In Szambelak v. Tsipouras, 2007 WL 4179315 (Del. Ch., Nov. 19, 2007), read opinion here, the Chancery Court granted specific performance in a land contract involving the sale of a farm. There are many twists and turns in the factual section of the opinion. In short, the seller did not have an attorney and the use of a "middleman" (not a realtor) added to the confusion. There was a signed agreement but the seller thought that because they had not received the down payment, the contract was not effective. The court found that due to their conduct in furtherance of the agreement, and in light of the non-material aspect of the term that they thought was not complied with, among other reasons, the discretionary remedy of specific performance was appropriate in this case. ( It is notable that the seller was apparently trying to save money by not hiring a lawyer to handle the sale, but in that approach appears to have cost them dearly in the end.)