There is no lower limit put on use of power in the manufacturing process. In deed it could be a factory even if there is no use of power in the manufacturing process like traditional brick kilns, tile factories etc. Further, it has been stated that even if the power is used for lighting purpose in the work area it would still be a factory like a stitching unit with the traditional sewing machines or the work area where halwai makes sweets could be factory provided there are minimum 10 workers working under electric light.