The International Court of Justice (“ICJ”), in its recent decision of Certain Iranian Assets (Merits) 2023 has resurrected the Clean Hands doctrine, muddying the grounds for its applicability at the merits stages of disputes presented before it. The clean hands doctrine can be understood as follows: a State which is guilty of illegal conduct may be deprived of the necessary locus standi in judicio for complaining of corresponding illegalities on the part of other States; or simply, ‘he who comes to equity for relief must come with clean hands’. The application of this doctrine, as well as its mere existence, has been a matter of debate, and the ICJ’s recent decision contributes to it.