Strictly speaking, this is not a case of subrogation; it is a case of recoupment. Similar rules apply to transfers of contractual rights by way of subrogation. In these cases, subrogation may be rendered worthless or impossible. This is subrogation in its proper or core sense. On 16 September 1971, the second subrogation was enacted. Subrogation typically arises in three-party situations. Subrogation allows the insured to retain his personal right. Subrogation entitles the plaintiff to the rights as the third party against the defendant. Subrogation is an equitable remedy, having first developed in the English Court of Chancery. Subrogation, then, is essentially a right of recourse without transfer of rights. "Subrogation" has been used in this context to refer to two distinct situations.