Some additional points that would apply :
9. Leave.--(1) Holidays with pay will be allowed as provided for in 11[Chapter VIII of the Factories Act, 1948],
and other holidays in accordance with law, contract, custom and usage.
5. Publication of holidays and pay-days.—Notices specifying (a) the days observed by the establishment as
holidays, and (b) pay-days shall be pasted on the said notice-boards.
So, in case of the original post, custom and usage specifies that these days must be given as a holiday.
Second as i said earlier, when you give the return of holidays at the start of the year, the factory inspector will insist that these days be declared a holiday and if you do not agree, he will issue a notice asking the factory to include these holidays.
From India, Mumbai
23589. Leave.--(1) Holidays with pay will be allowed as provided for in 11[Chapter VIII of the Factories Act, 1948],
and other holidays in accordance with law, contract, custom and usage.
5. Publication of holidays and pay-days.—Notices specifying (a) the days observed by the establishment as
holidays, and (b) pay-days shall be pasted on the said notice-boards.
So, in case of the original post, custom and usage specifies that these days must be given as a holiday.
Second as i said earlier, when you give the return of holidays at the start of the year, the factory inspector will insist that these days be declared a holiday and if you do not agree, he will issue a notice asking the factory to include these holidays.
From India, Mumbai
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List of Holidays Karnatka.pdf