We have included in the note to this section a brief digest of the late Michigan cases from Volumes 189 to 213, inclusive, where the relief by way of specific performance has been denied.34 eion of the balance of the purchase price ordered where the vendors, husband and wife, had both died, and the representatives of their estates were in disagreement as to division of the fund. Flam-mer v. Cullen, 194 Mich. 585.

Specific performance of an oral agreement to convey defendant's farm in consideration of services, etc., will be granted. Woodward v. Walker, 192-188.

Specific performance of a contract, fully performed on one side by plaintiffs, to convey certain premises if plaintiffs would give up their farm, and move into defendant's home and make certain improvements, was decreed, although it was not in writing. Friend v. Smith, 191-99.

Specific Performance-Relief Denied.

34. Silver v. Shulman, 213 Mich 211. Relief denied because contract made on Sunday.

Morrison v. Meister, 212 Mich. 516. Contract signed by only one of several joint owners.

Sayers v. McKeever, 211 Mich. 249. Relief denied. Plaintiff had failed to pay taxes on property and had no agreement relative to taxes. She refused to pay same and court held title encumbered by lien.

Woods Land Co. v. Beeman, 211 Mich. 360. Option not enforced, contract procured by overreaching on plaintiff's part.

Schoenfeld v. Kemter, 211 Mich. 464. Relief denied; judgment had been rendered by Circuit Court Commissioner and writ of restitution granted previous to filing of bill of complaint. Plaintiff held no equities.

Slatkin v. Schumer, 210 Mich. 513. Relief denied. Bill dismissed because time had expired, and other parties acquired interests in the property.

Harrison v. Eassom, 208 Mich. 685. Denied because acts of part performance by plaintiffs and permitted by defendants were not of kind to create strong equities in plaintiff's favor.

Oakman v. Esper, 206 Mich. 315. Denied when plaintiff had defaulted and property had been sold to others.

Lozon v. McKay, 203 Mich. 364. Vendee denied relief after forfeiture of land contract unless relieved of forfeiture (decree conditional)

Law v. McKechnie, 202 Mich. 284. Involving option to purchase dur ing term of lease. Specific performance denied because tender of full amount and demand for deed had not been made according to terms.

Zigen v. Rosier, 200 Mich. 328. Involves contract for sale of land held by husband only.

Bradway v. Miller, 200 Mich. 648. Defendant bought on condition that the abstract show a merchantable title. Same not shown; plaintiffs