In Brief
The State of Goa filed a criminal complaint against Namita Tripath, a laundry business operator, alleging violation of the Factories Act, 1948 for operating without proper registration and licensing. The High Court quashed the complaint, holding that dry cleaning does not constitute a 'manufacturing process'. The Supreme Court reversed, holding that 'washing and cleaning' are explicitly defined as manufacturing processes under the Factories Act. Since the laundry employed over 9 workers using power, it fell within the statutory definition of 'factory'. The Court rejected the High Court's interpretation borrowed from Central Excise Act precedents, emphasizing that the Factories Act is a protective welfare statute whose provisions must be interpreted liberally to achieve worker safety objectives.
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