What remedies are available to a plaintiff in a case of unjust enrichment?

Cromwell J. in Kerr v. Baranow, supra, at paragraph 52, recognizes that there is enough flexibility in the equitable remedies available to a court in cases of unjust enrichment to permit alternate remedies if the circumstances of the case justify it. Specifically, Cromwell J. states that a court may grant the plaintiff rights that flow from the recognition of property rights where the plaintiff can establish that a monetary award is insufficient in the circumstances. The court can also take into account the probability of recovery of an award.