Bombay High Court Directs CBI Investigation into Death of Disha Salian

The Bombay High Court, in Satish Salian v. State of Maharashtra & Ors., Criminal Writ Petition No. 1612 of 2025, Neutral Citation No. 2026:BHC-AS:35902-DB, has ordered that the Central Bureau of Investigation (CBI) must take over and conduct a full-scale investigation into the 2020 death of celebrity manager Disha Salian.

The Division Bench of Justice Sarang V Kotwal and Justice Ranjitsinha Raja Bhonsale reserved judgment on 28 June 2026 and delivered it on 2 September 2026. After closely scrutinising the material placed on record, the Court concluded that there were “too many glaring discrepancies” in the police inquiry. It therefore held that a mere inquiry under Section 174 of the Cr.P.C. was inadequate and that a substantive investigation under Section 154 to Section 173 of the Cr.P.C. ought to have been undertaken.

The Court accordingly directed the CBI to register an FIR, record the statement of the petitioner–father, and investigate all aspects relating to the circumstances in which the deceased lost her life, under the framework of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Background and Core Relief Sought

Central Relief in the Writ Petition

The writ petition was instituted by Satish Salian, father of the deceased, seeking various reliefs. After hearing all sides, the Bench identified prayer clause (d) as the pivotal relief that required adjudication. This prayer sought:

“Transfer of Investigation to CBI & Supervision by This Hon’ble Court: – Direct the State of Maharashtra to hand over the entire investigation to the Central Bureau of Investigation (CBI) and further direct that the CBI to appoint an officer not below the rank of Inspector General of Police (IGP) to lead the investigation under the direct supervision of this Hon’ble Court to ensure impartiality, transparency, and adherence to due process.”

The Court noted that the petitioner is the bereaved father of a young woman who died in what he describes as suspicious circumstances. It recorded that the petition arises out of serious doubts about whether his daughter’s death was investigated properly and whether the hypothesis of suicide is sustainable in light of the factual record.

Petitioner’s Broad Allegations (Without Individual Attribution)

While the judgment consciously avoids reproducing all individual allegations against named persons, it captures the broad narrative of the petitioner’s case:

  • The deceased was working professionally with Sushant Singh Rajput.
  • According to the petitioner, she came to know of certain “objectionable activities” of influential individuals.
  • The allegation is that she shared this information with Sushant Singh Rajput, who, in turn, inadvertently disclosed it, leading to the information reaching back to those very individuals.
  • The petitioner contends that, to silence her, she was murdered and, prior to her death, subjected to gang rape.
  • He alleges that a false story was constructed to project the incident as a suicide from the 12th floor flat of her fiancé, said to have occurred between the night of 8 June 2020 and the early hours of 9 June 2020.

The Court, however, made it clear that it was not at this stage deciding on the truth or falsity of these allegations. Instead, it focused on whether the manner and quality of investigation by the police met the legal standard required in cases involving suspicious death.

Why the Court Found a CBI Probe Necessary

Overall Assessment of the Police Inquiry

The Division Bench, after reviewing the record, underscored that the police’s approach raised more questions than it resolved. The Court held that the circumstances demanded a full-fledged investigation into a cognizable offence, but this was never undertaken. Instead, the police confined themselves to an inquiry under Section 174 Cr.P.C., treating the matter as an accidental or suicidal death, without moving to register an FIR under Section 154 Cr.P.C.

The Court crystallised a set of key factual and procedural concerns, which collectively, in its view, justified entrusting the matter to the CBI.

Key Circumstances Highlighted by the Bombay High Court

In paragraph 38 of the judgment, the Bench laid out several crucial aspects that, taken together, demonstrated the inadequacy of the original investigation and warranted transfer to the CBI.

1. Delayed Spot Panchnama

Although the police reached the building promptly after the incident, the spot panchnama was conducted only between 9.40 a.m. and 9.45 a.m. on 9 June 2020—more than nine hours after the alleged fall.

The Court relied, inter alia, on the supplementary statement of Rohan Rai dated 15.06.2020, where he stated:

  • Friends Himanshu and Indranil initially did not allow him to go down, saying he would be shocked at the sight.
  • The deceased was taken to hospital by Himanshu and Indranil, while he stayed back with Resha.
  • When they were about to leave for the hospital, police arrived at the building.
  • The police questioned him, inspected the spot, took him to the 12th floor flat, entered the room, and even asked him to remove his clothes for examination.
  • Only later did he learn the sequence of hospitals to which the deceased had been taken, ending with Shatabdi Hospital, Kandivali, where she was declared dead.

The Court noted that this description clearly indicates police presence at the flat and initial inquiries much earlier than the formal ADR. Yet there is no mention of this early inspection in the ADR or subsequent investigation records.