...unauthorized execution of an instrument affecting the title to land or an interest therein may be ratified by the owner of the land or interest so as to be binding upon him (21 N.Y. Jur, Estoppel, Ratification, and Waiver, § 87). Ratification relates back and supplies original authority to execute the conveyance (2 Williston, Contracts [3d ed], § 278, p 253). Although very closely associated with estoppel, ratification differs therefrom because it does not require a change of conduct by, or...of position (21 N Y Jur, Estoppel, Ratification, and Waiver, § 60). These are commonly termed the elements of detrimental reliance.
While the circumstances indicate that the doctrine of equitable estoppel may be applied to Seneca, Odai and Grago, Holm may be equitably estopped only by his own conduct. It...is only estoppel by deed which binds successors in interest (see Mutual Life Ins. Co. of N.Y. v. Corey, 135 N.Y. 326, 335; see, also, 21 N.Y. Jur, Estoppel, Ratification, and Waiver, § 7, p 9). The only conduct attributable...