reflecting on the nature of withdrawal right in the electronic contracts

in most legal systems, the right to cancel the contract is provided for consumer in electronic contracts with slight variations. in article 6 of the european :union: directives on the protection of consumers in respect of distance contracts, such right is provided too. article 37 of iranian ec code considered for the right of withdrawal is very close to the above terms. there is a controversy about the nature of this right between the authors. the dominant approach considers it as a new legal cancellation right. it seems that despite the apparent similarity, the right of withdrawal in these two, is fundamentally different. article 37 unlike its european equivalent, obligates the supplier to provide the withdrawal right for the consumer in the contract not any establishment of the right of rescission for the consumer.