There remains the issue of a constructive trust. In Pettkus v. Becker, Dickson J. (as he then was) laid down the tests for a constructive trust [at p. 835] as “an enrichment, a corresponding deprivation and absence of any juristic reason for the enrichment.” There can be no doubt from these tests that there must be a direct connection between the enrichment and the deprivation, that is to say, that what one party was deprived of flowed directly to and became the enrichment of the other party.
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