Bombay HC Orders CBI Probe Into Death of Celebrity Manager Disha Salian

Summary: 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, reserved on 28 June 2026 and pronounced on 2 September 2026, directed the Central Bureau of Investigation (CBI) to investigate the circumstances surrounding the 2020 death of celebrity manager Disha Salian. The Division Bench of Justice Sarang V Kotwal and Justice Ranjitsinha Raja Bhonsale found “too many glaring discrepancies” in the police investigation, including the delayed spot panchnama, questions concerning the timing of ADR No. 85/2020, CCTV footage showing police presence at the building, absence of blood at the spot, injuries recorded in the postmortem notes, concerns raised by the Chemical Analyzer regarding the quantity of blood on articles, the absence of recorded damage to the bedroom door, discrepancy between swabs and smears sent to the FSL, questions regarding the deceased’s clothes and belated seizure of her laptop and mobile phone. The Court held that proper and substantive investigation contemplated under Section 154 to 173 of the Cr.P.C. had not been conducted and that investigation under Section 174 was inadequate and insufficient in the facts of the case. Rejecting the submission that the petitioner could approach the Magistrate under Section 175 of the BNSS, the Court noted that the police had investigated the matter in two phases for more than six years and that a Magistrate could not direct a CBI investigation. It directed a suitably experienced senior CBI officer to record the petitioner’s statement, register an FIR and investigate all aspects surrounding the death. The Court clarified that nobody shall be treated as an accused unless sufficient grounds for reasonable suspicion emerge from the material collected. Investigation is to proceed under the Bharatiya Nagarik Suraksha Sanhita, 2023, followed by an appropriate report before the competent Court.

Bombay High Court Orders CBI Investigation

It is entirely in the fitness of things that the Bombay High Court (which is one of the oldest and so also one of the most esteemed High Courts in not only just India but all over the world with maximum High Court Benches which demonstrates its magnanimity even though it is Allahabad High Court which is biggest High Court in not only just India, in not only just Asia but all over the world even after the partition of Uttar Pradesh in 2000 and still has just one High Court Bench and even before partition had just one Bench created at Lucknow in July 1948 so close to Allahabad High Court and nowhere else) in a most learned, laudable, landmark, logical and latest judgment titled Satish Salian v. State of Maharashtra & Ors. in Criminal Writ Petition No. 1612 of 2025 and cited in Neutral Citation No.: 2026:BHC-AS:35902-DB that was initially reserved on 28.06.2026 and then finally pronounced on 02.09.2026 has ordered the Central Bureau of Investigation (CBI) to probe the most mysterious and inexplicable death of celebrity manager Disha Salian in 2020 which had captured news headlines in all news channels. It must be noted that a Division Bench comprising of Hon’ble Mr Justice Sarang V Kotwal and Hon’ble Ranjitsinha R Bhonsale directed the agency to register a First Information Report (FIR) based on the complaint that had been filed by her father Satish Salian. We need to also note that the Court also further directed the Joint Director of the CBI (Mumbai Region) to appoint a senior, suitably experienced officer to record the petitioner’s statement and register the FIR.

It may be recalled that Disha Salian had died on June 8, 2020 after falling from the 14^th floor of a residential building in the Mumbai suburbs. It cannot be lightly dismissed that Bombay High Court explicitly observed that, “The investigation carried out by the police raises more questions than it answers. Therefore, investigation by CBI is necessary.” Apart from this, the Court said that the CBI shall register an FIR and record the statement of the deceased’s father Satish Saliyan. It was also clarified by the Court that no person shall be treated as an accused until and unless there is sufficient material gathered against them during the probe.

Purpose of the Writ Petition

At the very outset, this elegant, eloquent, erudite and above all effective judgment authored by Hon’ble Mr Justice Sarang V Kotwal for a Division Bench of Bombay High Court comprising of himself and Hon’ble Mr Justice Ranjitsinha Raja Bhonsale sets the ball in motion by first and foremost putting forth the purpose of the petition in para 2 that, “This Petition is filed with many prayers. There are other Interim Applications in this Writ Petition. However, after hearing the parties we find that the most important prayer in this Petition and all the Interim Applications is prayer clause (d) of this Petition, which reads as follows:

“(d) 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.”

