English courts have now accepted that the concept of unjust enrichment has a role to play in subrogation.See, e.g., Bank of Cyprus v Menelaou [2015] UKSC 66; it was first recognised in Banque Financiere v Parc [1999] 1 AC 221. In contrast, this approach has been stridently rejected by the High Court of Australia, where the doctrinal basis of subrogation is said to lie in the prevention of unconscionable results: for example, the discharge of a debtor or one party getting double recovery.Bofinger v Kingsway [2009] HCA 44; Heydon, Leeming and Turner, Meagher, Gummow & Lehane's Equity: Doctrine and Remedies (5th ed, 2015) 391-2.
