very once in a while, one or another international tribunal is faced with the resurgence of a question that should long have been regarded as settled: is there a doctrine of ‘unclean hands’ that exists in the form of a ‘general principle of law’ – in the sense of Article 38(1)(c) of the Statute of the International Court of Justice (“ICJ”)? Such an argument is generally raised with escapist tendencies – a respondent State would contend that the claimant State’s allegations are inadmissible because the claimant has engaged in illegalities in relation to the claim. Despite the lack of any considerable support for this doctrine, it has been frequently resurrected in recent ICJ litigations