What is the current state of the law of specific performance in real estate transactions in Canada?

The law of specific performance as it relates to real estate transactions has evolved in Canada since the decision in Semelhago v. Paramadevan (1996 CanLII 209 (SCC), [1996] 2 S.C.R. 415). That case was argued on the assumption that specific performance was an appropriate remedy for the parties in Semelhago. However, in speaking about specific performance generally, Sopinka J. stated: 21. It is no longer appropriate, therefore, to maintain distinction in the approach to specific performance as between realty and personalty. It cannot be assumed that damages for breach of contract for the purchase of the sale of real estate will be an inadequate remedy in all cases. The common law recognized that the distinction might not be valid when the land had no peculiar or special value… 22. Courts have tended, however, to simply treat all real estate as being unique and to degree specific performance unless there was some other reason for refusing equitable relief… Some courts, however, have begun to question the assumption that damages will afford an inadequate remedy for breach of contract for the purchase of land…