Why Did the Court Refuse to Make an Order of Specific

Multiple Choice

Why did the court refuse to make an order of specific performance in J.C.Williamson Ltd v Lukey & Mulholland [1931] HCA 15?

A) The agreement was not in writing.
B) The Court would have had to supervise the order to ensure compliance.
C) Damages were an adequate remedy.
D) The agreement was not in accordance with the Statute of Frauds.