__Fair dealing__ is a Limitations and exceptions to copyright to the exclusive right granted by copyright law to the author of a creative work. Fair dealing is found in many of the common law jurisdictions of the Commonwealth of Nations - wikipedia 
Fair dealing is an enumerated set of possible defences against an action for infringement of an exclusive right of copyright.
Unlike the related United States doctrine of fair use, fair dealing cannot apply to any act which does not fall within one of these categories, although common law courts in some jurisdictions are less stringent than others in this regard.
In practice, however, such courts might rule that actions with a commercial character, which might be naïvely assumed to fall into one of these categories, were in fact infringements of copyright, as fair dealing is not as flexible a concept as the American concept of fair use.
- Fair dealing in the UK - Fair dealing in Singapore - Fair dealing in India - Fair dealing in Canada
# Comparison with Fair Use
While fair use is a broad and flexible principle in U.S. law, **fair dealing** (used in the UK, Canada, Australia, and other Commonwealth countries) is narrower and more prescriptive.
| Aspect | Fair Use (US) | Fair Dealing (UK/Canada) |
|--------|----------------|--------------------------|
| Legal Source | U.S. Copyright Act §107 | UK Copyright, Designs and Patents Act 1988 |
| Structure | Open-ended, case-by-case | Closed list of specific permitted purposes |
| Key Criterion | Transformative use and market impact | Use must fall within allowed purposes (e.g. criticism, review, news reporting, research, parody) |
| Flexibility | High — adaptable to new media | Moderate — depends on legislative updates |
Fair dealing allows certain uses similar to fair use but lacks the broader transformative test that U.S. courts apply.
- en.wikipedia.org
- gov.uk
# United States
The parallel concept in United States copyright law is fair use. The term "fair dealing" has a different meaning in the U.S. It is a duty of full disclosure imposed upon corporate officers, fiduciaries, and parties to contracts - wikipedia
In the reported cases, it usually arises in the context of the "implied covenant of good faith and fair dealing," which underlies the tort cause of action for insurance bad faith.
# See also