Does the clean hands doctrine apply to common law spouses?

The Court in Turbide v. Moore, 2006 NSSC 71, at paragraphs 68 to 74, dealt with the clean hands doctrine in the context of common law spouses. It stated that the “doctrine is not applied rigorously in family law proceedings” and noted that if the equitable relief requested can be established without relying upon the misconduct in question it is not barred.