State Of Goa vs Namita Tripathi 2025 INSC 306 - Factories Act - Laundry Business - Manufacturing Process

Factories Act 1948 - Section 2(m),2(k) - The business of laundry involving cleaning and washing of clothes including dry cleaning would be squarely covered by the expression “manufacturing process" (Para 33) [Context: High Court quashed the JMFC’s order, holding that dry cleaning does not fall within the definition of "manufacturing process" under Section 2(k) of the Act, as it does not result in a "new marketable commodity" or a transformation of the article into a commercially distinct product- In appeal, Supreme Court set aside the High Court’s decision and held:” “Manufacturing process” has been defined to mean any process for washing or cleaning with a view to its use, sale, transport, delivery or disposal. The linen deposited with the launderer is, after washing and cleaning, delivered to the customer for use. The ingredients of the section are fully satisfied.]

Interpretation of Statutes -Where the words of statute are clear, the plain meaning has to be given effect (Para 33) - Where a statute under consideration itself defines for the purposes of the said Act a certain phrase, a court of law is bound to apply the term as defined except in exceptional cases where the opening part of a definition, ‘anything repugnant in the subject or context’ applies. (Para 41) Social welfare legislation intended to benefit the large community of workers ought to be interpreted in a manner to give efficacy to legislative intent. (Para 30)

Factories Act 1948 - A welfare statute aimed at ameliorating the conditions of the workmen employed in factories. It is a beneficial legislation intended to protect workers from occupational hazards by seeking to impose upon owners and occupiers certain obligations for protecting the workers and securing their employment in conditions conducive to their health and safety. (Para 29)