Facts in the Case
- The term “factory” is defined under the Factories Act, 1948.
- A question arises about whether salt-making units situated in open lands—without conventional factory infrastructure—fall within this definition.
- These salt works are involved in manufacturing processes, but do not have roofed structures or enclosed buildings.
- The authorities or courts must determine if these units qualify as factories under the Act for the purpose of regulation and worker protection.
Issues in the Case
- Does the Factories Act apply to salt-making units operating in open land without traditional factory premises?
- Should the definition of “factory” be interpreted strictly (literally) or liberally (purposively) in such circumstances?
- What interpretative approach should courts adopt when applying welfare legislation like the Factories Act?
Principles Applied
1. Beneficial or Liberal Interpretation
- The Factories Act is a social welfare legislation intended to ensure health, safety, and welfare of workers.
- Courts apply a liberal (purposive or beneficial) interpretation to such laws to advance the object of the legislation, not defeat it.
- Interpretation should ensure that workers engaged in manufacturing are not deprived of legal protection due to technicalities like the absence of a roof.
2. Definition under Section 2(m) of the Factories Act
- A factory is defined as any premises where a manufacturing process is carried on with the aid of power or where more than a specified number of workers are employed.
- The term “premises” is not restricted to enclosed or covered buildings; it can include open spaces where systematic manufacturing activity occurs.
3. Judicial Precedent
Indian Petrochemicals Corp. Ltd. v. Shramik Sena, AIR 1999 SC 2577
- The Supreme Court emphasized that beneficial legislation like the Factories Act must be interpreted liberally to cover all categories of workers involved in manufacturing.
Chief Inspector of Factories v. Raman & Raman Ltd., AIR 1961 SC 161
- The Court held that physical form of the location (e.g., open land vs. enclosed building) is irrelevant if the statutory requirements of a factory are met.
Judgment
- Salt-making units on open lands carry out a manufacturing process using human labour and often mechanical power.
- Despite the absence of roofed premises, these units satisfy the criteria laid down under Section 2(m) of the Factories Act.
- Applying the principle of beneficial construction, such units should be classified as factories, thereby bringing workers within the protective scope of the Act.
