1340 SHRI CHINTAMAN RAO & ANOTHER vs THE STATE OF MADHYA PRADESH

The Supreme Court held that the Sattedars and their coolies delivering bidis to the factory were not 'workers' as defined under Section 2(1) of the Factories Act, 1948. The Court established that the determining factor for worker status is the employer's control over the work process, which was absent in this case. Consequently, the appellant's conviction under Section 92 for failing to maintain a register of workers was overturned, as the non-inclusion of the Sattedars and coolies did not constitute an offence.