LEGAL PRINCIPLE: CIVIL PROCEDURE – Res Judicata – Distinction Between Cause of Action Estoppel and Issue Estoppel
PRINCIPLE STATEMENT
Cause of action estoppel prevents another suit founded on the same cause of action; issue estoppel prevents certain issues decided in the original action from arising again in subsequent proceedings based on a different cause of action.
RATIO DECIDENDI (SOURCE)
Per Ayoola, JSC, in Adone & Anor v. Ikebudu & Ors (2001) NLC-1401996(SC) at p. 8; Paras A–C.
"The classification of estoppels under estoppel by judgment is related to the purpose for which the judgment is used. If it is intended to be used to prevent another suit founded on the same cause of action as the original suit, the decision in the original action is said to constitute res judicata. If, on the other hand, the subsequent proceedings are based on a different cause of action ... issue estoppel can operate only to prevent certain issues which were decided in the original action from arising for further consideration by the court."
EXPLANATION / SCOPE
Cause of action estoppel (res judicata proper) bars relitigation of the entire claim when the same cause of action is pursued in subsequent proceedings. Issue estoppel applies where the cause of action differs, but a specific issue previously decided between the same parties is raised again. Issue estoppel prevents only that issue from being relitigated—not the entire claim. The distinction is critical for determining the scope of the estoppel. Cause of action estoppel is broader; issue estoppel is narrower. Both promote finality but operate differently. The classification depends on whether the subsequent proceedings share the same cause of action or merely raise a previously decided issue.
