DR. DEVENDRA M. SURTI vs STATE OF GUJARAT

The Supreme Court held that the appellant's dispensary did not qualify as a 'commercial establishment' under Section 2(4) of the Bombay Shops and Establishments Act, 1948, as his professional activity was not organized as trade or business. The Court emphasized that the definition must be construed restrictively, applying the principle of noscitur a sociis, which limits the general terms to those analogous to the specific terms used. Consequently, the appellant's conviction for non-maintenance of an employee register under Rule 23(1) was deemed illegal, and the acquittal by the trial magistrate was restored.