What is the current state of the law in Canada on constructive trust?

Canada (Federal), Canada

The following excerpt is from Soulos v. Korkontzilas, [1997] 2 SCR 217, 1997 CanLII 346 (SCC):

20 Canadian courts have never abandoned the principles of constructive trust developed in England. They have, however, modified them. Most notably, Canadian courts in recent decades have developed the constructive trust as a remedy for unjust enrichment. It is now established that a constructive trust may be imposed in the absence of wrongful conduct like breach of fiduciary duty, where three elements are present: (1) the enrichment of the defendant; (2) the corresponding deprivation of the plaintiff; and (3) the absence of a juristic reason for the enrichment: Pettkus v. Becker, supra.

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