Agricultural lease includes casuarina plantation land use, so the lease falls outside Section 107 formalities.

Cultivation of land for casuarina trees was held to fall within the wider meaning of "agriculture" under Section 117 of the Transfer of Property Act, because it involved preparation of the soil and continued human care and labour for a useful product. A narrow reading confined to food crops was rejected as inconsistent with the ordinary meaning and statutory policy. The lease of land for a casuarina plantation was therefore treated as an agricultural lease and was not governed by Section 107 of the Act.

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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 consequently not governed by Section 107 of that Act.

Analysis: The expression "agriculture" was construed in its wider sense as embracing cultivation of the soil for useful or valuable products derived with human care and labour. A narrow construction limited to food crops was rejected as inconsistent with the ordinary meaning of the term and with the scope of the statutory policy. The cultivation of casuarina trees involved preparation of the ground and subsequent care, and therefore fell within agricultural use. The earlier restrictive views on the term were not accepted for the purpose of this Act.

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

Ratio Decidendi: "Agriculture" in Section 117 of the Transfer of Property Act includes the cultivation of land for useful or valuable growths, including tree plantations, where human skill and labour are employed.

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