LEGAL PRINCIPLE: EVIDENCE LAW – Estoppel – Admissions of Liability – Effect of Unequivocal Written Admissions
PRINCIPLE STATEMENT
Certainly, it will be inequitable for anyone, such as the respondent herein to enjoy the liberty of making statements by himself or through his accredited agents or representatives, which having been acted upon by another to his detriment in the belief that the statements were true, is thereafter allowed to renege from such statements. The law has accorded reasonable protection to unsuspecting members of society who are misled by such statements because the maker thereof is absolutely estopped to contradict or deny the truth of such statements. Thus section 151 of the Evidence Act provides: 'When one person has by his declaration, act or omission, intentionally caused or permitted another person to believe anything to be true and to act upon such belief, neither he nor his representative in interest shall be allowed, in any proceedings between himself and such person or such persons representative in interest, to deny the truth of that thing.' Estoppel is an admission, or something which the law views as equivalent to an admission. By its very nature, it is so important, so conclusive, that the party whom it affects is not allowed to plead against it or adduce evidence to contradict it.
RATIO DECIDENDI (SOURCE)
Per Achike, JSC, in Bank of the North Ltd. v. Alhaji Bala Yau (2001) NLC-2501993(SC) at pp. 18–19; Paras A–D.
"Certainly, it will be inequitable for anyone, such as the respondent herein to enjoy the liberty of making statements by himself or through his accredited agents or representatives, which having been acted upon by another to his detriment in the belief that the statements were true, is thereafter allowed to renege from such statements. The law has accorded reasonable protection to unsuspecting members of society who are misled by such statements because the maker thereof is absolutely estopped to contradict or deny the truth of such statements. Thus section 151 of the Evidence Act provides: 'When one person has by his declaration, act or omission, intentionally caused or permitted another person to believe anything to be true and to act upon such belief, neither he nor his representative in interest shall be allowed, in any proceedings between himself and such person or such persons representative in interest, to deny the truth of that thing.' Estoppel is an admission, or something which the law views as equivalent to an admission. By its very nature, it is so important, so conclusive, that the party whom it affects is not allowed to plead against it or adduce evidence to contradict it."
EXPLANATION / SCOPE
Unequivocal written admissions of liability create estoppel. A party who makes statements—personally or through agents—that another relies on to their detriment cannot later contradict those statements. Section 151 of the Evidence Act codifies this principle. Estoppel by admission is conclusive—the affected party cannot plead against it or adduce contradictory evidence. The principle prevents injustice and protects those who reasonably rely on representations. The admission must be clear, unequivocal, and acted upon. The estopped party cannot renege even if the admission was mistaken. The law values reliance and fairness over technical truth. The estoppel is absolute, not discretionary.