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The Division Bench of the Delhi High Court ruled that the principle of “clean hands” cannot be invoked to deny relief to a petitioner who has successfully proven cruelty, especially if the counter-allegations against them are unsubstantiated. 
 
Key Features of the Doctrine

• Equitable Principle: The doctrine applies only to equitable remedies, not to claims for damages at law.
• Subject Matter Specific: The misconduct must be directly related to the matter in dispute. A party's unrelated wrongdoing does not automatically bar relief.
• Affirmative Defense: The doctrine is typically raised as an affirmative defense by the opposing party.
• Judicial Discretion: Courts have discretion in applying the doctrine, considering the nature and gravity of the misconduct and its impact on the fairness of the proceedings.​

Application in Indian Jurisprudence

• In India, the Supreme Court and various High Courts have consistently emphasized the importance of the clean hands doctrine.
• The courts have held that litigants must approach the court with full transparency and integrity, disclosing all material facts relevant to the case.
• If a party has concealed facts, engaged in fraud, or acted in bad faith, the court may refuse to grant relief, even if the party has a technically valid claim.
• The doctrine is often invoked in cases involving fraud, concealment, or abuse of process.​

Recent Delhi High Court judgment on the Doctrine of Clean Hands

• The case involved a divorce petition under the Hindu Marriage Act where the petitioner claimed cruelty by the spouse.
• The Family Court had dismissed the petition citing the petitioner’s unclean hands, relying on counter-allegations that were unsubstantiated.
• The Delhi High Court held that the doctrine of clean hands cannot be used to deny relief if the petitioner has proven cruelty and the counter-allegations are not established.
• The court emphasized that the doctrine prevents benefiting from one’s own wrongdoing but should not bar legitimate relief where statutory grounds like cruelty are proven with evidence.

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