Until quite recently, it was assumed that, in the event of a breach of contract, it was only the reliance and the expectation interests that were recognised for compensatory purposes. However, there now seems to be a third possibility, compensation for the 'restitution' interest. What makes this third interest particularly controversial is that it can arise where the innocent party has no financial losses relative to either the reliance or the expectation interest. Nevertheless, on the facts, it is arguable that the contract-breaker has been unjustly enriched.