Importantly, the UK approach in the Sillitoe 48 and the University of London Press
cases 49 specifies that the fair dealing exception for private study will only cover the private
study of a person dealing with the copyright works for his own personal purpose and does not
extend to the third parties who produce copyright materials for the public for the purpose of
others’ private study or for sale to students. 50 This approach can be adapted to solve the issue
with respect to the photocopy shops in Thailand. This issue can be resolved if the Thai
Government follows the UK approach by limiting the capability of third parties or photocopy
shops to make multiple reproductions or copy entire textbooks for sale to the students, and by
inserting a clear limitation as to the amount of reproduction, and a clear prohibition on multiple
reproductions, into the educational exceptions.