We must add that, the doctrine has, since 1975, also found statutory expression in Section 26 of the Evidence Act, 1975 (NRCD 323), which provides: “Except as otherwise provided by law, including a rule of equity, when a party has, by his own statement, act or omission, intentionally and deliberately caused or permitted another person to believe a thing to be true and to act upon such belief, the truth of that thing shall, as against that party, be conclusively presumed in any proceedings between that party and such relying person or his successor in interest.” The section, though couched in the language of conclusive presumption rather than estoppel simpliciter, has been recognised by this Court in numerous decisions as the statutory embodiment of the equitable doctrine of estoppel by representation, of which promissory estoppel is but one species.
NDK FINANCIAL SERVICES LIMITED vs. SAFKOS FARMS & 2 ORS [2026] SLR (SC) 60 · Supreme Court · 2026 · AMADU JSC
Read it in the judgment