In this paper I focus on three equitable principles in the common law jurisdictions of England and Sri Lanka and the treatment of those principles in Tinsley v. Milligan (1993) 3 ALL ER 65 (HL) my conclusion is that the UK House of Lords creates the judicial trend of unifying the Law of Restitution with respect to claims to property as relief before the court where the parties admit that there have been previous illegal transactions concerning the use of the property. My remark in this paper is that the development of equitable principles in both Law and Equity in England needed a change in judicial trend, and, for the House of Lords in Tinsley v. Milligan there is justification to make more flexible rules of equity and law under the cover of these progressive judicial trends which appeared in judgments before Tinsley v. Milligan and which are explored in this paper. Therefore the conclusion in this paper is that trends are the influencing factors for the House of Lords in cases like Tinsley v. Milligan with respect to evolving equitable principles in both law and equity which depart from the traditional application of those rules which existed before in the courts in England. I argue in my paper with historical evidence that the three equitable principles of Law and equity ex turpi causa, in pari delicto and the clean hands principle are connected by cannon law and this justifies the approach of The House of Lords to unify the Law of remedies relating to equitable relief so as to avoid departing from judicial precedent such as the Bowmaker rule which the House of Lords imports in Tinsley v. Milligan to make the clean hands principle more flexible in law of equity.