The general rule is that the court will not grant specific performance of contracts relating to personalty - not because of any difference between real and personal property, but because usually damages will be an adequate remedy. If, therefore, the contract is for the sale of a specific chattel, and damages will not be an adequate remedy, specific performance may be enforced. The cases are collected in the notes in 2 White & Tudor's Leading Cases, 8th ed., 1912, pp. 428 ff., to the case of Cuddee v. Rutter, 1720, 5 Vin. Abr. 538, pi. 21, 6 R.C. 640.

In Ontario the Sale of Goods Act provides:

51. In any action for breach of contract to deliver specific or ascertained goods, the court may, if it thinks fit, direct that the contract shall be performed specifically, without giving the defendant the option of retaining the goods on payment of damages, and may impose such terms and conditions as to damages, payment of the price, and otherwise, as to the court may seem just.

In the United Kingdom the Sale of Goods Act provides:

52. In any action for breach of contract to deliver specific or ascertained goods the court may, if it thinks fit, on the application of the plaintiff, by its judgment or decree direct that the contract shall be performed specifically, without giving the defendant the option of retaining the goods on payment of damages. The judgment or decree may be unconditional or upon such terms and conditions as to damages, payment of the price, and otherwise, as to the court may seem just, and the application by the plaintiff may be made at any time before judgment or decree.

The provisions of this section shall be deemed to be supplementary to, and not in derogation of, the right of specific implement in Scotland.

In Scotland specific performance, or, as it is called, specific implement, is an ordinary not an an extraordinary remedy, and it can be demanded as of right wherever it is practicable.

Chalmers, Sale of Goods, 7th ed., 1910, p. 126, citing Stewart v. Kennedy, 1890, 15 App. Cas. 75, at pp. 102,105.

The Sale of Goods Act confers on the court the power of enforcing at the instance of a buyer specific performance of a contract for the sale of specific or ascertained goods, whether or not the property has passed by the contract.

Jones v. Tankerville, [1909] 2 Ch. 440, at p. 445; as to what is meant by specific or ascertained goods, see chapter 3, 33.