Strict compliance for reconveyance rights defeats equitable relief where contractual conditions are not satisfied.

A contractual right to reconveyance made exercisable only on strict compliance with stipulated conditions is not enforceable in equity when those conditions are not met. The sale deed, rent note, and reconveyance covenant formed one transaction, but the option had to be exercised within the specified time and while arrears remained below the agreed limit. Equity against forfeiture applies to penalties or security arrangements, not to a beneficial right conditional on exact performance; absent fraud, accident, or surprise, no relief is available. The right to reconveyance was therefore not specifically enforceable and equitable relief was refused.

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Issues: Whether a court can grant equitable relief against forfeiture and enforce a covenant for reconveyance when the beneficiary has failed to comply strictly with the conditions on which the right to reconveyance was made exercisable.

Analysis: The sale deed, the covenant for reconveyance, and the rent note formed one transaction, but the right to demand reconveyance was only a concession subject to strict conditions. The beneficiary had to exercise the option within two years and keep the rent arrears below the stipulated limit. Equity may relieve against penalties where the object is merely to secure payment of money or performance of an act, but that principle does not apply where a contract confers a beneficial right only upon performance of the stipulated conditions in the stated manner and within the stated time. In such a case, absent fraud, accident, or surprise, equity does not relieve against the breach.

Conclusion: The right to reconveyance could not be specifically enforced in favour of the plaintiff, and no equitable relief against forfeiture was available.

Ratio Decidendi: Where a beneficial contractual right is made exercisable only on strict compliance with stipulated conditions, failure to satisfy those conditions defeats the right and equity will not grant relief against the resulting forfeiture.

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