Why Did the Supreme Court of Canada,in 2009,expressly Reaffirm That

Why did the Supreme Court of Canada,in 2009,expressly reaffirm that restrictive covenants in the sale of a business are subject to less scrutiny than other applications of restrictive convenants?

A) because the clauses are typically reasonably clear as stated
B) because there is typically a power balance in business transactions
C) because the clauses are typically time limited and less intrusive
D) because the vendor typically receives consideration for good will