I respectfully dissent.
In Salvation Army v. Hoehn, et al., 354 Mo. 107, 188 S.W.2d 826, 830 [6] (1945), the court, en banc, held that the words “used exclusively” appearing in what is now article X, § 6, of the constitution of Missouri, and § 137.100, RSMo 1969, have reference to the primary and inherent use as distinguished from a secondary and incidental use. See also: Frisco Employes’ Hospital Ass’n v. State Tax Commission, 381 S.W.2d 772, 779 (Mo.1964).
The present day concept of the words “purposes purely charitable” is expressed *847in Salvation Army v. Hoehn, supra, and Missouri Goodwill Industries v. Gruner, 357 Mo. 647, 210 S.W.2d 38 (1949). In Gruner, supra, the court said (l.c. 40) that the term “charity” is not confined “solely to the relief of the destitute,” but also includes “humanitarian activities * * * which are intended to improve the * * * mental * * * condition of the recipients and make it less likely that they will become burdens on society and make it more likely that they will become useful citizens.”
The accepted definition of charity, quoted in the principal opinion, embraces not only a gift but also a use of property which bestows the benefits of education directly upon an indefinite portion of the public. Of course, not all uses of property for educational purposes may be characterized as being for purposes purely charitable. The use of property of a private organization or club of professional men for educational purposes may be characterized as charitable for purposes of tax exemption if the primary purpose of that use is for the benefit of the general public and its use by members of the club merely the means adopted to support the primary purpose. But if the primary purpose of the use is to benefit its members or a limited class of persons it may not be so characterized, even though the public will derive an incidental benefit therefrom. Massachusetts Medical Society v. Assessors of Boston, 340 Mass. 327, 164 N.E.2d 325, 328 [3] (1960).
Viewed in the light of these principles, I am of the opinion that the decision of the trial court was clearly right. As indicated, one of the uses made of its Club building by the Engineers’ Club is for educational purposes during a part of the year. The programs presented at Club meetings are technical in nature and a stated objective of these programs is to enable specialists to learn to communicate with specialists in their own and allied fields. The symposiums and seminars conducted by the Club alone or with others on such subjects as mass transportation, airport planning, water quality, waste disposal and pre-stressed concrete design are no doubt educational and of benefit to members of the Club and, in general, to those other engineers and persons specializing in or otherwise associated with businesses engaged in these particular fields of engineering. Although it is said the general public is invited to these meetings, symposiums and seminars, the very nature of the programs presented would tend to discourage, and probably effectively exclude, the attendance of the public in general. Clearly, the programs are not so designed and attuned as to attract and encourage their attendance. It may not be said, in my opinion, that these uses of the Club property are primarily for the direct benefit of the public. On the contrary, its use is primarily for the benefit of Club members and others having closely allied interests, “a limited class of persons.”
The education-oriented uses made of the property by the Club are praiseworthy in that their purpose is to advance the knowledge and skills of members of engineering and related professions by continuing their education. No doubt a better informed and prepared group of professionals is of benefit to the public, but in this case it is an indirect and purely incidental benefit.
For these reasons, I would hold that the uses made of this property were not exclusively for purposes purely charitable, and that it is not exempt from ad valorem taxes levied for the year 1970.