Estoppel in Russian law

In the course of the recent reform of the Civil Code of the Russian Federation, common law legal institutions such as estoppel were implemented in Russian contract law. However, the differences in the doctrinal foundations between common law and Russian law are obvious. Russian private law does not require consideration for the formation of the contract or for its modification, while the doctrine of promissory estoppel is usually taught as a topic ancillary to the consideration rule. Nor does Russian law have a tradition of equity, which enables equitable estoppel and especially proprietary estoppel under English law. Nevertheless, the Russian case law seems at least in parts to follow a logic similar to that of the English doctrine of estoppel. In particular, the Russian courts are obviously concerned with elaborating a value-based notion of estoppel using a definition which refers to reasonable reliance of the other party, good faith and commercial honesty as well as the proscription of inconsistent and unconscionable conduct. The recent cases do not only apply the doctrine of estoppel beyond the boundaries of the relevant provisions of the Civil Code; they also try to develop the general limitations of estoppel on the basis of the good faith doctrine