Legal documents for most countries when signed outside the jurisdiction usually have to be notarised. This means that the documents have to be signed by the person named in the deed in the presence of a notary appointed by the Court or by Royal Authority. When the notary is satisfied that the person signing is person named in the deed and that he or she understands the nature of the document and the legal implications thereof, he will witness the signatures and affix his own signature and Seal of Office.

In some cases the documents are in a language other than English but it is possible that the English notary will still witness these documents if he is satisfied that there is a valid translation annexed to the deed that is understood by the person signing. In exceptional cases he may be satisfied to fix his seal of office and signature on documents in a foreign language if he is fully satisfied that the person signing is conversant with the language of the document.

But if the person signing does not understand the foreign language of the document and there is no English translation attached to it, then it is necessary for the document to be translated by an official legal translator who will then have to sign a statutory declaration certifying that it is a true translation and this declaration itself will have to be witnessed by the notary and sealed.

Many countries require notarised documents to be legalised also. The reason for this is that it is a double check that the notary’s signature is genuine. For example, the person signing the document has his identity checked by the notary and the notary will also check that the person signing understands the document but what if the notary's signature is fraudulent? Legalisation is a double check to make sure that the notary signature is genuine and recognised and this is done by government departments and embassies. Documents are checked by foreign embassies to make sure that the notary's signature matches the one on their records. There was Hague Convention in 1961 which attempted to make the process of legalisation easier. The idea was that instead of going round various different embassies in London to have a document legalised, the process would be centralised by the Foreign and Commonwealth Office which would legalise documents affixing a piece of paper after checking. This piece of paper is called an "Apostille".

Unfortunately this piece of labour-saving legislation has been somewhat undermined. The idea of the legislation was to make it necessary only to go to one place to have the document legalised but some countries now require documents legalised at the Foreign and Commonwealth Office to be legalised at their own embassies as well. This doubles up the work involved. Certain embassies such as India will legalise documents even though they have not been to the Foreign and Commonwealth Office. Certain countries (and Bulgaria it is one of them) seem to require documents to be legalised at the Foreign office and at the Bulgaria embassy as well. This practice is not widespread however and in most cases it is sufficient for the document simply to go to the Foreign and Commonwealth Office for an Apostille after the notary has notarised the document.

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