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Since the Judicature Acts 1873 and 18751 judges have applied both common law and equity in the same court at the same time. An example of this came from Lord Griffin in Napier and Enttrick (Lord) v Hunter2 in which he stated: "Our task now days is to see the two strands of authority, at law and in equity, moulded into a coherent whole" It is still a key question however as to what extent the rules and principles of common law and equity have been shaped into one coherent, principled body of law. In this essay I will look at the relationship between the two with regards to the 'unclean hands' maxim in equity, whilst scrutinizing the decision made by the House of Lords in case of Tinsley v Milligan3. As some academics argue that although the Judicature Act1 fused the adjudication of common law and equity, the intellectual distinction remains....

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