In the above scenario, I considered how the beneficiaries could have been compensated for the unauthorized profit made at their expense. In this regard, among other equitable remedies, the court may have ordered the trustee to turn over a profit statement with respect to the embezzled trust money. In my studies, I have become aware of another circumstance where the court can order the surrender of a profit account, for a breach of contract. I had come across this remedy in an Obligations 2 conference examining equitable remedies for breach of contract; McKendrick called the action giving rise to the remedy “tort enrichment,” which apparently parallels unjust enrichment. The difference in the wording of enrichment by tort is that the defendant, as a result of the breach of contract, had received an unfair advantage in the form of a profit which he would not otherwise have made. The leading case in this area is AG v Blake, which states that the remedy is only available in exceptional circumstances where no other remedy is adequate and the claimant has a legitimate interest in denying the defendant its surplus profit; furthermore, the court must be satisfied that all the circumstances of the case justify the need to order an account of profits. Therefore, the concept of providing a profit statement can have