Unifying Legal Principles: Investigating The Role of Estoppel in Global Commercial Law and Contractual Relations

Abstract

The doctrine of estoppel serves as a critical mechanism for ensuring fairness and consistency in legal and contractual relations. This paper explores the role of estoppel within global commercial law, examining its application across different jurisdictions. By investigating commonalities and differences in the doctrine's application, the paper aims to highlight how estoppel functions to unify legal principles, promote justice, and foster predictable commercial interactions.  Through comparative analysis of case laws, statutes, legal literature, and interpretations, from common law and civil law jurisdictions, the study sought to identify pathways for greater coherence and predictability in the doctrine of estoppel, with the ultimate goal of proposing a unified framework that enhances legal clarity and coherence in global commercial law, thereby enhancing fairness and efficiency of cross-border contractual relations.