What is the test for specific performance of an agreement to purchase a residential property?

In Bowser v. Prager, [1999] O.J. No. 1438 (S.C.J.), Weekes J. refused specific performance of an agreement to purchase a residential property and awarded damages instead. Weekes J. found that the property was unique, but refused specific performance on the basis of hardship. The seller was mentally competent, but was depressed when he signed the contract. He was on social assistance and had been released about a month before from involuntary committal to a psychiatric institution. He had two sizable debts which he was unable to pay. He could not afford similar accommodation in the area and was at risk of becoming homeless. Weeks J. acknowledged that the buyer would also suffer hardship, but less than the seller in the circumstances.