Habeas petitions do not count towards vexatious litigant determination. The plaintiff was effectively declared a vexatious litigant. Administrative tribunals in Quebec cannot declare a person a vexatious litigant. Bittaker was declared a vexatious litigant in 1993. Rulings such as this have classified the Church of Scientology as a chronically vexatious litigant. A court may sometimes explicitly reassure a litigant that an action will not prejudice him. A litigant who approaches the court must come with clean hands. Self-evidently, unless the proposed litigant has legal personality, there will be no jurisdiction. Cases are not taken up if the litigant has no standing to sue. The French courts also tried cases in which one litigant was Tunisian, the other European. The party who did so, however, whether litigant or champion, was punished with outlawry. Moreover, that he favors or is hostile to either litigant is unthinkable. All parties must file a budget, unless they are a litigant in person. In England and Wales the comparable status is that of "litigant in person". Many featured the exploits of Albert Haddock, a tireless and veteran litigant.