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Issues: Whether employees performing timekeeping and allied clerical duties in a factory fall within the definition of "worker" under the Factories Act, 1948.
Analysis: The definition of "worker" in section 2(1) of the Factories Act, 1948 is wide and extends beyond persons directly engaged in manufacturing to those employed in work incidental to or connected with the manufacturing process. The definition of "manufacturing process" in section 2(k) is also framed broadly. On the findings of fact, the employees prepared pay sheets, maintained attendance and leave records, kept job-card particulars, dealt with settlement matters and maintained records connected with the running of the workshop. The Court held that the Act is welfare legislation and must receive a liberal construction so as to advance its object without doing violence to the language. The deletion of the word "whatsoever" from the earlier enactment did not materially narrow the scope of the present definition.
Conclusion: Employees engaged in timekeeping and similar clerical duties, where those duties are incidental to or connected with the factory's manufacturing activities, fall within the definition of "worker"; the appeal therefore failed.
Ratio Decidendi: A factory employee need not be engaged in manual manufacturing work to qualify as a "worker" if the duties performed are incidental to or connected with the manufacturing process and the statutory definition is construed liberally in furtherance of the welfare purpose of the Act.