Urban land exemption applications can survive vesting when statutory context makes the exemption provision workable and effective.

An exemption application under Section 20(1)(a) or Section 20(1)(b) of the Urban Land (Ceiling and Regulation) Act remains maintainable even after excess vacant land has vested in the State under Section 10, because the exemption scheme depends on prior determination of ceiling excess. The definition of "to hold" in Section 2(1) applies to computation of ceiling area, but it does not control Section 20 where that meaning would make the provision unworkable. The Court held that context can displace a statutory definition when necessary to preserve the purpose of the exemption provision, and upheld the availability of the remedy despite vesting.

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Issues: Whether an application for exemption under Section 20(1)(a) or Section 20(1)(b) of the Urban Land (Ceiling and Regulation) Act, 1976 is maintainable after excess vacant land has vested in the State under Section 10, and whether the definition of "to hold" in Section 2(1) governs Section 20.

Analysis: The scheme of the Act requires declaration, statutory deductions, computation of ceiling area, and final determination of excess land before a person can know the exact extent of land liable to be surrendered. Until that process is complete, it is not possible to meaningfully seek exemption, because the declarant may not know whether there is any excess and, if so, its precise extent. The definition of "to hold" in Section 2(1) applies to computation of ceiling area and preliminary determination, but the context of Section 20(1)(a) and Section 20(1)(b) requires a different meaning. If the definition in Section 2(1) were applied to Section 20, the provision would become unworkable, because an application could not be made before determination of excess and could not be made after vesting. The Court also noted that the view taken by the High Court was consistent with earlier decisions.

Conclusion: An application for exemption under Section 20(1)(a) or Section 20(1)(b) is maintainable even after vesting of excess land under Section 10, and the definition of "to hold" in Section 2(1) does not control Section 20 in that context.

Final Conclusion: The challenge to the High Court's view failed, and the exemption remedy under Section 20 remained available despite prior vesting under Section 10.

Ratio Decidendi: A statutory definition yields to context where its application would defeat the purpose of the provision, and an exemption scheme dependent on determination of excess land remains available after final vesting if the Act so requires by context.

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