There is a restitution for wrongs point in the judgment of Sir Jack Beatson for the CA in Marino v FM Capital Partners Ltd [2020] EWCA Civ 245, released yesterday http://www.bailii.org/ew/cases/EWCA/Civ/2020/245.html

One of multiple defendants who gained from wrongdoing (bribe-taking) cannot claim a reduction of liability in respect of the plaintiff’s recovery (by settlement) from another defendant. This is because, following the argument of Andy Burrows, such defendants are severally liable, each for their own gain.

Lionel