It has been claimed that products include minerals that have been extracted from soil, water, oil, gas, and even air (in the form of compressed air). However, the landowner may grant the right to draw water, extract oil or gas, or other minerals from the soil as a disposition of an interest in the land and not as a sale of goods.
The Supreme Court ruled in Mahadeo v. State of Bombay, AIR 1959 SC 735, that transactions involving items that are a component of the soil itself, such as coal or other minerals, gravel, or sand that the buyer may remove, are not sales of goods.
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