Introduction

Equitable principles are a part of international law. The International Court of Justice ("ICJ") has confirmed that "the legal concept of equity is a general principle directly applicable as law."[1] Among those equitable principles that international tribunals have applied is the concept that a claimant's claims may be barred due to its illegal conduct in relation to the claims he brings. This concept is known as the "clean hands doctrine."[2] As Sir Gerald Fitzmaurice has summarized: 'He who comes to equity for relief must come with clean hands'. Thus a State which ...