper and magazine ads and even mass emails are permitted as long as they are not misleading, and no financial incentive is promised.

Personal injury ads are commonplace in the USA. Often known as 'ambulance chasers', these personal injury lawyers are robust in their advertising — on billboards, newspapers, flyers, and even distasteful ads on the television. However, ambulance chasing is not representative of professional practice in India since these class of lawyers are the sort who solicit business by lurking around hospitals or by ads in newspapers and in Yellow Pages with toll free numbers and 'free' consultations. However, it is a matter of debate whether the Victorian tradition (UK has itself done away with the prohibition) should be retained within which law was considered to be a noble profession and hence advertising was prohibited so as to not tarnish the image of lawyers.

The issue of allowing advertising and solicitation by lawyers requires balancing the interest of the public which includes getting information on legal rights and services through advertisements and enhancement of access to justice and the legal profession on one hand and the possible misuse of advertising techniques by lawyers which may lead to a loss of credibility of the profession as a whole. Countries like USA, UK and France are more flexible with granting permission for legal ads whereas Hong Kong, Singapore and Malaysia are moving towards progressive relaxation. In Malaysia, for example, the Legal Profession (Publicity Rules), 2001, is a simple, comprehensive code that regulates ads in legal and non-legal directories, controls publication of journals, magazines, brochures and newsletters and interviews in the media, bars publicity through clients and even regulates greeting cards. In Hong Kong, lawyers are forbidden to advertise on television, radio and in the cinemas but are permitted to advertise in print media.

Opportunities For Law Graduates
Law is an exciting and challenging profession. Law graduates in India have various options and opportunities open to them after their graduation. A law degree, in addition to being a professional degree, is now considered to be training in a discipline which trains the mind to think analytically and communicate systematically. Following are some of the opportunities available (and opted for by law graduates) to graduates after they obtain their degrees in law.

Legal Education In India
Legal education in India is regulated by the Bar Council of India. There are two ways to obtain a degree to practice law and enrol with the Bar Council: (1) a 3-year LL.B. program which requires a prior undergraduate degree and (2) a 5-year integrated B.A., LL.B./BBA., LL.B./B.Sc., LL.B program which commences immediately after secondary school. Some universities offer both the five-year and the three-year degree programs. In 1987, the first National Law School — National Law School of India University (NLSIU) was set up in Bangalore. Its establishment marked the beginning of the reform of legal education in India. There are now 23 National Law Schools in India, with more being planned. 22 of these now have a common entrance test — CLAT (Common Law Admission Test) which tests logical reasoning, legal reasoning, English and comprehension, legal knowledge and general knowledge. Preparatory institutes for law entrances have also been set up such as the Law School Tutorials (LST).
National Law School University, Delhi conducts a separate entrance test called the AILET — All India Law Entrance Test, while a number of others law schools in India have adopted the Law School Admission Test (LSAT) conducted by the Law School Admission Council (LSAC), US A. Some other institutions conduct their own separate entrance tests.

- Litigation: Graduates may practice as an advocate in a court of law. This can be achieved by working under experienced advocates or being attached to litigation departments of law firms or companies in order to practice in the Courts of India.
- Law Firm Practice: Law firms vary in size and practice areas. Law firms may range from boutique law firms specializing in specific areas of law (such as Intellectual Property Rights and Tax law), to midsized law firms as well as large law firms which are full service law firms with different practice groups such as general corporate, mergers and acquisitions, employment law, taxation, international trade, insurance, intellectual property, and project finance and infrastructure. Transactional law at law firms typically involves practicing in commercial and economic laws and advising on issues pertaining to a commercial transaction between two or parties. This would usually include advising on the laws applicable to the transaction, drafting contracts and other documents and helping clients with the commercial negotiations and the management and execution (i.e., successful completion) of the transaction. Corporate lawyers would also advise on regulatory issues and legal compliance. Centres for Legal Process Outsourcing (LPOs) also have a lot of transnational transactional work.
- Corporate Sector: Large corporations often have an in-house legal practice. An in-house counsel will give legal advice to the company, have expertise in the business of the company and be responsible for ensuring that the business of the company is being run in compliance with applicable laws and when required will bring in external lawyers. Several organisations such as commercial banks, multinational companies, investment firms, insurance companies, e-commerce ventures, media houses are hiring law graduates for managing their legal departments.
- Public Policy: Lawyers have an important role in formulating and advising on public policy. Several organizations employ law graduates for policy making and have institutionalized fellowships where law graduates can be Research Assistants. For example, a law graduate interested in public policy can apply to serve as a Legislative Assistant under the Legislative Assistants to Members of Parliament (LAMP) Fellowship programme run by PRS Legislative Research. Institutions such as Competition Commission of India and Securities Exchange Board of India also employ law graduates for policy making in the respective fields. Law firms have established Government Policy Departments where they employ law graduates for policy research.
- Legal Research and Academia: Graduates may attach themselves with Research Centres and think tanks.
Law graduates may take up teaching and research as a profession. At least a post graduate degree in Law or related disciplines is expected to build a career in academics. Universities employ postgraduates in law as Lecturers/Assistant Professors at the beginning of their careers. Short term positions and opportunities as Visiting Professors/Adjunct Professors are also available in academia.
- Non-governmental Organizations: Not-for-profit organizations, especially organizations with a social justice orientation have positions for law graduates.
These range from small grassroot level organizations to large well-funded organizations. They may be general in nature providing free legal aid, legal education and legal awareness to more specialist organizations involved in areas such as women and child right, environmental law, employment laws, consumer rights and public health.
- Government Institutions: Government departments, statutory authorities, public sector undertaking and regulatory bodies also provide interesting opportunities to lawyers. Graduates may opt for jobs in the government sector in institutions such as National
Human Rights Commission, Law Commission of India, and National Commission for Women etc.
- Further study: Law is an interdisciplinary subject and graduates may opt for further studies in related disciplines such as Business, Economics, Anthropology and Sociology. Traditionally, law graduates pursue Master of Laws (LL.M) degree followed by research degrees such as M.Phil or Ph.D. A variety of opportunities are available in India and abroad for advanced studies in law.
- Judicial Services/Clerkships: The court system provides several avenues to law graduates. The higher judiciary, that is judges of the High Courts and Supreme Courts have law clerks cum research assistants who assists a judge in researching for cases, maintaining paperwork etc. Judicial clerks often sit in court hearings with the judges. Graduates may write the All India Judicial Services Examination to avail of positions in the Indian Judiciary. Qualifying candidates start in subordinate courts and may then progress to hold offices in the High Courts and even the Supreme Court of India.
- Other avenues: Law graduates may opt for different career paths such as politics, journalism (legal journalism at places such as Bar and Bench and Legally India as well as in media houses), Legal publishing, Fellowships (such as the Teach for India Fellowship), civil services etc.

