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What is height of bst?

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The following numbers are inserted into an empty bst in given order 10,1,3,5,15,12,16. What is the height of the bst( the height is the maximum distance of a leaf node from the root)
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If you consider the height of root as $0$ then Height of tree will be $3$,

else it will be $4$.

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3 is the height (distance from root 10 to leaf 5

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