The Supreme Court of India, on 29 November 2025, granted crucial interim relief to Vijay Kumar Sistla, the CEO of HLL Biotech Limited (HBL), by staying his arrest in an FIR lodged under the SC/ST (Prevention of Atrocities) Act, 1989. The case concerns allegations by a junior employee belonging to the Scheduled Caste community who claims she was denied maternity benefits, including Child Care Leave (CCL), while her colleagues were granted similar reliefs.
The matter was heard by a Bench comprising Justice M.M. Sundresh and Justice S.V.N. Bhatti, which also issued notice on the Special Leave Petition (SLP) filed by the petitioner challenging the Madras High Court’s refusal to grant anticipatory bail.
This article provides a detailed, SEO-optimized analysis of the case, the petitioner’s arguments, the statutory framework, and the legal precedents involved.
Background of the Case
The FIR stems from allegations made by a woman employee of HLL Biotech Limited who belongs to the Scheduled Caste community. According to the complaint, the CEO discriminated against her by denying maternity benefits, including one year of Child Care Leave, after she delivered a child on 8 May 2025. She asserts that other employees were granted these benefits without difficulty, and the hostile treatment meted out to her amounted to harassment and discrimination on account of her caste.
The FIR invokes:
- Section 3(1)(r) of the SC/ST (Prevention of Atrocities) Act, 1989, which criminalizes intentional insult, humiliation, or intimidation of a member of the SC/ST community in public view; and
- Section 4 of the Tamil Nadu Prohibition of Harassment of Women Act, 1988, relating to harassment of women employees.
The Madras High Court had declined to grant anticipatory bail, leading to the SLP before the Supreme Court.
Petitioner’s Grounds in the Supreme Court
Before the Supreme Court, the petitioner strongly contended that the FIR was motivated by personal vendetta and lacked the essential ingredients of the offences alleged.
1. Previous Complaint & Exoneration
The CEO pointed out that the complainant had earlier filed a similar complaint in 2023. This allegation was comprehensively examined by a Fact-Finding Committee constituted by the HBL Board. The committee, after inquiry, exonerated the petitioner and submitted its report dated 2 November 2023 to the Additional Secretary, Ministry of Health, Government of India.
This background was cited to demonstrate that the allegations were not new, and earlier proceedings had already cleared him.
2. Delay in Lodging FIR
The petitioner highlighted the three-year delay in lodging the FIR, pointing out that the complaint was made only after the CEO denied her request for one year of Child Care Leave, which did not fall within his delegated powers. This, he argued, showed that the complaint was:
- false,
- vindictive, and
- filed with the intention to cause harm.
3. Applicability of Section 18 of the SC/ST Act
Section 18 of the SC/ST Act creates a statutory bar on anticipatory bail where offences under the Act are alleged. However, the petitioner argued that courts can still grant anticipatory bail when the allegations are prima facie false or motivated by vendetta.
To support this contention, he relied on the landmark ruling in:
- Shajan Skaria v. State of Kerala
The Supreme Court in Shajan Skaria held that even when the SC/ST Act is invoked, if the allegations appear manifestly false, courts should conduct a preliminary inquiry to determine whether the essential ingredients of the offence are made out. The Court clarified that the bar under Section 18 does not apply to frivolous, motivated, or fabricated complaints.
Supreme Court’s Interim Order
After hearing the submissions, the Bench of Justices Sundresh and Bhatti granted interim protection by staying the arrest of the CEO. This relief was significant because:
- Denial of anticipatory bail under the SC/ST Act is treated strictly.
- Prima facie false cases must not lead to unjust incarceration.
- The Court recognized that the matter raised important questions regarding the abuse of stringent statutes.
The Supreme Court also issued notice to the respondents, seeking their response.
The case is listed as:
Vijay Kumar Sistla vs. State of Tamil Nadu
SLP (Crl.) No. 18448/2025
Legal Issues Raised
1. Whether the FIR disclosed prima facie offences under the SC/ST Act?
For Section 3(1)(r) to apply, the alleged humiliation must:
- Be intentional,
- Be connected to caste identity, and
- Occur in public view.
The petitioner claims none of these ingredients are present.
2. Whether the denial of maternity benefits constitutes caste-based discrimination?
The complaint alleges “discriminatory denial”. However, the petitioner argues the decision was administrative, not discriminatory, and that other employees were also denied benefits due to lack of delegation of power.
3. Whether the FIR was filed with mala fide intent?
The delay and timing of the FIR, combined with previous inquiries, form the crux of this contention.
Relevance of the Shajan Skaria Judgement
The petitioner’s reliance on Shajan Skaria is strategic and relevant. The Supreme Court in that case emphasized:
- Courts must scrutinize allegations under the SC/ST Act for truthfulness.
- Even with stringent statutory bars, courts cannot be blind to motivated complaints.
- A preliminary judicial inquiry is permissible to assess whether the offence is made out.
This principle is likely to play a role in future hearings of the present case.
Implications of the Supreme Court’s Intervention
1. Protection Against Misuse of SC/ST Act
The SC/ST Act is a crucial safeguard against caste-based atrocities. However, courts also recognize that its stringent provisions can be misused in exceptional cases. This case adds to the growing jurisprudence balancing:
- Protection of vulnerable communities
- Safeguards for innocent accused persons
2. Workplace Rights and Maternity Benefits
The allegation revolves around denial of maternity rights, which are protected under:
- Maternity Benefit Act, 1961
- Government service rules for Child Care Leave
- Constitutional principles of equality and dignity
Even though the petitioner claims lack of delegated power, the case raises broader concerns about access to maternity entitlements in public sector undertakings.
3. Importance of Departmental Inquiries
The earlier fact-finding committee report exonerating the CEO highlights how departmental mechanisms can serve as internal checks. Yet, courts will ultimately scrutinize their findings while deciding on criminal liability.
Conclusion
The Supreme Court’s stay on the arrest of HLL Biotech CEO Vijay Kumar Sistla marks an important development in the evolving jurisprudence surrounding the SC/ST Act and anticipatory bail. While the complainant alleges discriminatory denial of maternity benefits, the petitioner asserts that the complaint is delayed, motivated, and unsupported by evidence, relying heavily on the precedent in Shajan Skaria.
The case, now pending further adjudication, will test the boundaries of criminal liability in workplace disputes, the protection of SC/ST employees, and the judicial approach to potentially false FIRs under the SC/ST Act.
As the proceedings continue, this matter will be closely watched for its implications on employment law, anti-harassment norms, and the interpretation of statutory bars on anticipatory bail.
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