Under the Battersea framework, it has been accepted that the claimant must establish that there is a connection or nexus between the (a) receipt of an enrichment by the defendant and (b) the claimant’s loss, so as to justify the unjust enrichment claim against the defendant. However, the question of whether the defendant has been enriched or the enrichment was at the claimant’s expense, is complicated, especially where it appears the enrichment was no more than an incidental benefit, or the defendant has received the enrichment only indirectly from the claimant.
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