There has, over the years, been considerable criticism of the loose use of the word "acquiescence" as a broad conjunctive or disjunctive companion to "laches": see, e.g., per Lord Cottenham L.C., Duke of Leeds v. Earl of Amherst [13] ; De Bussche v. Alt [14] . Such criticism has obvious force in that, so used, the word has a chameleon-like quality which adds little besides confusion to an already vague area of equity doctrine. Strictly used, acquiescence indicates the contemporaneous and informed ("knowing") acceptance or standing by which is treated by equity as "assent" (i.e. consent) to what would otherwise be an infringement of rights (cf. Dann v. Spurrier [15] ; Life Association of Scotland v. Siddal. Cooper v. Greene [16] ; Cashman v. 7 North Golden Gate Gold Mining Co. [17] ). The word is commonly also used to refer: (i) to a representation by silence of a type which may found an estoppel by conduct (see, e.g., Mitchell v. Homfray [18] ); or (ii) to acceptance of a past wrongful act in circumstances which give rise to an active waiver of rights or a release of liability (see, e.g., Brunyate, Limitations of Actions in Equity (1932), pp. 188-189; Hanbury and Maudsley, Modern Equity, 12th ed. (1985), pp. 621-622); or (iii) to an election to abandon or not enforce rights: see, e.g., per Lindley L.J., Allcard v. Skinner [19] . A plaintiff may, however, lose his right to relief by an "inferior species of acquiescence" (cf. Banning, Statute Law of the Limitation of Actions, 2nd ed. (1892), p. 269) which does not amount to assent, waiver or election or give rise to an estoppel. In these cases, acquiescence may be used in at least one of three ways. First, it is sometimes used as an indefinite overlapping component of a catchall phrase also incorporating "laches" or "gross laches" and/or "delay". While such phrases may provide a convenient means of referring to a general area of equity, they tend to obscure principle rather than to assist in its identification. Secondly, acquiescence is used as a true alternative to "laches" to divide the field between inaction in the face of "the assertion of adverse rights" ("acquiescence") and inaction "in prosecuting rights" ("laches") (see, e.g., Smith, Manual of Equity Jurisprudence, 14th ed. (1889), p. 24). Upon analysis, that use of the word "acquiescence" is not helpful since laches ("an old French word for slacknesse or negligence or not doing": Co. Litt. 380b; Partridge v. Partridge [20] ) comprehends silence or inaction in the face of an unwarranted assertion of adverse rights by another as well as inaction or delay in prosecuting one's own rights. Thirdly, and more commonly, acquiescence is used, in a context where laches is used to indicate either mere delay or delay with knowledge, to refer to conduct by a person, with knowledge of the acts of another person, which encourages that other person reasonably to believe that his acts are accepted (if past) or not opposed (if contemporaneous): see, e.g., Cashman [21] ; Glasson v. Fuller [22] .