Book excerpt: Fair use and fair dealing are the most used exceptions to copyright. They are common denominators in national copyright legislations. Whereas they developed from the common law fair use doctrine, both exceptions have different implications in modern times. While the fair use variant is seen as open-ended and more flexible, the fair dealing variant is regarded as close-ended and inflexible. The fair dealing variant is adopted in Nigeria and South Africa. Both countries are reviewing their respective copyright Acts and copyright exceptions and limitations, including fair dealing provisions, are among the subjects of such review. One key challenge for law makers in both countries, is how best to frame the exceptions and limitation, especially the fair dealing provisions in order to achieve an equitable balance between the interest of copyright owners and the need to promote creativity. In modern times, the fair use variant is widely regarded as more effective in striking the required balance between the interest of copyright owners and the public interest. Thus, while reflecting on the fair dealing provisions in the extant copyright Acts in Nigeria and South Africa, this paper reviewed the proposed amendments to determine whether they are adequate to ensure such balance. To this end, the paper compares the proposed amendments with the fair use and fair dealing provisions in other common law jurisdictions.