Reflections on R v R
the club of a banker's draift for £3,735 and the difficulties which surround the relationship between a claim in conversion and a restitutionary claim. In many ways it is appropriate that, 25 years aifter the publication of the first edition of Goff and Jones' The Law of Restitution, which has had an enormous influence upon the way in which we think about the law of restitution, one of its authors, Lord Goff, should write the leading judgment in the House of Lords which takes the important double step of recognising an independent law of restitution based upon unjust enrichment and a defence of change of position. As this note has sought to demonstrate, many difficulties lie ahead and there remain many matters for debate to occupy the attention of restitution lawyers, but these debates can now focus on the shape and scope of the subject rather than its existence.