Who may be entitled to the specific performance of contract

Relevant provision:
Section 23 and 24 of the special relief act 1877, deals with the persons for whom
the contract may be specifically enforced and for whom the contracts may not be
specifically enforced.
Under section 23:
Except as otherwise provided by this chapter, the specific performance of a
contract may be obtained by:
1. Any party (section 23 (a)):
Any party to contract or any party to suit.
2. Representation-in-interest (section 23 (b)):
The representative in interest, or the principal, of any party thereto:
Conditions in which a representative in interest or his principal cannot obtain
specific performance of the contract are-
i. If the knowledge, ability, solvency, or any personal quality of such party is
a material factor in the contract.
ii. If the contract provides that his interest shall not be assigned.
Illustration: A made a contract with B for painting (skill). Hence A cannot
obtain the specific performance of this contract as it is made on an
individual’s skills.
Representative in interest is a person or entity who acts on behalf of
another party´s rights, individual´s interests or claims.
3. Contract of settlement on marriage or compromise of doubtful rights
(section 23 (c):
Where the contract is a settlement on marriage, or a compromise of
doubtful rights between members of the same family, any person
beneficially entitled thereunder.
Illustration 1: A made a contract with B to marry C for a specified amount,
and if B denied paying then, A can obtain specific performance of the
contract.
Illustration 2: A, B, C, D are brothers and have a joint property in the
village. A, B, C made a contract to give whole property to D. D is the
 beneficiary entitled here and can claim specific performance of such
contract.
4. Tenant for life (section 23 (d):
Where the contract has been entered into by a tenant for life in due
exercise of a power, the remainder man.
Illustration: A gave his house to B for his life but had a contract that after
his death, the property will accelerate to C.
5. Remainder man: A person who inherits or is entitled to inherit property
upon the termination of the estate of the former owner. A remainderman
is a person who has an interest in the remaining property and will
eventually own it at some time in the future.
Illustration: A gave his house to B for lifetime. B is a tenant for life but had
a contract that after B’s death, the property will accelerate to C. C is
remainder man.
6. Reversioner in possession section 23 (e):
A reversioner in possession, where the agreement is a covenant entered
into with his predecessor in title and the reversioner is entitled to the
benefit of such covenant.
Reversioner in possession: Any person to whom the property is reversed
back, and he is in possession of that particular property. When a property
owner effectively transfers property to another yet retains some future
rights in the property, it is known as a reversioner in possession.
Covenant: It is a legal promise or an agreement between two people, or
companies, or even countries.
Illustration: A (grandfather), B (father), and C (son). A does not want to give
his property to B. Instead, he wanted to give his property to C. A entered
into a contract with Z (tenant for life) to enjoy his property till his life and
pay the rent to C, and after Z’s death, the property will be accelerated to C
(reversioner in possession).
Here, the reversioner in possession also has the right to obtain the specific
performance of the contract entered by another person.
7. Reversioner in remainder (section 23 (f)):
 If an agreement is a covenant and the reversioner suffers material injury in
case of breach of contract, then reversioner in remainder will be entitled to
the benefit.

Illustration:
A gave his house to B and asked to pay the rent to C. If B does not pay the
rent, then C has to bear the injury caused.
8. Public company section 23 (g):
When a public company has entered into a contract and subsequently
becomes amalgamated with another public company, the new company
which arises out of the amalgamation.
9. Promoters of company section 23 (h):
When the promoters of a public company have, before its incorporation,
entered into a contract for the purposes of the company, and such contract
is warranted by the terms of the incorporation, the company.
Case law:
Ghulam Sarwar vs. Nisar Ahmed (1990):
The case involved a contract for the sale of a house. The court held that
specific performance was appropriate when the buyer had paid the
purchase price but the seller refused to execute the sale deed, emphasizing
that the buyer´s readiness and willingness to perform their obligations were
crucial factors.
Conclusion:
Under the special relief act, 1877 specific performance of contracts can be
enforced by various parties. The contracting parties themselves have the
right to specific performance if the other party breaches contract.