In a large number of cases a court of equity will lays in payment, the sellers are ignorant people of foreign extraction.

48. Tildersley v. Clarkson, 30 Beav. 419; Marks v. Gates, 154 Fed. 481, 12 Ann. Cas. 120, 14 L. R. A. (N. S.) 317, 83 C. C. A. 321; Clark v. Rosario Mining & Milling Co. 176 Fed. 180, 99 C. C. A. 534; Alabama Cent. R. Co. v. Long, 158 Ala. 301, 48 South 363; Swint v. Carr, 76 Ga. 322, 2 Am. St. Rep. 44; Koch v. Streuter, 232 111. 594, 83 N. E. 1072; Goodwin v. Springer, 233 111. 229, 84 N. E. 234; Wilson v. Larson, 138 Iowa, 708, 116 N. W. 703; George Gunther, Jr., Brewing Co. v. Brywczynski, 107 Md. 696, 69 Atl. 514; Banaghan v. Malaney, 200 Mass. 46, 128 Am. St. Rep. 378, 19

L. R. A. (N. S.) 871, 85 N. E. 839; Miller v. Laneda, 75 Or. 349, 146 Pac. 1090; Latta v. Hax, 219 Pa. St. 483, 68 Atl. 1016; Colonna Dry Dock Co. v. Colonna, 108 Va. 230, 61 S. E 770.

49. Lake Erie Land Co. v. Chilin-ski, 197 Mich. 214.

Also where there has been overreaching or sharp practices, Gibbs v. Mintline, 175 Mich. 626.

No relief will be granted where the contracts are not mutual. Hol-lingshead v. Morris, 172 Mich. 126.

For a case where relief was denied because the contract was oppressive see Realty Co. v. Shaffer, 176 Mich. 639.

50. Pomeroy Eq. Jur., Sec. 2209.

51. Pomeroy Eq. Jur., Sec. 2209.

not undertake to specifically perform a contract, because of the nature of the promise, as in the case of contracts for personal service, agreements to procure the assent of third persons, agreements requiring special knowledge, skill, etc., or in cases of incapacity of the parties, or where plaintiff's promise is too indefinable and uncertain, while the contract remains executory in all these cases equity will not afford relief, because of lack of mutuality on the right and obligations growing out of the circumstances of the parties or the nature of the contract, but where such contracts have been executed on the part of the person in whose favor the disability exists then equity will specifically perform the contract.52

Thus, in cases, when a contract for the conveyance of land in consideration for personal services has been entered into as we have seen,53 specific performance cannot ordinarily be invoked to compel the rendering of such personal service, but where such personal services have been fully performed, then specific performance of the contract may be had.54