I respectfully dissent. I would affirm the court of appeals’ decision, but remand the case for a determination of the *63appropriate amount Beaufort County, must disgorge as a result of its unjust enrichment.
A court may grant equitable relief where there is no adequate remedy at law. Santee Cooper Resort, Inc. v. South Carolina Pub. Serv. Comm’n, 298 S.C. 179, 185, 379 S.E.2d 119, 123 (1989). An adequate remedy at law is one which provides the plaintiff with “the' full end and justice of the case. It is not enough that there is some remedy at law, but that remedy must be as practical, efficient, and prompt as the remedy in equity.” Chisolm v. Pryor, 207 S.C. 54, 60, 35 S.E.2d 21, 24 (1945) (internal citations omitted).
“Restitution is a remedy designed to prevent unjust enrichment.” Stanley Smith & Sons v. Limestone College, 283 S.C. 430, 435 n. 1, 322 S.E.2d 474, 478 n. 1 (Ct.App.1984). To recover on a theory of restitution, the plaintiff must show that: (1) he conferred a non-gratuitous benefit on the defendant, (2) the defendant realized some value from the benefit, and (3) it would be inequitable for the defendant to retain the benefit without paying the plaintiff for its value.- Sauner v. Pub. Serv. Auth. of South Carolina, 354 S.C. 397, 581 S.E.2d 161 (2003).
The majority finds that S.C.Code Ann. § 12-51-150 (2000) provided the Respondent’s with an adequate remedy at law. Although I agree that the statute provides some remedy for the Respondents, I do not find the remedy adequate because it is neither practical, complete, nor efficient. While the statute mandates the return of the amount paid by the bidder, the statute fails to provide complete relief to the Respondents who, through no fault of their own, have, been denied the use of their funds. The interpretation propounded by the majority provides little incentive for the County to resolve its mistakes in a timely fashion, and instead, encourages the County to indefinitely hold funds which rightfully belong to the bidder.
Here, the Respondents gave the County money in exchange for the title to real property. Although the County failed to deliver title for the real property to the Respondents, the County retained the money and utilized the funds to earn interest. Clearly, this constitutes a non-gratuitous benefit for which the County received some value. Surely it is inequita*64ble for the County to retain these benefits without compensating the Respondents for their value.
The County argues that no inequity occurred because the Respondents had actual notice that interest would not be given in the event the tax sale was voided. However, in my opinion, the notice provided to the bidders refers to the statutory interest payments bidders normally receive if a property is redeemed by the taxpayer, see S.C.Code Ann. § 12-51-100 (2000), and not the interest the County earns on the funds through a deposit account or other similar investment. While it is reasonable that the County should not pay statutory interest that it has not received through redemption, it is unreasonable and inequitable to allow the County to retain interest earned on funds which rightfully belonged to the Respondents.
Additionally, the majority holds that the legislature intended to prohibit the return of any interest earned on bid money retained by the County because the statute is silent on the issue of interest and the legislature could have included such language in § 12-51-150 as it has in other statutes. I disagree.
First, I would find that the statute’s silence regarding the return of interest is ambiguous and does not clearly demonstrate legislative intent to prohibit the return of such interest. This Court has acknowledged that “subsequent legislation may be of service as indicating the construction given to the former by the legislature itself.” Abell v. Bell, 229 S.C. 1, 5, 91 S.E.2d 548, 550 (1956) (internal citations omitted). Furthermore, this Court recognizes: *65North River Ins. Co. v. Gibson, 244 S.C. 393, 398, 137 S.E.2d 264, 266 (1964) (holding that the legislature’s modification of language in a statute accomplished by general revision of the laws indicated the legislature’s intent to clarify the existing law and not to materially change the existing law).
*64the rule of construction that the adoption of an amendment which materially changes the terminology of a statute under some circumstances indicates persuasively and raises a presumption that a departure from the original law was intended. However, like all rules of construction, the presumption is merely an aid in interpreting an ambiguous statute and determining the legislative, intent. The presumption is strongest “in the case of an isolated independent amendment ... and ... is of little force in respect of amendments adopted in a general revision or codification of the laws.”
*65The legislature recently revised § 12-51-150 to include additional language requiring a county .that voids a tax sale to also relinquish the amount of interest actually earned on the amount paid by the bidder. See Act No. 386, 2006 S.C. Acts 3077. Like the statute at issue in Gibson, § 12-51-150 was modified through an act which provided a general revision to many statutes in our Code of Laws. Because the modification of the statute was accomplished through an act of general revision and not an isolated independent amendment, I would hold that the revision by the legislature indicated its intent to clarify the statute as opposed to an intent to materially modify the law.
Second, I find the majority’s reliance on the fact that the legislature could have included language requiring the return of interest in § 12-51-150 as it had in other statutes inconsequential. Both §§ 12-51-100 and -130 refer to situations distinctly different from the one at hand.' As I have discussed, § 12-51-100 clearly refers to the statutory interest provided by § 12-51-90. Section 12-51-130, on the other hand, allows the County to retain interest earned on money which it rightfully possesses due to the failure of the defaulting taxpayer or owner of record to claim the funds in a timely fashion. Therefore, in my opinion, the legislature’s discussion of interest in these statutes provides no indication of its intent to prohibit the relinquishment of interest pursuant to § 12-51-150. These statutes simply address interest in different contexts.
For the foregoing reasons, I would affirm the court of appeals and allow the Respondents to maintain an action against the County for restitution. However, in recognition of the unintentional nature of the County’s mistake and the costs associated with carrying out these types of transactions, I believe that the equitable remedy of restitution only allows the Respondents to recover the amount in which the County was unjustly enriched. Therefore, I would remand the case to the *66trial court with instructions to determine the amount of unjust enrichment the County must disgorge.
PLEICONES, J., concurs.