| Summary: | The law on unfair contract terms affecting small businesses have been regulated differently in different countries. Some countries provide statutory protection as a means of protection towards small businesses and adopt legislative approach in dealing with unfair terms, such as Australia and the United Kingdom, while some countries such as Malaysia, only rely on legal doctrines and judicial approach. These differences called for a comparative study to be done to analyses critically whether small businesses need to be protected against unfair contract terms. For the purpose of this research, three countries are selected as a comparative model, which were Malaysia, Australia and the United Kingdom.
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