Liberalization Of The Legal Profession
There is an ongoing debate about the issue of liberalization of legal service sector in a growing economy. Given that India had signed the WTO Treaty in the 1990s leading to economic liberalization, it is also expected to liberalize the legal services sector under the GATS (General Agreement on Trade and Services) and services negotiations under various free trade agreements/economic partnership agreements.

The Bar Council of India has consistently passed several resolutions between 2002 and 2007 opposing the opening up of the Indian legal profession to foreign lawyers or foreign law firms. In 2011, in a judgment delivered by the Bombay High Court on a public interest litigation (PIL) was filed by Lawyer's Collective, a non-profit organization, the High Court held that foreign law firms could not be permitted to set up liaison offices in India. Contrary to this position, the Madras High Court, in response to a PIL filed by A.K. Balaji, permitted foreign lawyers to practice in India on a 'fly in and fly out' basis. The Law Commission of India, in a working paper in 1999, raised pertinent issues and concerns Legal Studies 91 while recommending amendments to the Advocates Act to prepare a level-playing field for Indian lawyers. There is no resolution in sight regarding this issue.

Globalization Of Legal Profession
As globalization increases the flow of people and information across borders, there are increasing opportunities for trained lawyers. Typically, the opportunities are available in Common Law based jurisdictions such as the United States and the United Kingdom and to an extent Australia and Canada.

However, unlike many other professions, lawyers trained and licensed in one jurisdiction may not be licensed to practice in other jurisdictions. Lawyers trained in other jurisdictions will have to requalify in order to practice in the foreign jurisdictions. Given the globalisation of legal profession, a number of lawyers have dual qualifications.

Women And The Legal Professionin India
Legal practice in India, as in most other countries, is a male dominated profession. In 1916, the Calcutta High Court, and in 1922, the Patna High Court had held that women otherwise qualified were not entitled to be enrolled as Vakil or Pleader.In the Patna High Court case, Ms. Hazra, the petitioner, secured a B.L. degree from Calcutta University. She was refused enrolment as a Pleader. She challenged this in the High Court of Patna. The Court rules that the sections of the Legal Practitioner's Act referred to males and not females.

Since 1793, no woman had ever been admitted to the roll of pleaders. To remove doubts about the eligibility of women to be enrolled and to practise as legal practitioners, the Legal Practitioners (Women) Act, XXIII of 1923, was enacted to expressly provide that no woman would by reason only of her sex disqualified from being admitted or enrolled as a legal practitioner or from practising as such.

The Allahabad High Court took the lead by enrolling Ms. Cornelia Sorabji as the first Indian lady Vakil of Allahabad High Court on 24 August, 1921 by a decision of the English Committee of the Court (as the Administrative Committee was then called), consisting of Chief Justice Sir Grim Wood Meers. Since then, although the number of women entering into the profession has increased gender bias still pervades the profession. A recent survey found that the percentage of successful women candidates for the Common Law Admission2 Test was 47%, however 36% of women lawyer in another survey stated that they had faced some sort of gender bias at work. There have been only 5 women Senior Advocates since 1962 of the 397 designated Senior Advocates. However, recent studies have indicated that genderbased disadvantages are gradually being eliminated, especially in the corporate law sector.