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Promissory Estoppel

/prəˈmɪsəri ɪˈstɒpəl/

Legal Doctrine / Equitable Principle

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Definition

A doctrine that prevents a party from going back on a clear and unambiguous promise where the promisee has relied on that promise to their detriment. Even without formal consideration (the technical requirement of contract formation), a promisor will be held to their promise if the promisee changed their position in reliance on it. In India it is applied against the government where it would otherwise exercise its rights contrary to equity.

Etymology

Legal term with origins in Latin, Anglo-French, or Old English legal tradition, later codified in Indian law.

Examples

A government promises a company a tax exemption to set up a factory; the company invests crores on that basis. When the government tries to revoke the exemption, promissory estoppel prevents it.
A landlord who promises a tenant they need not pay rent during a difficult period cannot later sue for arrears for that period if the tenant relied on the promise.

Case Study

The leading Indian case is Union of India v. Anglo Afghan Agencies (1968), where a government circular promising export incentives was later withdrawn. The Supreme Court held that the government was estopped from going back on its representation to exporters who had acted in reliance. Justice Shah held that in India, unlike in England, promissory estoppel can be used as a sword (cause of action) not just a shield.

Key Cases

Union of India v. Anglo Afghan Agencies

1968

AIR 1968 SC 718

The foundational Indian authority on promissory estoppel against the government. Held that the government cannot resile from a representation that induced parties to act to their detriment. Promissory estoppel can be a cause of action in India.

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M.P. Sugar Mills v. State of U.P.

1979

AIR 1979 SC 621

Extended promissory estoppel to government policy commitments. Held that where government representation induces industry to invest, the government is bound by the representation unless overriding public interest demands departure — and even then compensation may be payable.

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Central London Property Trust v. High Trees House

1947

[1947] KB 130

Lord Denning's foundational promissory estoppel case. A landlord who promised reduced rent during wartime was estopped from claiming the full amount for the duration of the promise.

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Also Known As

equitable estoppel

Synonyms

equitable estoppelestoppel by representationdetrimental reliance doctrine

Antonyms / Opposites

breach of promise without reliancedetrimental reliance absent

Related Terms

estoppelconsiderationlegitimate expectationdetrimental relianceequitySection 115 Evidence Act

Dictionary Entry

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