3,568. Unusual Places for Trees
Hilchos Maaser Sheini and Neta Revai 10:5
Let’s say that someone plants trees in the public domain or on a ship, or trees grow on their own in a private domain, or a non-Jew plants a tree either for himself or for a Jew, or a thief plants a sapling that he stole. In all of these cases, the trees are obligated in orlah and neta revai.
Hilchos Maaser Sheini and Neta Revai 10:6
Trees that grow on their own in a rocky place are exempt from orlah. The same is true even if someone plants a tree in an uninhabited place, so long as the tree doesn’t produce enough fruit to make it worth caring for until the fruit could be brought to an inhabited area. If the tree produces enough fruit that it’s worth caring for, then it is obligated in orlah.