Estoppel
From Common law
Procedure and evidenceContract and obligations
What it means
Estoppel stops a person from going back on something they said or did when another person has relied on it. It comes in several kinds, including promissory estoppel and estoppel by representation.
Why it travels badly
Civil-law systems reach similar results through general good-faith rules and doctrines against contradictory conduct, not through a named doctrine called estoppel.
How other systems say it
Verwirkung / widersprüchliches Verhalten
Forfeiture of a right by long inaction, and the ban on contradictory behaviour, both based on good faith.
doctrina de los actos propios
No one may act against their own earlier conduct, if others relied on it.
interdiction de se contredire au détriment d'autrui
A principle developed by the courts; it is not a named doctrine of the Civil Code.
Tip for translators and students
Keep 'estoppel' for common-law contexts and describe the civil-law rule by its own name, noting that it is similar in effect.
Related: Good faith, Equity
Updated October 2026. Spotted a mistake? Tell us.
TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.
