In Brief
This case concerns whether a buyer of land can compel its sale through specific performance when he has failed to pay the agreed rent. The land was delivered to the buyer on the understanding he would pay customary rent. The Supreme Court held that failure to perform this reciprocal obligation—a key part of the agreement—bars the buyer from obtaining the discretionary remedy of specific performance. The Court affirmed that in contracts with reciprocal promises, a party's non-performance forfeits his right to claim performance from the other side. The appeal was allowed, reversing the lower courts' decree for specific performance.
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