Estoppel is a legal concept in common law which does not have exact equivalents in civil law systems. The Black’s Law Dictionary defines it as: “1. a bar that prevents one from asserting a claim or right that contradicts what one has said or done before or what has been legally established as true; 2. a bar that prevents the relitigating of issues; 3. an affirmative defense alleging good faith reliance on a misleading representation and an injury or detrimental change in position resulting from that reliance”.
Due to its plurality of meanings, it is difficult to translate it with a single similar word from the realm of civil law: in fact, as this notion does not exist in civil law, the term estoppel is almost impossible to translate.
In French, for example, it could be roughly translated as “fin de non-recevoir”. However, the French case-law has introduced the concept into the French legal system without translating the word (c.f., Cass Civ 1, 6 July 2005, Revue de l’arbitrage, 2005, p. 993,).
In continental law systems, the Latin expression “exceptio doli” can be closely related to one of the meanings of estoppel.
In Italy, depending on the context, the words “preclusione” or “acquiescenza” can sometimes be a reasonably correct translation of “estoppel”.