Where a lessee gives notice of exercise of an option to renew a lease but fails to satisfy other conditions for the option's exercise (such as being in arrears of rent) before the lease expires, no obligation arises for the lessor to grant a further lease, and equitable relief against forfeiture is not available because no interest survives the expiry of the lease. The lessee's interest under an option for renewal is commensurate with the availability of specific performance, and where there is nothing to specifically perform, there is no interest to relieve from forfeiture. The reasoning of Gibbs J in Mercantile Credits regarding an option for renewal creating an 'interest in land' is properly understood as referring to the Torrens system concept, not to an interest capable of founding equitable relief against forfeiture.
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