Bharat Electronics Limited vs B.E.L. Head Office Staff Association ... on 7 March, 2000
In Employees' State Insurance Corporation, Madras v S.M. Srira-mulu Naidu, the case related to a studio which was engaged in the production of cinematograph films. A number of buildings constituted this studio. All of them were situated in the same compound. The work of the studio was done by several departments. The studio employed more than 20 persons. On those facts, the Madras High Court held that studio was a factory.