This section is from the book "The Law Of Land Contracts", by Asher L. Cornelius. Also available from Amazon: Michigan Law Of Land Contracts.
A party seeking relief against forfeiture should tender sufficient to make the other party whole. If he does not make this tender before filing the bill of complaint he should at least make the tender by bill and the better practice would be to pay all arrearages due upon the land contract into court together with all interest, although in one case the vendee made no tender of the amount due either in the Supreme court or the lower court, but was permitted to redeem upon, paying to the clerk of the Circuit court within sixty days all arrearages due under the contract together with the costs of both courts.23
23. Lozon v. McKay, 203 Mich. 364; Hickman v. Chaney, 155 Mich. 217; Stickney v. Parmenter, 35 Mich. 237; Morris v. Hoyt, 11 Mich. 9.
In Lozon v. McKay, supra, the plaintiff had been in arrears on one payment under a contract of $200 and had failed to pay the taxes which were more than one year in arrears, and had never tendered or offered to pay the sums called for by the contract. In respect to that case the court used the following language:
"It is apparently as uncertain now as it has been for years whether the plaintiffs can pay what is due to the defendant. It ought to have been tendered before suit was be-
Where the vendor elects to repossess himself of the property through proceedings by the circuit court commissioner, and the vendee does not avail himself of the privilege of paying the amount due, under the statute within 30 days of the date of the rendition of the judgment before such commissioner,24 equity will not entertain a bill for specific performance or for relief from the forfeiture effectuated by the judgment of the circuit court commissioner, in the absence of fraud, accident, or mistake.25
 
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