Mishnah for Bava Batra 2:5

There are some who bring bikkurim and recite [the declaration]; others who only bring, but do not recite; and there are some who neither bring nor recite.The following are those that do not bring: one who plants [a vine] on his own property, but buries [a shoot in the ground] so that [it] grows on property belonging to [another] individual or to the public. And similarly if one buries [a shoot in the ground] of another person’s private property or in public property, so that it grows on his own property; Or, if one plants [a vine] on his own [property] and [buries it in the ground] so that it still grows on his own property, but there is a private or public road between, such a one does not bring [bikkurim.] Rabbi Judah says: such a one has to bring bikkurim.

What constitutes an orchard? Any field in which there are at least three trees for every bet seah. If each tree is capable of yielding a cake of pressed figs, the size of sixty in the Italian maneh, then the entire bet seah may be plowed for their sake. If less than this amount, they may only plow the area that is occupied by the gatherer when his basket is placed behind him.