ARDESHIR H. BHIWANDIWALA vs THE STATE OF BOMBAY.

The Supreme Court upheld the conviction of the appellant under Section 92 of the Factories Act, 1948 for operating a salt works without a license. The Court clarified that the term 'premises' includes open land and that the process of converting sea water into salt constitutes a 'manufacturing process' as defined in Section 2(k). The Court concluded that the appellant's operations fell within the definition of a factory under Section 2(m), affirming the necessity of a license for such activities.