The locative, ablative, and illative forms are not considered cases by many modern authorities. Instead, they are considered combinations of the genitive case of the noun and "ಅಲ್ಲಿ," meaning "there." Therefore, "ಮರದಲ್ಲಿ" means "there of the tree." This explanation is likely because "ಅಲ್ಲಿ" can still be declined even in its combination with the genitive. For example, the "ablative" form is simply the instrumental case of "ಅಲ್ಲಿ" suffixed to the genitive. However, because many learners' grammars, traditional grammars, and a few modern authorities will give the locative case as a case, it has been included in the declension table. In any case, some may consider the locative a case that has evolved from a postposition anyway because "ಅಲ್ಲಿ" cannot be separated from the noun as with other postpositions.