Although Iacobucci J. was speaking in the commercial context, the principles of unjust enrichment apply equally to family law cases. In this regard, I note that McLachlin J. observed the following at ¶24 of Peter v. Beblow: I doubt the wisdom of dividing unjust enrichment cases into two categories—commercial and family—for the purpose of determining whether a constructive trust lies. A special rule for family cases finds no support in the jurisprudence.
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