Broad meaning of premises under the Factories Act confirms salt works can qualify as a factory through manufacturing activity.

Under the Factories Act, 1948, "premises" is construed broadly and is not confined to buildings; it can include open land with temporary shelters where statutory manufacturing activity is carried on, so salt works may fall within the definition of a factory. The conversion of sea water into salt is also a manufacturing process because the operations at the works treat and adapt the raw material into a distinct commercial product through human agency aided by natural forces. On that basis, the salt works answered the statutory definition of a factory and required the prescribed licence.

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Issues: (i) Whether salt works carried on in the open, with only temporary shelters and ancillary structures, fall within the expression "premises" in the definition of "factory" under the Factories Act, 1948. (ii) Whether the conversion of sea water into salt amounts to a "manufacturing process" under the Factories Act, 1948.

Issue (i): Whether salt works carried on in the open, with only temporary shelters and ancillary structures, fall within the expression "premises" in the definition of "factory" under the Factories Act, 1948.

Analysis: The expression "premises" was held to be a generic term capable of including open land as well as land with buildings or buildings alone, depending on context. The inclusive phrase "premises including precincts" did not restrict the word to buildings. Internal provisions of the Act, including the reference to premises and to separate buildings within premises, supported a wider meaning. The welfare purpose of the Act also favoured a construction that did not exclude workers engaged in manufacturing activity merely because it was carried on in the open.

Conclusion: The salt works were within the expression "premises" and could constitute a factory.

Issue (ii): Whether the conversion of sea water into salt amounts to a "manufacturing process" under the Factories Act, 1948.

Analysis: The work at the salt works involved directing sea water into reservoirs, managing crystallising beds, controlling density, scraping and collecting crystals, grading, sieving, and bagging. These operations showed treatment and adaptation of sea water into a new commercial article, namely salt. The process was not attributable to natural forces alone, but to human agency aided by natural forces. The finished article was different from the raw material and was brought into saleable condition by the operations carried on at the works.

Conclusion: The conversion of sea water into salt was a manufacturing process.

Final Conclusion: The salt works answered the statutory definition of a factory, and the appellant was liable for working it without the required licence.

Ratio Decidendi: Under the Factories Act, 1948, "premises" is not confined to buildings and includes open land where the statutory manufacturing activity is carried on, and a process that converts a raw substance into a distinct marketable product by human effort aided by natural forces is a manufacturing process.

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