... 'he who comes to equity must come with clean hands' prevented M from being able to claim her share in the property. "For a plea of unclean hands to succeed two requirements must be satisfied: the conduct complained of must have 'an immediate and necessary relation to the equity sued for', a restriction established as long ago as 1787,2 and the conduct must be of a kind equity regards as unclean."3 The court held that on the facts of the case "M had established a resulting trust by showing that she had contributed to the purchase price of the house and that there was a common understanding between her and T that they owned the house equally." The point in question at the appeal was whether M's claim was automatically defeated by the fraud against the DSS even though she had admitted and "made her peace with them soon after the action ...

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