Ardeshir H. Bhiwandiwala v State of Bombay

Rule established

The definition of 'factory' under Section 2(m) of the Factories Act, 1948 turns on whether a 'manufacturing process' is carried on with the aid of power, and the concept of 'manufacturing process' is broadly construed to include activities that transform or treat raw material into a different or usable form, such as the conversion of seawater into salt through natural processes assisted by mechanical means, bringing such premises within the scope of the Act.