A creditor who chooses to use court proceedings for debt recovery needs a lawyer. In Germany this is a legal requirement: proceedings in the civil courts of general jurisdiction (Landgerichte) and in the courts of higher instance can only be commenced and further conducted by a lawyer admitted to practise in the relevant district and court instance. Parties must accordingly be represented by an advocate before the relevant court (Anwaltszwang, compulsory representation by an advocate). 1 In Turkey 2 and in England 3 a litigant may represent himself in any court and, in the latter, may even be assisted by a friend. 4 In practice however it is unusual even in these countries for a non-lawyer to appear before the court without being represented by counsel.