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In page Statute of frauds:

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Section 6[3] of the Statute of Frauds Amendment Act 1828[b] (9 Geo. 4. c .14) (commonly known as Lord Tenterden's Act)[4] was enacted to prevent Section 4 being circumvented by bringing an action against a verbal guarantor for the tort of deceit (the tort in Freeman v. Palsey).[5] A common summary of the law is "a verbal guarantee (for a debt) isn't worth the paper it is written on".[citation needed]