CONTROLLER OF ESTATE DUTY, KERALA vs V. VENUGOPALA VARMA RAJAH

The Supreme Court held that under Section 5 of the Estate Duty Act, 1953, agricultural land is subject to estate duty upon the owner's death. The Court restricted the definition of 'agricultural land', stating it must be determined based on actual or intended agricultural use, rather than a broad interpretation. The Court overturned the High Court's ruling that forest-covered land in Malabar was agricultural, concluding it was non-agricultural as it was not actively developed for farming purposes.