What is the test for specific performance of a contract?

The Court of Appeal recently summarized the principles relevant to awarding specific performance in Lucas v. 1858793 Ontario Inc., 2021 ONCA 52. The basic rationale for an order of specific performance of contracts is that damages may not, in the particular case, afford a complete remedy. However, specific performance should not be granted absent evidence that the property is unique to the extent that its substitute would not be readily available: Lucas, supra, at para. 69. Whether specific performance is to be awarded or not is a question that is rooted firmly in the facts of an individual case. Courts typically examine and weigh together three factors: (i) the nature of the property involved; (ii) the related question of the inadequacy of damages as a remedy; and (iii) the behaviour of the parties, having regard to the equitable nature of the remedy. The issue is whether the plaintiff has shown, upon the consideration of all the factors, that the land rather than its monetary equivalent better serves justice between the parties: Lucas, supra at paras. 71, 76.