As we see, the Bench observes in para 4 that, “The Petitioner is an unfortunate father of a young daughter who lost her life in tragic circumstances. It is the case of the Petitioner that she lost life in the suspicious circumstances and, therefore, this Petition is filed.”

Petitioner’s Allegations Noted by the Court

It is worth noting that the Bench notes in para 9 that, “Keeping in line with our approach, we are not referring to the allegations made by the Petitioner in detail against some individuals. Very briefly, the gist of the allegations is that the Petitioner’s daughter was working with Sushant Singh Rajput. She got to know about some objectionable activities of the powerful people. She gave that information to Sushant Singh Rajput, who innocently divulged that to others and ultimately that information reached back to those people; and, therefore, to silence the Petitioner’s daughter her murder was committed. It is also case of the Petitioner that she was subjected to gang rape before her murder was committed. This is the gist of allegations made by the Petitioner. According to the Petitioner, a false story was concocted and it was shown as if the Petitioner’s daughter jumped from a flat of her fiancé which was on the 12th floor of a building; and committed suicide, between the night of 8th June, 2020 and 9th June, 2020.”

Circumstances Warranting CBI Investigation

Most significantly, the Bench encapsulates in para 38 those circumstances which warrant CBI investigation and which constitute the cornerstone of this notable judgment postulating precisely that, “Those circumstances are as follows:

Delayed Spot Panchnama

i] The spot panchnama was conducted belatedly: In this case the spot panchnama was conducted belatedly and there are indications that the police were not treating the case as an accidental death case but they were suspecting foul play. The statement of Rohan Rai at Page-186 of compilation “B” is important. His statements were recorded on multiple occasions but this particular statement was a supplementary statement dated 15.6.2020. The statements of the friends of the Petitioner’s daughter are recorded on more than one occasion and their basic story about the events from the evening till the incident is more or less consistent. All of them have stated that the Petitioner’s daughter was under depression. All of them enjoyed a party in the evening. They had consumed alcohol. The Petitioner’s daughter had a video call with her friend Ankita from London. She had a long conversation. She then went in the master-bedroom. She did not open the door. After some time, the friends entered the bedroom and they noticed her lying on the ground. The flat was on the 12th floor. This description is mentioned by all of them. Significantly in Rohan Rai’s supplementary statement dated 15.6.2020 he mentioned a few important aspects. He has stated that his friends Himanshu and Indranil did not allow him to go down as according to them he would be shocked. Therefore, he waited with his friend Resha inside the flat. The Petitioner’s daughter was taken to the hospital by Himanshu and Indranil. After some time, Resha called Indranil, who told her that he was taking the injured to the hospital. After that Rohan Rai and Resha came down. They were about to go to the hospital in his car. At that time the police came near his building. They made some preliminary inquiry with him and they conducted inspection of the spot. Then they took Rohan to his 12th floor flat. The police went inside his room and inspected it. Significantly Rohan Rai was asked to remove his clothes and the police carried examination of his person. After some time, one of their friends called telephonically and informed them that she was taken to Evershine Nursing Home, Malad and then to Tunga Hospital, Malad and finally to Shatabdi Hospital, Kandivali where she was declared dead.

These particular events are quite significant. This was before registration of ADR and even before the police were informed that the deceased had died. There is no such reference in the ADR recorded by the police. The police were at the spot very shortly after the incident. They suspected Rohan Rai but they did not conduct the spot panchnama. It was infact conducted between 9.40 a.m. to 9.45 a.m. on 9.6.2020; after more than nine hours from the incident. This aspect has remained unexplained and raises reasonable suspicion about the steps taken by the police right at the beginning.

Timing of ADR No. 85/2020

ii] The timing of ADR No.85/2020: ADR No.85/2020 registered at Malvani police station, Mumbai shows that the time of the incident or time of death was mentioned as 2.25 a.m. on 9.6.2020. Registration of ADR was at 3.07 a.m. on 9.6.2020. The ADR mentions that the police had already recorded the statements of her parents and that they had not expressed any suspicion or complaint against anyone. The first statement of the Petitioner recorded by the police mentions that he received a phone call from Malvani police station at about 3.00 a.m. on 9.6.2020. He was asked to go to Shatabdi Hospital at Kandivali. He reached the hospital at 4.00 a.m.. That time, he came to know about the death of his daughter. In that statement, he had stated that he did not have complaint against anyone. This statement itself shows that he had reached the hospital at 4.00 a.m. and then his statement was recorded. Therefore, it is not explained as to how a reference to that statement is made in the ADR registered at 3.07 a.m. on 9.6.2020.

