Agricultural land test for estate duty turns on whether a prudent owner would undertake farming operations on the land.

For estate duty valuation, forest lands are excluded only if they qualify as agricultural lands, and the controlling inquiry is whether a prudent owner would undertake farming operations in relation to the lands concerned. Present user is relevant but not determinative on its own; the statutory context governs the meaning of "agricultural land" because the term is not defined in the Estate Duty Act or the Constitution. As the case record did not contain findings directed to that test, the factual basis was inadequate, and the matter had to be remitted for a clear finding on the agricultural character of the lands.

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Issues: Whether the forest lands in question were agricultural lands so as to be excluded from the estate duty valuation, and what test should be applied to determine their agricultural character.

Analysis: The expression "agricultural land" is not defined in the Estate Duty Act, 1953 or in the Constitution of India. The authorities discussed indicate that the expression may receive a wide meaning, but its content depends on the statutory context. For estate duty purposes, the crucial inquiry is not merely present use but whether a prudent owner would undertake any of the processes of farming in the widest sense in relation to the lands. Current user is relevant but not ative by itself. As the statement of the case did not contain findings directed to that test, the factual basis was insufficient for a final answer.

Conclusion: The proper test is whether a prudent owner would embark on agriculture in respect of the lands concerned, and the matter had to be sent back for the Tribunal to record a clear finding on that question.

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