Meaning and Legal Basis
Estoppel, governed by Section 115 of the Indian Evidence Act, 1872, prevents a person from denying or contradicting a statement, representation, or conduct that another person has relied upon. It ensures fairness by stopping individuals from taking inconsistent positions that would harm others. Estoppel acts as a rule of evidence, not as a substantive cause of action, and operates to maintain honesty and good faith in legal relationships. For estoppel to apply, there must be an intentional representation of fact, reliance by the other party, and a resulting change of position. Once these conditions are satisfied, the person making the representation cannot later deny it, thereby promoting certainty and trust in transactions.
Essentials and Scope of Application
For estoppel to apply under Section 115, three essentials must be present: (1) A clear representation or conduct by one party about an existing fact; (2) Reliance by the other party; and (3) A resulting change of position that would cause detriment if the truth is denied. Estoppel may arise through words, actions, omissions, or documents such as deeds. Courts also apply promissory estoppel as an equitable doctrine, even though it is not expressly mentioned in the Evidence Act. However, estoppel cannot operate against statutory provisions, government sovereign functions, or minors who lack legal capacity. It also cannot validate illegality, contradict law, or operate on matters of pure law or future promises.
Types and Limitations
The doctrine appears in various forms: estoppel by representation, conduct, silence, deed, and record. Estoppel by representation is the most common, preventing a party from disputing facts they previously represented. Estoppel by deed arises through statements made in formal documents, while estoppel by record is similar to res judicata and binds parties to judicial determinations. Courts also recognize promissory estoppel, as seen in Motilal Padampat Sugar Mills v. State of Uttar Pradesh, where government promises can be enforced to prevent injustice. Despite its wide scope, estoppel has strict limits: it cannot override statutory law, create rights that are illegal, expand jurisdiction, or operate against minors or future intentions. It must relate to existing facts only.
Real-Time Example
A, the actual owner of a plot, tells B that the land belongs to C. Trusting A’s statement, B purchases the land from C after confirming the claim. Later, A asserts that he is the real owner and attempts to reclaim the property from B. Under Section 115, A is estopped from denying his earlier representation because B relied on it and changed his position by investing money. Allowing A to deny the earlier statement would cause injustice and financial loss to B. Thus, the doctrine of estoppel protects B and prevents A from shifting positions, ensuring fairness and consistency in property transactions and other legal dealings.
Mnemonic to Remember
A useful mnemonic for ESTOPPEL is “RRL–CP–PCL”:
R – Representation made
R – Reliance by the other party
L – Loss or change of position
C – Conduct or silence can create estoppel
P – Past or existing facts only
P – Promissory estoppel is separate
C – Cannot override statutory law
L – Limitations: minors, illegality, future promises
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