Courts in several other jurisdictions have also held that "school purpose" or "school purposes" means something more than classroom instruction alone. See, e.g., McCullough v. Swifton Consol. Sch. Dist., 202 Ark. 1074, 155 S.W.2d 353, 354 (1941); Wilcox County Sch. Dist. v. Sutton, 265 Ga. 720, 461 S.E.2d 868, 870 (1995) ("`[S]chool purposes' means `any activity that is necessary in the proper maintenance and operation of a school under our present school system. . . .'") (quoting Bd. of Educ. of Appling County v. Hunter, 190 Ga. 767, 10 S.E.2d 749, 750 (1940)); Mahrenholz v. County Bd. of Sch. Trs. of Lawrence County, 125 Ill.App.3d 619, 80 Ill.Dec. 870, 466 N.E.2d 322, 328 (1984) ("[T]he term `school purpose' does not require the actual holding of classes."); Orleans Parish Sch. Bd., 700 So.2d at 872-75 ("School purposes" indicates a "general category of purposes related to the City's schools rather than the single specific purpose of an actual school."); Koonz v. Joint Sch. Dist. No. 4, Vill. of Gresham, Shawano County, 256 Wis. 456, 41 N.W.2d 616, 619 (1950). We agree with the Mahrenholz court's observation that had a grantor intended to limit the use of property to classroom instruction alone, the grantor could have simply stated so explicitly. 466 N.E.2d at 327.

In the context of a deed such as is being considered here, "school purposes" means "any activity that is necessary in the proper maintenance and operation of a school under our present school system . . . ." Bd. of Ed. of Appling County v. Hunter, 190 Ga. 767 (2) ( 10 S.E.2d 749) (1940). Evidence adduced at the hearing established without dispute that the land on which the old school building is located has been and continues to be part of the campus of the consolidated county school complex.

The court held that the land, when used for the purpose of a bus station for school children, had not been abandoned for school purposes. In Board of Education of Appling County v. Hunter, 190 Ga. 767, 10 S.E.2d 749, the court held that the mere fact that the school board subsequently built a larger school on nearby land and permitted one or more of its teachers to occupy the original schoolhouse on the land, did not show an abandonment of the property for school purposes so as to cause a reverter under a reverter clause. It also has been held that school land being used for parking purposes for the school district was being used for a "school purpose."

1. In Board of Ed. of Applying County v. Hunter, 190 Ga. 767 (1) ( 10 S.E.2d 749), it was held: "Under the language of the deed conveying to a county board of education land for `school purposes' with a reversionary clause as to the title if the land ceased to be used for `educational purposes,' the mere facts that the board built another larger school near by, and had permitted a teacher to live in the schoolhouse on the land in question, would not cause a reverter." See also Fleishel Kimsey v. Hightower, 62 Ga. 324.

Cited and discussed the following: 19 Am. Jur., Sec. 32, p. 523; Allen v. Boykin, 190 Miss. 417; Board of Education of Village of Van Wert v. Edson, 98 Am. Dec. 114; Board of Education Appling County v. Hunter, 10 S.E.2d 749; Gaston v. Mitchell, 192 Miss. 452, 8 R.C.L. pp. 978, 1037; James, et al. v. Gulf Refining Co., 206 Miss. 781; Kennedy v. Kennedy, 183 Ga. 432, 188 S.E. 722; 109 A.L.R. 1143; Kent, et al. v. Stevens, 127 Miss. 529; Kilpatrick v. Twin, (Miss.), 10 So.2d 447, Am. Jur. Sec. 206, 26 C.J.S. Sec. 169, p. 566; Lee v. Dunnaway, 114 So. 353; McCloud v. Clark, 110 Miss. 861; McCullough v. Swifton Consolidated School Dist., 155 S.W.2d 353; Sec. 6373 Code 1942; Miller v. Board of Supervisors of Tunica County, 67 Miss. 651; New Hebron Consolidated School Dist. v. Sutton, 151 Miss. 475; Pabst v. Hamilton, 133 Cal. 631, 44 L.R.A. (N.S.) 1226; Poitevent v. Board of Supervisors Hancock County, 58 Miss. 810; Richardson v. Moore, et al., 198 Miss. 741; Sherman v. Town of Jefferson, (Ill.), 131 N.E. 624; Words Phrases, Perm. Ed., Vol. 28, Pocket Ed.; Y. M.V.R.R. Co. v. Traction Co., 100 Miss. 281. Ethridge, J.

