Comparative law notes
The closest concept in Anglo-American law is "equitable subrogation", which is a legal doctrine that allows a party that has made payments on behalf of another party to lay claim to the recovery of damages or funds from a third-party. Equitable subrogation is a legal concept that allows one party to replace another party when it comes to a legal right. It is most commonly associated with the insurance industry, specifically in relation to the settlement of claims.