dissenting.
Perhaps, as counsel for the College suggest, Camp Sequoya is the finest camp in the area. It may preeminently teach swimming, sailing, horseback riding, tennis, archery, riflery, golf, drama, drawing, painting, composition, design, music appreciation, ballet and literature. But the record shows that Camp Sequoya is after all just another summer camp, like hundreds of other summer camps dedicated to recreation for campers and profit for owners.
The record makes clear, I believe, why Sullins College invested substantial sums in land, buildings and equipment for a summer camp. The College’s sound business judgment has been proved by the $483,000 of net income produced by Camp Sequoya for the College during the period 1959-1968—about 24% of the College’s net income during that period.1
Understandably, the faculty, students and alumni use the bucolic Camp property for meetings, dances and mixers during the academic year. But those activities are quite incidental to the primary use of the Camp property. As brought out by a witness for the College, the Camp property is vacant most of the time, except in the summer. And during the summer it is used as a camp for precollege-age girls.
Accordingly, in my opinion, the Camp property is not exempt from taxation under § 183 of the Constitution of Virginia. Paragraph (d) exempts only property “primarily used for literary, scientific or educational purposes or purposes incidental thereto”. Because the Camp property is used primarily as a recreational summer camp, and only incidentally for educational purposes, I believe the property is expressly excluded from the exemption afforded by paragraph (d).2
But even if the Camp property were used primarily for educational purposes or purposes incident to education, its property cannot be *598exempt from taxation because of a subsequent provision of § 183: “Whenever any building or land, or part thereof, . . . shall be leased or shall otherwise be a source of revenue or profit, all of such buildings and land shall be liable to taxation as other land and buildings in the same county, city or town.” The record shows not only that profit was intended, but also that profit has been abundantly realized from the operation of Camp Sequoya.
Our holdings in Hanover County v. Trustees of Randolph-Macon College, 203 Va. 613, 125 S.E.2d 812 (1962), and Richmond v. Southside Bay Nursery Assn, 207 Va. 561, 151 S.E.2d 370 (1966), do not control this case. The Randolph-Macon case involved land bought by the college to be made available to its faculty for housing. The evidence showed that the college was concerned about the lack of available housing for its faculty and'bought the land in the belief “that if capable faculty members were to be obtained and retained, and if the college was to perform the functions for which it was established, it was necessary to extend its campus to have land available upon which the members of the faculty could construct their own homes”. 203 Va. at 616, 125 S.E.2d at 815. We held the property exempt under § 183 of the Constitution because it was acquired and held by the college primarily for educational purposes, even though a profit of $915 had been incidentally realized by the college upon the sale of lots to faculty members.
The Southside Bay Nursery case involved property owned by a non-profit corporation and used as a nursery for children of working parents. The evidence showed that the Southside Day Nursery employed an executive director and four supervisors for the children, “all college trained in the field of childhood education”. 207 Va. at 564, 151 S.E.2d at 373. According to a witness, “Southside is a ‘model [nursery] for persons interested in establishing centers to * * * observe the program, the equipment, the phyiscal plant, the general environment that is so important to training the young child’ ”. Id. This witness stated further “that Southside is not a ‘babysitting organization’ and that it has a ‘very fine educational program’ ”. Id. The City produced no evidence to the contrary. We upheld the trial court’s finding that Southside’s property was used primarily for educational purposes and therefore exempt under § 183 of the Constitution.
The Randolph-Macon and Southside Bay Nursery cases, though they are factually quite different and do not control this case, admittedly reflect a liberal construction of § 183 of the Constitution. *599But they can no longer be regarded as the high water mark. Today the Court not only holds that the operation of a summer camp is primarily for educational purposes or purposes incident to education, but it also holds that a summer camp that contributes about 24% of its owner’s (the College’s) net income is not a source of revenue or profit.
The Court justifies today’s extension by the judicially declared rule that a liberal construction should be given to the exemption provisions of the Constitution, a rule announced in Commonwealth v. Lyncburg YMCA, 115 Va. 745, 80 S.E. 589 (1914), and repeated in later cases including Richmond v. Southside Day Nursery Assn, supra. That rule was considered and rejected, however, by the Commission on Constitutional Revision. Commission on Constitutional Revision, Report: The Constitution of Virginia 306 (1969).
Rather than extending past decisions, I believe we should heed the will of the people. Following the Commission’s recommendation, they expressed their will in Article 10, § 6(f), of the ,Constitution of Virginia effective July 1, 1971: “Exemptions of property from taxation as established or authorized hereby shall be strictly construed.” Believing we should at least refrain from further liberalizing our construction of § 183 of the present Constitution, I would deny exemption to the Camp property.
The majority opinion states that repairs to buildings and depreciation have not been deducted from net income. However, counsel for Washington County asserted in their brief, and counsel for the College did not deny, that during the ten-year period the College received an additional $145,000 from operation of the Camp because certain general expenses of the College were charged to the Camp.
An academic who testified as an expert witness for the College expressed the opinion that “any experience which would assist a child to find his niche in society and to become a useful member of society is in effect educational”. In his view “horseback riding”, “water skiing”, or merely “being together in a group” is educational. Camp Sequoya of course would qualify as an educational institution under this expert’s all encompassing definition. To adopt his definition as the Constitutional meaning of “educational”, which I believe unwarranted, would vitiate the restrictions set forth in paragraph (d).