This essay is focused on the protection of purchaser’s reliance during the 16th–18th centuries, w... more This essay is focused on the protection of purchaser’s reliance during the 16th–18th centuries, with the aim of tracing how this problem was approached on both sides of the Channel. The issue involves the doctrine of equitable estoppel, with particular regards to proprietary estoppel, which is commonly considered a genuine common law doctrine, without a civil law counterpart. The author claims that common law and civil law shared a common rule of protection of the purchaser’s reliance up to the 19th century. She concludes that the equitable doctrine of estoppel has its early source in the Jus commune developed in Europe.
This essay is focused on the protection of purchaser’s reliance during the 16th–18th centuries, w... more This essay is focused on the protection of purchaser’s reliance during the 16th–18th centuries, with the aim of tracing how this problem was approached on both sides of the Channel. The issue involves the doctrine of equitable estoppel, with particular regards to proprietary estoppel, which is commonly considered a genuine common law doctrine, without a civil law counterpart. The author claims that common law and civil law shared a common rule of protection of the purchaser’s reliance up to the 19th century. She concludes that the equitable doctrine of estoppel has its early source in the Jus commune developed in Europe.
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