What is the proprietary interest justification and what is the effect on constructive trust?

As to the proprietary interest justification, the author mentions Sorochan as a useful basis for deciding whether particular conduct should give right to a remedial constructive trust. Our Court of Appeal has recently reviewed the principles in Sorochan; in Panara, it makes the following comments: Three elements are necessary to establish a right to claim relief based on unjust enrichment: an enrichment, a corresponding deprivation, and the absence of any juristic reason for the enrichment: Pettkus, supra at 848; Sorochan v. Sorochan, 1986 CanLII 23 (SCC), [1986] 2 S.C.R. 38 at 44 ("Sorochan"); Peter v. Beblow, 1993 CanLII 126 (SCC), [1993] 1 S.C.R. 980 at 987 ("Peter"). It is not enough to establish that a benefit has been conferred; the benefit must be accompanied by a corresponding deprivation, in circumstances that would render retention of the benefit unjust: Pettkus, ibid.