K.M.S UBAIDA AND ANR. vs STATE OF KERALA & ANR

The Supreme Court held that lands cultivated with teak through systematic human efforts do not qualify for exemption from the definition of private forests under the Kerala Private Forests (Vesting and Assignment) Act, 1971, as per Clause (C) of sub-section (2)(1)(F). The Court clarified that agricultural activity does not encompass teak plantation, thereby affirming the Kerala High Court's decision. The appeal was dismissed without costs.