province of New Brunswick, the Law Reform Act provides that a penalty clause is enforceable "to the extent that it is reasonable in all of the circumstances" and that "a court may determine in the circumstances of a case before it that a penalty clause or a liquidated damages clause should be enforced in full, in part or not at all". The Canadian position in both Québec and the common law provinces is similar to the middle-ground approach taken under Philippine contract law, which provides that a penalty clause providing for liquidated damages is enforceable unless either the clause is "iniquitous or unconscionable" or the breach of contract in question is not one that was envisioned by the parties when they concluded the contract. Article 1226 of the French Civil Code provides for clause pénale, a variant of liquidated damages which combines compensatory and coercive elements. Judges may adjust excessive contract penalties, but such clauses are not generally void as a matter of French law. In Louisiana, which follows a civil law system similar to those of Québec and France, liquidated damages are referred to as "stipulated damages". Prior to 1 January 1985, Louisiana law used the term “penal clause” under former article 2117 of the Civil Code. Stipulated damages create a secondary obligation for the purpose of enforcing the principal obligation. The aggrieved party may demand either the stipulated damages or performance of the principal obligation, but may not demand both except for delay. Stipulated damages may not be modified by the court (and will therefore be enforced) "unless they are so manifestly unreasonable as to be contrary to public policy". Article 420-1 of the Civil Code of Japan provides an even firmer basis to uphold contractual penalties: The parties may agree on the amount of the liquidated damages with respect to the failure to perform the obligation. In such case, the court may not increase or decrease the amount thereof. The liquidated damages shall not preclude the demand for performance or the exercise of the cancellation right. Any penalty is presumed to constitute liquidated damages. Specific relief Where the court determines damages not to provide an adequate remedy for a breach of contract, they may provide for specific performance or an injunction. In common law provinces, the rules regarding remedies other than damages are derived from equity and are seen as the exception to the general rule that