Common registration for adjoining factory premises was upheld where inter-linkage and unified functioning were substantially established.

Separate registration is not required where adjoining premises function as one factory and the factual indicators of inter-linkage are substantially satisfied. The governing instructions look to common raw materials, shared utilities, common labour, common management, interdependent processes and similar signs of unified functioning; separation by a public road, canal or railway line is the relevant exception, not a mere intervening plot. Here, the premises were connected by pipeline for furnace oil supply and use, shared access through a common road, and operated with substantial common functioning. Refusal of common registration solely because one plot lay between the premises was therefore unsustainable, and common registration for both premises was allowed.

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Issues: Whether common registration for the adjoining premises was justified when the units were claimed to be part of the same factory and most prescribed indicators of inter-linkage were satisfied.

Analysis: The governing instructions provide that separate registration is not required where multiple premises are actually part of the same factory and are segregated by a public road, canal or railway line, with the factual inquiry turning on indicators such as interlinked processes, common raw materials, common electricity, common labour, common management and other signs of inter-dependence. On the facts, the premises were found to be connected by pipeline for supply and use of furnace oil, the separation by an intervening plot was held not to be material, and a common road was available to both premises. As the material factors of inter-linkage and common functioning were substantially satisfied, rejection solely because one plot lay between the premises was not sustainable.

Conclusion: The appellant was entitled to common registration for both premises, and the refusal was set aside.

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