Broad factory definition covers adjoining yards and child workers engaged in incidental processing work within manufacturing premises.

The factory definition was construed broadly to include the whole premises and precincts, not only the room where machinery stood, where mechanical power was used anywhere on the site in aid of a manufacturing process; the drying yard was therefore part of the factory. Children engaged in sorting ground-nuts were treated as employed in the factory because the work was incidental to the manufacturing process and connected with the article being processed; who paid their wages was immaterial. The revision accordingly failed, and the conviction and fine were left undisturbed.

---

---

Issues: (i) whether the drying yard formed part of the factory within the meaning of the Act; and (ii) whether the children engaged in sorting ground-nuts were employed in the factory so as to attract liability under the Act.

Issue (i): whether the drying yard formed part of the factory within the meaning of the Act.

Analysis: The expression defining a factory was treated as wide enough to include the whole premises and precincts, not merely the room where a particular machine stood. Where mechanical power was used in aid of a manufacturing process anywhere on the premises, the entire establishment, including adjoining yards and adjuncts, was within the statutory description of a factory. Authorities under the English Act were distinguished because they turned on different facts and on whether any manufacturing process existed on the premises at all.

Conclusion: The drying yard formed part of the factory.

Issue (ii): whether the children engaged in sorting ground-nuts were employed in the factory so as to attract liability under the Act.

Analysis: A child found in a part of the premises where work incidental to a manufacturing process was being carried on was treated as employed in the factory unless the contrary was shown. Sorting ground-nuts was held to be work connected with the article that was itself the subject of the decorticating process. Since the premises were being used for a regular manufacturing process, the children were within the statutory mischief, and it was immaterial who paid their wages.

Conclusion: The children were employed in the factory within the meaning of the Act.

Final Conclusion: The revision failed because both the premises question and the employment question were answered against the petitioner, leaving the conviction and fine undisturbed.

Ratio Decidendi: Where mechanical power is used anywhere on the premises in aid of a manufacturing process, the whole premises and its adjuncts constitute the factory; and work connected with the article being manufactured amounts to employment in the factory for the purposes of child-labour restrictions.

---