The doctrine of estoppel plays an important role in international arbitration, preventing a party from acting inconsistently with their previous representations or conduct to the detriment of another. Grounded in the principles of good faith and procedural fairness, estoppel contributes to the stability and predictability of arbitral proceedings. This paper explores the application of estoppel across common law and civil law, and examines its impact on arbitral procedure and awards. It highlights how arbitral tribunals rely on estoppel to protect legitimate expectations and to promote equitable outcomes in cross-border disputes.
Zein et al. (Sun,) studied this question.