In Campbell Inns, Inc. v. Banholzer, Turnure & Co., 527 A.2d 1142 (Vt. 1987), the court ordered an injunction for specific performance where a defendant seller refused to sign an agreement subordinating his lien on the plaintiff purchaser's property, even though their sales contract required him to do so. Id. at 1143.
On appeal, the Vermont Supreme Court affirmed the injunction because if the defendant did not sign the agreement, the plaintiff would be unable to secure other financing for their inn, causing them to lose the inn. Id. at 1146.
In reaching that result, the court noted that "loss of a business" satisfies the irreparable injury requirement for a preliminary injunction. Id.