Breach of Unilateral Promise to Sell Versus Bona Fide Third-Party Purchaser Rights

A lower court had ordered a defendant to pay damages to a plaintiff for a breach of a promise to sell real property, despite the defendant having subsequently sold the property to a third party who was unaware of the prior agreement. The high court quashed this decision, reasoning that while the breach of a unilateral promise to sell (where the option holder has not yet exercised the option) results in damages, it does not confer a right to specific performance or an order transferring ownership to the option holder, especially when the property has been legally transferred to a good-faith third-party purchaser who has completed the necessary publicity requirements.