‘Agricultural Land’ – something or other can be, and often is, grown on any vacant land, but that would not necessarily make it agricultural land for our purposes.

sarfaesi, Sarfaesi S. 31

“We suppose that something or other can be, and often is, grown on any vacant land, but that would not necessarily make it agricultural land for our purposes. To give an example the possibility of cultivating, or even the actual cultivation of, what is essentially a building site in the heart of a town would not make it agricultural land. It is the purpose for which it is held that determines its character and the existence of a few coconut trees or a vegetable patch on the land cannot alter the fact that it is held for purposes of building and not for purposes of agriculture.”

Kunjukutty Saheb v. State of Kerala, 1972 2 SCC 364