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Supreme Court Rules That Commercial Laundry Services Using Power-Operated Machinery and Employing More Than 10 Workers Qualify as a “Factory” Under the Factories Act, 1948, and Restores Criminal Proceedings Quashed by the High Court

Supreme Court Rules That Commercial Laundry Services Using Power-Operated Machinery and Employing More Than 10 Workers Qualify as a "Factory" Under the Factories Act, 1948, and Restores Criminal Proceedings Quashed by the High Court

Supreme Court Rules That Commercial Laundry Services Using Power-Operated Machinery and Employing More Than 10 Workers Qualify as a "Factory" Under the Factories Act, 1948, and Restores Criminal Proceedings Quashed by the High Court

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Court’s Decision

The Supreme Court ALLOWED THE APPEAL, setting aside the High Court’s decision. The complaint and summons were restored, and the case was remanded to the Judicial Magistrate for further proceedings.


Facts

The case revolves around whether a laundry service business falls under the definition of a “factory” under the Factories Act, 1948. The dispute originated from an inspection conducted on May 20, 2019, at the premises of a commercial laundry service. The inspection revealed:

The inspection report further noted that:

The respondent (laundry service) replied on May 30, 2019, arguing that:

Following further correspondence, the Inspectorate of Factories and Boilers obtained information from the Employees’ State Insurance Corporation (ESIC), confirming that the laundry business was covered under the ESIC Act.

Subsequently, the Judicial Magistrate First Class (JMFC), Panaji, issued a summons on December 4, 2019, initiating legal proceedings.

The respondent then approached the High Court of Bombay at Goa, seeking to quash the complaint and summons, primarily arguing that:

  1. The order issuing the summons lacked reasoning and application of mind.
  2. Dry cleaning was a service, not a “manufacturing process,” under the Factories Act.

The High Court accepted these arguments and quashed the complaint and summons.

Dissatisfied with this ruling, the State authorities appealed to the Supreme Court.


Issues Before the Court

The central issue before the Supreme Court was:

Whether the laundry service in question, which involved washing and dry cleaning, constituted a “manufacturing process” under Section 2(k) of the Factories Act, 1948, and whether the premises fell under the definition of a “factory” under Section 2(m) of the Act.


Petitioner’s (Appellant’s) Arguments

The appellants (State authorities) argued that:


Respondent’s (Defendant’s) Arguments

The respondent (laundry service) argued that:


Analysis of the Law

The Supreme Court analyzed:


Court’s Reasoning

The Supreme Court ruled that:

  1. The High Court’s ruling was erroneous in requiring transformation into a new product. The plain meaning of Section 2(k) includes washing and cleaning.
  2. The laundry service’s use of machinery and employment of more than 10 workers qualified it as a “factory” under Section 2(m).
  3. The Factories Act’s purpose is worker protection, and businesses engaging in washing and cleaning must comply with its safety and welfare provisions.
  4. The respondent was already registered under the ESIC Act as a factory, further proving that the establishment met the definition under the Factories Act.
  5. The complaint and summons were valid, and the High Court wrongly quashed them.

Implications

Also Read – Karnataka High Court Orders Immediate Resumption of Halted Co-operative Society Elections, Extends Board’s Term, and Imposes Costs on Election Officials for Negligence and Legal Malice”

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