1. A rather interesting question has arisen for decision in this case. That concerns the construction of S.87 of the Kerala Land Reforms Act and may be of importance as a question of common occurrence in future. When any land is exempt from the provisions of Chapter III of the Kerala Land Reforms Act, 1963, as land falling within the exempted categories specified in S.81(1) of the Act, whether a subsequent conversion of that land into a non-exempt category obliges the owner to surrender land as excess under S.87 of the Act denning such land as a quired on the date of conversion? Private forest is a category of land exempted from the ceiling provisions of the Act. If on 1-1-1964 the land was private forest it is exempt from the ceiling provisions on 1-1-1970 and therefore irrespective of the extent of such private forest held by a person on 1-1-1970 he can hold other land to the extent of the maximum permissible ceiling area. If such a person subsequently acquires land other than that in the exempted category he is liable under S 87 of the Act to surrender the excess arising by reason of such acquisition. That is provided for in order to prevent accumulation of lands in