each individual shall be exercised with due regard to the rights, collective security, morality and common interest. 143. The Respondent State therefore prays that the Commission finds that the legislation in question does not violate Article 9of the Charter as alleged by the Complainant. Respondent State’s supplementary submissions on the merits st 144. During the 41 Ordinary Session, the Respondent State made a supplementary submission claiming that it never received the Complainant’s submissions on the merits prior to submitting its original submission on the merits, adding that the supplementary submissions was meant to address the issues raised by the Complainants. 145. In its submissions, the Respondent State notes that Complainants argue that there are civil and criminal sanctions forinjuria and defamation which already regulate the conduct of journalists and hence no need for further legislation, that registration requirements are unduly intrusive and burdensome, and that compliance with the requirements does not necessarily guarantee registration of a journalist as the MIC has the discretion to decide whether or not to register a journalist. The Respondent State claims that each of the Complainants’ submissions referred to above and elsewhere are without merit. 146. The African Commission finds that supplementary submission of the Respondent State does not depart from its earlier submission summarised in paragraphs 131-143 of this decision. The African Commission’s decision on the merits 147. In the present communication, the Commission is called upon to make a determination whether the decision of a domestic court, the highest court of the land in the Respondent State, not to hear a petition brought by the Complainants because the latter came before the Court with ‘dirty hands’, is a violation of the Charter. In other words, did the Supreme Court violate the rights of the Complainants by invoking the equitable doctrine of [quote]‘he who comes to equity must come with clean hands’? The Commission is not called upon to determine the constitutionality of the AIPPA which was the subject at issue before the Supreme Court. The Commission is also not called upon to determine whether the AIPPA or provisions thereof, violate the African Charter. It is called upon to determine whether by invoking the dirty hands doctrine, the Respondent State, through its Court, violated the right to have the Complainants’ cause heard, as guaranteed under Article 7.1.a of the African Charter. What is the clean hands doctrine? 148. According to the Black’s Law Dictionary (2000), the clean hands doctrine is an equitable principle which requires that a party cannot seek equitable relief or assert an equitable defense if that party has violated an equitable principle such as good faith. It bars relief to persons who are guilty of misconduct in the matter for which they seek relief. It is a positive defense that is available where the complaint by the claimant is equitable. 149. Normally, equitable relief is generally available when a legal remedy is insufficient or inadequate to deal with the issue. These rights and procedures were created to provide fairness, unhampered by the narrow confines of the old common law or technical requirements of the law. It was recognised that sometimes the common law did not provide adequate remedies to solve all problems hence the creation of the courts of equity by the monarch. 150. However, in modern days, separate courts of equity have largely been abolished and the same courts that may award a legal remedy have the power to prescribe an equitable one. With time, certain aspects of equity were imported into the law and one such import is the Doctrine of Clean Hands. 151. It is notable also that it is quite a controversial doctrine particularly in the sphere of public law where the formulation is that the responsibility of the State is not engaged when the Complainant has acted in breach of the law of the State. However, as an equitable rule extended to the domain of law, it is necessary to be cautious when applying it particularly in cases where fundamental legal/human rights are involved.