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(b) That's right. The agreement in this case involves the performance of services, but they are not 'personal' services in the same way as the previous example. The monitoring and analysis will likely be shared by various workers. The requirements of performance are clearly specified in the contract. And, if A Co. is not made to continue performing, the analysis will be set back two years. In these circumstances you might expect the court to order specific performance.

But the courts will not order specific performance if the contract involves ongoing performance by both parties over an extended period and there is no guarantee that both parties will perform as required without the court being involved in ongoing supervision. In the present case, the council has ongoing obligations to provide support and equipment to A Co., and might default on these. An order of specific performance against A Co. is therefore unlikely and the city council will have to be satisfied with an award of damages.

JC Williamson Ltd v Lukey & Mulholland (1931) 45 CLR 282.