A party asserting equitable estoppel is not required to demonstrate 'innocence' in the sense of being free from prior wrongdoing; such conduct is relevant only to the discretionary defence of clean hands. The preservation of company assets by successfully defending fraudulent claims constitutes 'enrichment' for the purposes of the rule in Ex parte James. The scope of Ex parte James may extend beyond money paid under mistake of law, though this was left as an open question.
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