Where parties agree to forego a time stipulation in a contract, the assessment of whether a reasonable time for calling for performance has elapsed requires a broad inquiry into all the circumstances, including the purpose of the obligation, the cause of and responsibility for the delay, changes in the surrounding circumstances (including the planning framework), and the fairness of holding the obligor to the obligation. A party that is responsible for the delay in performance, and that calls for performance at a time when the obligation can no longer achieve its original purpose, may find that a reasonable time has elapsed. The question of whether a planning instrument can give rise to a 'benefit' for the purposes of the doctrine of approbation and reprobation was left open.
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