Dharangadhara Chemical Works Ltd v. State of Saurashtra (AIR 1957 SC 264)

Main Question: Were the agarias (salt workers) independent contractors or workmen under the Industrial Disputes Act, 1947?

Answer: Workmen. The Supreme Court said the company’s control over how salt was produced (methods, quality checks) showed an employer–employee link.

• Are agarias contractors or workmen considering the company’s supervision?
• What elements define a master–servant relationship for seasonal, piece-rate salt work?

Control test: Beyond “what” is to be done, look at “how” it is done. Supervision, process control, and quality checks point to an employment relationship. Degree of control varies by industry.

The Supreme Court affirmed that agarias are workmen under the ID Act. The decisive factor was the company’s method-level control—brine tests, plot prep, crystal formation, and final quality checks—showing supervision over how work was done.

How over what: Employer control over the manner of production, plus staged supervision and quality control, establishes an employer–employee relationship even with seasonal, piece-rate work.

• Protects seasonal and piece-rate workers when process control is with the principal.
• Shows flexible hours do not defeat workman status if method control exists.
• Guides industries with process-heavy supervision (e.g., salt, mining, food processing).

Mnemonic: “HOW = Hired”

1. Map the Method: Who controls process & quality?
2. Follow the Flow: Advances, rates, plot allocation.
3. Weigh Seasonality: Flexibility ≠ lack of control.

Issue: Are agarias workmen under the ID Act?

Rule: Control over how work is performed (process/quality supervision) indicates employment; industry context matters.

Application: Company supervised brine density, plot prep, crystal formation, and final testing; advances and fixed rates structured the relationship.

Conclusion: Agarias are workmen; Industrial Tribunal’s jurisdiction upheld.

Agaria

A traditional salt worker engaged in seasonal salt production.

Control Test

Legal test focusing on who controls the manner of work.

Patta

Allocated plot of land used for salt production.

• Cases on control test and workman status under the ID Act.
• Judgments on seasonal/piece-rate work and employment links.