Editing Maxims of equity (section)

===He who comes into equity must come with clean hands===
It is often stated that one who comes into equity must come with [[Unclean hands|clean hands]] (or alternatively, equity will not permit a party to profit by his own wrong). In other words, if you ask for help about the actions of someone else but have acted wrongly, then you do not have clean hands and you may not receive the help you seek.<ref>{{cite BAILII| |court=UKHL |year=1993 |num=3 |litigants=Tinsley v Milligan |courtname=auto}}.</ref> For example, if you desire your tenant to vacate, you must have not violated the tenant's rights.

However, the requirement of clean hands does not mean that a "bad person" cannot obtain the aid of equity. "Equity does not demand that its suitors shall have led blameless lives."<ref>''[[Loughran v. Loughran]]'', {{ussc|292|216|1934|pin=229}}, ([[Louis Brandeis|Brandeis, J.]])</ref> The defense of unclean hands only applies if there is a nexus between the applicant's wrongful act and the rights he wishes to enforce.

In ''[[D & C Builders Ltd v Rees]]'',<ref>{{cite BAILII |litigants=[[D & C Builders Ltd v Rees]] |year=1965 |court=EWCA |division=Civ |num=3 |courtname=auto}}.</ref> a small building firm did some work on the house of a couple named Rees. The bill came to £732, of which the Rees had already paid £250. When the builders asked for the balance of £482, the Rees announced that the work was defective, and they were only prepared to pay £300.<ref> Mrs Rees: "My husband will pay you £300. It is all you'll get. It is to be in satisfaction".</ref> As the builders were in serious financial difficulties (as the Rees knew), they reluctantly accepted the £300 "in completion of the account". The decision to accept the money would not normally be binding in contract law, and afterwards the builders sued the Rees for the outstanding amount. The Rees claimed that the court should apply the doctrine of [[equitable estoppel|promissory estoppel]],<ref>Promissory estoppel was established by Denning J in ''[[Central London Property Trust Ltd v High Trees House Ltd]]'' [1947] [[Kings Bench Law Reports|KB]] 130.</ref> which can make promises binding even when unsupported by consideration. However, [[Alfred Denning, Baron Denning|Lord Denning]] refused to apply the doctrine, on the grounds that the Rees had taken unfair advantage of the builders' financial difficulties, and therefore had not come "with clean hands".