English Law Has Yet to Fully Embrace the Concept of a Remedial

English law has yet to fully embrace the concept of a remedial constructive trust. Which of the following statements best explains why this might be so?

A) There is uncertainty as to the remedy awarded through a remedial constructive trust.
B) The courts have traditionally favoured certainty and predictability as to when a constructive trust arises over a broad discretion to vary property rights.
C) Remedial constructive trusts in other jurisdictions arise to prevent unjust enrichment, whereas in English law unjust enrichment is viewed as a common law action.
D) The remedial constructive trust is part of the law of the USA and Canada, so those cases only have persuasive authority in England and Wales.