Does the doctrine of estoppel apply in a personal injury action brought by a plaintiff who suffered from interspousal disability?

If interspousal disability to maintain an action for personal tort is to remain the rule of this state, then that rule should apply here. If plaintiff is allowed to invoke the doctrine of estoppel in order to pursue a separate maintenance action, it is proper that that doctrine should apply in her tort action. [49 Cal.2d 241] However, as hereinafter explained, this court could well consider overruling the holding of Peters v. Peters (1909), supra, 156 Cal. 32, 36, 103 P. 219, 23 L.R.A.,N.S., 699, and the cases which follow it.