The property here sought to be taxed was exempt under the constitution and laws of this State. See Board c. v. Hunter, 190 Ga. 767 ( 10 S.E.2d 749). Judgment affirmed. All the Justices concur, except Hewlett, J., not participating.

We have discussed the above cases because this court cited them without analysis in the opinion on the first appeal of this cause and because the parties differ in their interpretation of these authorities. The following authorities also support the view that "school purpose" may encompass something less than the actual holding of classes: Koonz v. Joint School District No. 4 (1950), 256 Wis. 456, 41 N.W.2d 616 (deed specified "school purposes only," otherwise to revert; held, no reverter where building was left with all equipment and books, a coal supply, and was insured); McCullough v. Swifton Consolidated School District (1941), 202 Ark. 1074, 155 S.W.2d 353 (deed specified "school purposes only," to revert if abandoned by school district; held, where the property was to be used for school bus waiting station, bus "turnaround," and gymnasium, the school district has not abandoned it for school purposes); and Board of Education v. Hunter (1940), 190 Ga. 767, 10 S.E.2d 749 (deed specified "school purposes," and reversion if the property ceased to be used for "educational purposes"; held, board's constructing a larger school nearby did not suffice to show abandonment for school or educational purposes). Parenthetically, we note that the phrase "school purposes" is often used in statutes of this State today ( e.g., Ill. Rev. Stat. 1981, ch. 122, pars. 5-17, 5-21, 5-30, 10-22.

See McCallum v. Quarles, 214 Ga. 192 (1) ( 104 S.E.2d 105); Williams v. Shaffer, 222 Ga. 334, 336 ( 149 S.E.2d 668). 2. Power is conferred on the counties of this state "to levy and collect taxes for educational purposes..." Code Ann. § 32-1127 (Code § 32-1127; Ga. L. 1922, pp. 81, 82). "[T]he words `educational purposes' are to be given the broadest significance" ( Wright v. Absalom, 224 Ga. 6, 9 ( 159 S.E.2d 413)) and include "`any activity that is necessary in the proper maintenance and operation of a school...'" Board of Education c. v. Hunter, 190 Ga. 767 (2) ( 10 S.E.2d 749); Board of Comm. c. v. Bond, 203 Ga. 558, 560 ( 47 S.E.2d 511). Our Constitution provides: "School tax funds shall be expended only for the support and maintenance of public schools, public education, and activities necessary or incidental thereto, including school lunch purposes."

The plaintiff thus waived any irregularity in the filing of the demurrers, Mayo v. Owen, 207 Ga. 641 ( 63 S.E.2d 649); and since there is no exception to the sustaining of the special demurrers, such action constitutes the law of the case. Prescott v. Ellis, 178 Ga. 822 ( 174 S.E. 525); Board of Ed. of Applying County v. Hunter, 190 Ga. 767 ( 10 S.E.2d 749); Roles v. Edward, 49 Ga. App. 527 ( 176 S.E. 106). The question for determination in this case, therefore, is whether or not the petition set forth a cause of action after the sustaining of the special demurrers. Watson v. Atlanta Gas Light Co., 46 Ga. App. 326 ( 167 S.E. 718).

Invoking the foregoing principle, many courts have held that a condition limiting the use of conveyed premises to school purposes is not violated by the cessation of classroom instruction where the school premises are not being abandoned but are to be used for purposes which are broadly related to the community's public educational system or needs. See Koonz v. Joint School Dist., 256 Wis. 456, 41 N.W.2d 616 (1950); Board of Education v. Hunter, 190 Ga. 767, 10 S.E.2d 749 (1940); McCullough v. Swifton Consolidated School District, 202 Ark. 1074, 155 S.W.2d 353 (1941); Crane v. Hyde Park, supra; Mills v. Evansville Seminary, supra. See also Board of Education v. Brophy, supra, at page 63, where Vice-Chancellor Lewis, in discussing the analogous issue before him, pointed out that: