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(c) a contract which is in its nature determinable;"

10.7 Section 10, which dealt with the duty of courts to specifically enforce contracts capable of specific performance, too, underwent a significant change with the 2018 Amendment Act, though the change does not seriously impact the controversy in the present case. The consequence of the change was that courts are now required mandatorily to order specific performance of contracts which are capable of specific performance. Prior to the amendment, Courts had the discretion to enforce, or not to enforce, specific performance. That discretion now stands eviscerated, with the amendment of Section 10. Section 10, before and after amendment, reads thus:

Before amendment "10. Cases in which specific performance of contract enforceable. - Except as otherwise provided in this Chapter, the specific performance of any contract may, in the discretion of the court, be enforced -

performance would not afford adequate relief.

After amendment "10.Specific performance in respect of contracts. -

The specific performance of the contract shall be enforced by the court subject to the provisions contained in sub- section (2) of section 11, section 14 and section 16."

10.10 A contract which is "in its nature determinable" was incapable of specific performance by virtue of the erstwhile Section 14(1)(c), and continues to remain incapable of specific performance by virtue of the present Section 14(d).

11. Mr. Baruah has invoked clauses (c) and (d) of Section 14. He has relied on decisions which, according to him, render a contract, such as the present, incapable of specific performance, as being "in its nature determinable". As this clause remains unchanged, even after the amendment of the Specific Relief Act, 1963 it would be appropriate to, in the first instance, examine this contention of Mr. Baruah, vis-à-vis, the response of Mr. Sandeep Sethi thereto.