O. SANFORD JASPER, AS TAX COLLECTOR OF PINELLAS COUNTY, FLORIDA, MAC S. HAINES, AS TAX ASSESSOR OF PINELLAS COUNTY, FLORIDA, FRED O. DICKINSON, JR., AS COMPTROLLER OF THE STATE OF FLORIDA, APPELLANTS,

v.

MEASE MANOR, INC., A FLORIDA NON-STOCK NON-PROFIT CORPORATION, APPELLEE

DREW, Justice.

The appellee, Mease Manor, Inc., has been granted a summary final decree holding it is entitled to exemption from ad valorem taxation because the pleadings and exhibits in this cause showed that it met all the tests for exemption of real and personal property used in the operation of its home for the aged as prescribed by Chapter 65-438, Laws of Florida, now F.S. Sec. 192.06(14), F.S.A. This statute provides:

“ * * * The following property shall be exempt from taxation: * * *

“(14) All property, real and personal, of any bona fide home for the aged, licensed by the state board of health, owned and operated by a Florida corporation not for profit, and used by such home for the aged for the purposes for which it was organized, and limited to * * * [housing for elderly persons and service personnel, medical, dining, laundry, parking, auditorium and adminis*823trative facilities] and other uses essential to the operation of such home for the aged ; provided that all income of such home for the aged remaining after payment of the usual and necessary expenses of operation, including the payment of liens and encumbrances upon its property, shall be used exclusively for educational, charitable or scientific purposes in-eluding the maintenance, improvement or expansion of its facilities.”

Although the decree incorporates extensive findings of fact,1 these findings are *824material in this appeal only so far as they reflect compliance with the minimum conditions of the statute, because the conclusion of the court was that appellee’s property was entitled to exemption under this law upon proof of those specified facts. The decree holds in effect that, in the absence of any statutory definition of the term “aged,” appellee met the requirements for exemption of the property in question by proof of (1) use as a licensed home for persons who are at least 62 years old or whose resident spouse meets that requirement, (2) ownership and operation by a Florida non-profit corporation for purposes and uses essential to the operation of such home, and (3) provisions of its articles of incorporation that any profit above expenses and payment of property encumbrances shall be used, during operation and upon dissolution, for the benefit of guests or expanded facilities and not for other private enrichment.

Appellant’s contention, in the trial court and here, is that the statute above construed is invalid because it violates the provisions of the Florida Constitution limiting tax exemption statutes to those for “municipal, education, literary, scientific, religious or charitable purposes,” Art. IX, Sec. 1, F.S.A.,2 and requiring that “the property of all corporations * * * shall be subject to taxation unless such property be held and used exclusively for religious, scientific, municipal, educational, literary or charitable purposes,” Art. XVI, Sec. 16.3

The latter section has, of course, been considered many times by this Court. We conclude from a study of the decisions, as well as the history and language of this provision in its constitutional context,4 that *825the words “shall be subject to taxation” are the precise equivalent of “shall not be exempt from taxation,” and the additional language simply excludes the specified classes of property from the preceding injunction so as to permit (but not require) exemption of corporate property used for such purposes. The last clause of this section is therefore merely negative in character, instead of affirmative or self-executing, and contrary pronouncements should stand corrected.5 The constitutional prescription concerning corporate property differs, then, from the general terms of Article IX, supra, only by expression of the requirement that corporate property be actually “used exclusively” for one of the specified purposes in order to make exemption permissible.

For practical purposes in the present case the two provisions present only the single problem of whether or not the statute, exempting all homes meeting the stated standards, is within the applicable constitutional mandate that property tax exemptions shall not be granted except for charitable purposes (no other constitutional ground for exemption being urged in support of the law).

In response to a preliminary question by appellant, examination of the language of the statute indicates that it was properly construed below to require no showing of an independent charitable purpose or use for potential income which may accrue to the corporate owner other than the purpose served by operation of the home'for aged persons, who may, so far as the law requires, be at all times self-sustaining in a financial and functional sense. The statute thus construed clearly constitutes a legislative definition of “charitable” to include operation of a home under the stated conditions for persons who are chronologically aged without regard to dependence or independence otherwise. This, we now conclude, is within the legislative prerogative.

The test for measuring such legislation against the constitutional restraints must be that of reasonable relationship between the specifically described exemption and one of the purposes which the Constitution requires to be served.6 The problem therefore differs significantly from that which has been presented in cases requiring judicial definition of the constitutional concepts in the absence of an explicit statute. Application in those cases 7 of a more limited definition of charitable use, in the primary sense of relief for the indigent or helpless, does not require or justify rejection of the current statute on constitutional grounds.8

*826Review of similar legislation in other states has prompted recognition of the fact that care of the aged, poor and otherwise, has become a problem of widespread governmental concern.9 We are unable in this situation to find that the Legislature acted arbitrarily in determining that institutions devoted to such purpose, without profit to others, serve a charitable purpose upon which tax exemption shall be based. The statute was therefore properly sustained.

The decree appealed is predicated upon a finding that respondent complied with all procedural provisions of the law governing applications for tax exemption.10 This requirement of annual re-examination of exemption status, turning on title and use of the property, has been sustained 11 as a logical means of determining taxability from year to year, and the practice should be of particular value in preventing any abuse or attempt to circumvent the basic purposes of the statute involved in this case.

Affirmed.

ERVIN, J., concurs.

ROBERTS, J., concurs in the opinion and judgment with Opinion.

THORNAL, J., concurs in opinion and also agrees with ROBERTS, J.

THOMAS, J. dissents.

WHITE, Circuit Judge (Retired), dissents with Opinion.

CALDWELL, C. J., dissents and concurs with WHITE, Circuit Judge (Retired).

ROBERTS, Justice

(concurring).

I concur in the opinion and judgment for the reasons stated herein and in the dissenting opinions in Presbyterian Homes of Synod of Fla., Inc. v. Bradenton, Fla., 190 So.2d 771.

THORNAL, J., agrees.

WHITE, Circuit Judge

(retired) dissenting.

The construction placed on the term “aged” used in Statute 192.06(14) as extending to those “who are at least 62 *827years old or whose resident spouse meets that requirement,” without regard to financial need, or physical or mental infirmity, or a state of senility resulting from advanced age, makes the statute unconstitutional as being outside the purview of the phrase “charitable purpose” used in the Constitution.

CALDWELL, C. J., concurs.