ABSTRACT
The law of unjust enrichment discloses a novel policy-motivated unjust factor called the policy
against accumulation. The policy applies whenever a claimant (R) receives a benefit, or has the
right to recover a debt or damages from another party (Y) and receives, or has the right to receive,
in respect of the same debt or damage from a third party (X). The general policy of the law in such
circumstances is that the claimant (R) is rarely, if ever, permitted to accumulate by receiving from
both X and Y. If R does in fact receive from both X and Y, she must reverse one transfer. The
claimant’s obligation to reverse one transfer is given to reverse the unjust enrichment which would
otherwise remain. The unjust factor underlying this claim is the policy against accumulation.