REVISITING THE DEFINITION OF MANUFACTURING PROCESS UNDER THE FACTORIES ACT: A JUDICIAL EVOLUTION

AUTHOR – MEHEK CHOWATIA, STUDENT AT SCHOOL OF EXCELLENCE IN LAW, TAMILNADU DR. AMBEDKAR LAW UNIVERSITY

BEST CITATION – MEHEK CHOWATIA, REVISITING THE DEFINITION OF MANUFACTURING PROCESS UNDER THE FACTORIES ACT: A JUDICIAL EVOLUTION, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (6) OF 2025, PG. 420-425, APIS – 3920 – 0001 & ISSN – 2583-2344

ABSTRACT

This article critically examines the evolving judicial interpretation of the term “manufacturing process” under Section 2(k) of the Factories Act, 1948, a cornerstone of labour legislation in India. Traditionally associated with the mechanical transformation of raw materials into finished products, the definition has undergone significant expansion through a series of landmark judicial pronouncements. Courts have increasingly adopted a purposive and welfare-oriented approach, bringing within its ambit a wide variety of processes that do not necessarily involve mechanization or result in a new product. Activities such as food preparation, packing, grading, refrigerating, and even dry-cleaning have been recognized as manufacturing processes when undertaken with a commercial or utilitarian objective.

The recent Supreme Court ruling in State of Goa & Anr. v. Namita Tripathi (2025) marks a notable development in this interpretive trajectory. The Court held that activities like washing, cleaning, and dry-cleaning fall within the ambit of a manufacturing process under the Act, emphasizing the legislative intent to ensure the health, safety, and welfare of workers across evolving sectors. This decision reinforces a broader application of the Act to service-oriented industries that were traditionally considered outside its scope.

Through a detailed analysis of key cases, this paper underscores the judiciary’s role in progressively broadening the scope of worker protection under the Factories Act. It also highlights the urgent need for a legislative update to the definition of “manufacturing process,” particularly in light of emerging digital, hybrid, and service-based industries. Until such reform is undertaken, courts are likely to continue relying on a functional and intent-based test to determine applicability.

Keywords: Factories Act, manufacturing process, labour law, worker welfare.