Question

Ajeet Singh, a famous singer, enters into a contract with Yash Aditya Music Company agreeing to perform exclusively for them for 2 years and not to perform for any other company during that period. After one year, Ajeet Singh refuses to perform for Yash Aditya Music Company and begins performing for BR Chopra & Company. Yash Aditya Music Company files a suit seeking an injunction restraining Ajeet Singh from performing for BR Chopra & Company. Which of the following statements is correct under the Specific Relief Act, 1963?

• A. The court must compel Ajeet Singh to sing for Yash Aditya Music Company.
• B. Only damages can be granted.
• C. The injunction may be granted to enforce the negative covenant.
• D. The injunction must be refused because contracts of personal service cannot be enforced.

Hint:

Remember the formula: \[ \text{Personal Service Contract} \Rightarrow \text{No Specific Performance} \] but \[ \text{Negative Covenant} \Rightarrow \text{Injunction Possible} \] This is one of the most frequently tested principles under the Specific Relief Act.

Answer 1

The Correct Option is C

The cleanest way to work through this fact pattern is to separate what Ajeet Singh promised to do from what he promised not to do, and then match the available remedy to each part separately.

1. Positive obligation (to sing for Yash Aditya): This depends on personal skill and artistic judgment, so a court will not compel him to actually perform, ruling out the option that the court must force him to sing.
2. Negative obligation (not to sing for anyone else): This is a separate, standalone promise that does not require the court to supervise any personal performance, it only requires Ajeet Singh to refrain from acting for a rival. Courts are willing to enforce exactly this kind of restraint through an injunction, which is why an injunction is available here even though specific performance of the positive obligation is not.
3. Why "only damages" falls short: Damages would leave Yash Aditya without any way to actually stop Ajeet Singh from performing for BR Chopra during the exclusivity period, defeating the value of the exclusivity clause itself; the law does not restrict the remedy to damages when an effective negative injunction is available.
4. Why "injunction must be refused" falls short: This option wrongly assumes that because the positive obligation cannot be enforced, no relief at all is available. In reality the bar on enforcing personal service contracts only blocks compelled performance, it does not block a negative injunction restraining the breach of the exclusivity promise.

Since the negative promise not to perform for anyone else can be independently enforced by injunction, regardless of the bar on specifically enforcing the positive promise to perform, the correct answer is that the injunction may be granted to enforce the negative covenant.

Answer 2

This fact pattern deliberately mirrors a well-known line of cases involving performers who agreed to exclusivity, so testing the options against that established pattern of reasoning gives a reliable check.

1. The court must compel Ajeet Singh to sing for Yash Aditya Music Company: In the classic performer-exclusivity cases, courts have consistently refused to order an artist to actually perform, since forcing an unwilling performer to sing or act would be both impractical to supervise and inconsistent with treating personal service as involuntary servitude. This option runs directly against that consistent judicial approach.
2. Only damages can be granted: The recurring lesson from these cases is that damages alone are treated as inadequate to protect the value of an exclusivity arrangement, because a rival company benefiting from the artist's talent during the very period of exclusivity causes harm that a later damages award cannot fully undo. Courts have therefore gone further than damages in such situations.
3. The injunction may be granted to enforce the negative covenant: The established pattern in these cases is to restrain the performer from working for the rival for the remaining contract period, without ordering them to work for the original party. That is precisely the relief being sought here, and it fits the recognised approach to exclusivity promises made by performers.
4. The injunction must be refused because contracts of personal service cannot be enforced: This option overstates the personal-service bar by treating it as a total bar on any relief, when the recognised judicial approach has always distinguished between refusing to compel performance and being willing to restrain a competing performance.

Following the same reasoning consistently applied to performer-exclusivity disputes, the outcome here is that the injunction may be granted to enforce the negative covenant, restraining Ajeet Singh from performing for BR Chopra & Company without compelling him to perform for Yash Aditya.