SHRIMANT SARDAR CHANDROJIRAO ANGRE vs STATE OF MADHYA PRADESH

The Supreme Court interpreted Section 5(b)(iv) of the Madhya Bharat Abolition of Jagirs Act, 1951, determining that a 'grove' can consist of trees not necessarily fruit-bearing or planted by human agency, provided they are sufficiently numerous to characterize the land as a grove. The Court held that the appellant's mango trees, planted along a road, did not meet the criteria for a grove as they were not grouped sufficiently to preclude other uses of the land. Consequently, the appellant's claim to the trees was denied, affirming the lower court's decision.