Broad meaning of agricultural lease brings casuarina plantation within special transfer rules, excluding general lease formalities.

A lease of land for growing casuarina trees for fuel was treated as an agricultural lease because "agricultural" was given a broad meaning that includes cultivation of useful products derived from the soil with human skill and labour, not only food crops. The court noted that casuarina plantation involved preparation of the ground, watering and protection, which brought it within agricultural use. On that basis, the lease fell within Section 117 of the Transfer of Property Act and was outside the operation of Section 107.

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Issues: Whether a lease of land for growing casuarina trees for fuel is a lease for agricultural purposes within the meaning of Section 117 of the Transfer of Property Act, and whether such a lease is outside the operation of Section 107 of the Transfer of Property Act.

Analysis: The term "agricultural" was construed in its wider sense as covering the raising of useful or valuable products derived from the soil with human skill and labour, not merely food crops. A narrow construction would unjustifiably exclude several forms of cultivation, including fibrous, dye, timber, and flowering plants. Casuarina plantation involved preparation of the ground and subsequent care such as watering and protection, and therefore answered the description of agricultural use. On that footing, the special conclusions reached in earlier Estates Land Act cases did not govern the present question.

Conclusion: A lease for casuarina plantation is an agricultural lease within Section 117 of the Transfer of Property Act and is not governed by Section 107 of the Transfer of Property Act.

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