Judgment :- 1. Plaintiffs are the appellants. The suit was filed for a declaration that the assessment of vehicle tax of KLA 5028, a tractor-trailor, by the second defendant is illegal and without jurisdiction. It is the contention of the appellants that the tractor-trailor was mainly used for agricultural purposes in their own land, that it is exempted under S.20 of the Kerala Motor Vehicles Taxation Act and that the action taken by the respondents to collect the tax is illegal. 2. Defendants filed written statements denying the allegation that the vehicle was used only for agricultural purposes. It is also the contention of the defendants that the first plaintiff has not applied for any exemption of tax on the ground that the vehicle is being used only for agricultural purposes and that there is no illegality in the collection of the tax. 3. The only point to be considered is as to whether the plaintiffs are entitled to get exemption from payment of tax under S.20 of The Kerala Motor Vehicles Taxation Act, 1963 (Act 24 of 1963). Two conditions are postulated under S.20 of The Act to enable the registered owner or the person having the possession or control of a motor vehicle from payment of the tax. One of the conditions is that he must be an agriculturist and that the motor vehicle has been designed for agricultural operations relating to food crops. The second condition is that the vehicle is used solely for such operations in relation to his own land. If both the conditions are satisfied, the motor vehicle shall be exempted from tax. The conditions under S.20 are cumulative and therefore person claiming exemption under S.20 has to satisfy both the conditions. Plaintiffs cannot claim exemption from payment of tax, only if one of the conditions is satisfied. In this case, the tractor is having a trailer attached to it.' If can well be said to be designed for agricultural purposes-relating to food crops. But it can be exempted from tax only if it is used solely for the agricultural operations in relation to the land of the plaintiffs. The explanation to S.20 of the Act defines "agricultural operations". But it can be exempted from tax only if it is used solely for the agricultural operations in relation to the land of the plaintiffs. The explanation to S.20 of the Act defines "agricultural operations". As per the definition it includes the following: (i) tilling, sowing, harvesting, crushing of any agricultural produce or any other similar operation carried out for the purpose of agriculture; (ii) transport of manure, seeds, insecticides and other like articles required for work in the land from the market to the land; and (iii) transport of any agricultural produce from the land to the place of storage or from the place of storage to the market. To get exemption under S.20 plaintiffs have to necessarily establish that vehicle has been used solely for the agricultural operations in relations to their own land. If they failed to establish that they cannot claim exemption under S.20 of the Act. 4. Second plaintiff examined as P.W.1 in her evidence admitted that the vehicle was let out on hire to strangers. It is admitted by her that the vehicle was rented to her husband's paternal uncle. To a specific question as to how many days the tractor was used for her purposes P.W.1 stated that it was used only for six days. It is also admitted by her that for the rest of the year the tractor was let out to strangers. The evidence of P.W.1 will not show that the vehicle was used solely for the agricultural operations in relation to the land belonging to the plaintiffs. As there is the admitted evidence of P.W.1 that the vehicle was let out to the use of strangers, plaintiffs cannot claim exemption under S.20 of the Act. 5. The Sub Judge was justified in holding that the plaintiffs are not entitled to the declaration that assessment of vehicle tax of KLA 5028 by the second defendant is illegal and without jurisdiction. The Sub judge rightly held that the defendants cannot be restrained by any order of injunction from realising any amount towards tax in pursuance of Ext. A1 demand notice. There is no merit in the appeal and hence the same is dismissed with no order as to costs. Dismissed.