In what circumstances will a court refuse to order the sale of a jointly owned property?

In Davis v. Davis, supra, Laidlaw J.A. stated: In my opinion the change made in the legislation in 1913, whereby the court obtained discretionary power to allow or refuse an application for partition or sale of lands, did not alter the policy of the law theretofore existing or the fundamental considerations which ought to prevail in reaching a decision in the matter. There continues to be a prima facie right of a joint tenant to partition or sale of lands. There is a corresponding obligation on a joint tenant to permit partition or sale, and finally the court should compel such partition or sale if no sufficient reason appears why such an order should not be made. I do not attempt to enumerate or describe what reasons would be sufficient to justify a refusal of an order for partition or sale. I am content to say that each case must be considered in the light of the particular facts and circumstances and the court must then exercise the discretion vested in it in a judicial manner having due regard to those particular facts and circumstances as well as to the matters which I have said are, in my opinion, fundamental.