CCTV Footage Showing Presence of Police Officers

iii] CCTV footage showing presence of Police Officers: The police had visited the said building in the night itself. The panchnama and description of CCTV footage are included in the compilation “A” from page No.65 onwards. Page No.67 shows that the police were present along with Resha and Rohan Rai at 2.14 a.m. in the said Flat No.1202 on 9.6.2020. Page No.69 shows that the police were present in that flat at 1.33 a.m.. On page No.75 it is mentioned that the police were present in the building at 12.59 a.m. on 9.6.2020. Thus, right from about 1.00 a.m. to 2.14 a.m. immediately the police were present at the spot in the building. There is no further reference either in the ADR or in the following investigation as to why they had gone there. There is no reference as to who were those police officers and what investigation they had carried out there and why there is no such reference in the ADR or in the following reports.

No Blood at the Spot Where She Had Fallen

iv] No blood at the spot where she had fallen: As we have observed, the spot panchnama was carried out belatedly. There are statements of at least two witnesses at page Nos.217 & 218 in compilation “B” who were standing near the spot where she had fallen. They had actually heard the sound of somebody falling. Both these witnesses have described that she had fallen on her face and blood was oozing from her head. Those statements are recorded on 15.8.2020 and 14.8.2020 respectively. The police had not recovered any blood stained earth from the spot and there was no bleeding injury to the head except bleeding injury to the chin. Their statements were important.

Injuries Mentioned in Postmortem Notes

v] Injuries mentioned in the postmortem notes: The postmortem notes mentioned the following six injuries:

1. CLW seen over chin 1x1x1 cms reddish, irregular, oedematous;

2. Grazed abrasion seen over upper part of chest and abdomen, reddish;

3. Abraded contusion seen on left elbow.

4. Abrasion seen on right arm, reddish.

5. Abrasion seen on left upper part of thigh, lower leg and knee, reddish.

6. CLW seen over right heel, reddish.

The internal examination showed that there was linear fracture of skull bones with sign of infiltration staining extended to base in anterior and middle cranial fossa. There were multiple ribs fracture with contused intercostal muscles. All other organs including pleura, larynx, trachea, bronchi, pericardium, peritoneum etc. were intact. The frontal teeth had fallen.

If the deceased had fallen on her face from 12th floor, then it is difficult to accept that there was only one injury of the size 1 x 1 x 1 cm in the nature of CLW over the chin. Not a single facial bone was fractured. There was neither fracture of mandible nor even of nasal bone which is quite delicate. We find this difficult to accept. This, of course, would be subject to expert’s opinion.

Chemical Analyzer’s Suspicion Regarding Blood on Articles

vi] Suspicion raised by Chemical Analyzer in respect of less blood on articles: The Assistant Chemical Analyzer attached to the Forensic Science Laboratory, Mumbai had raised a significant issue. They had addressed a letter to the Deputy Commissioner of Police and had informed him that they had received the articles and it was mentioned in the forwarding letter that the death was caused because of jump from the 12th floor. In that case, it was expected that there was more blood on the articles, but, when the articles were opened there was less blood. The Chemical Analyzer himself had raised this suspicion through a written communication dated 15.9.2020. (Page-354, Compilation “C”)

The police then had acted on that letter and sent their own letter dated 7.10.2020 to the Medical Officer, Borivali Postmortem Center seeking their opinion as to why there could be less blood on the articles. (Page-383, Compilation “C”) There was a specific reference to the clothes of the deceased. The police themselves were not sure as to why there was less blood on her clothes.

No Mention of Damage to the Door in Spot Panchnama

vii] No mention of damage to the door in the spot panchnama: The statement of Ankita at page No.223 in compilation “B” mentions that Himanshu had told her that the deceased had locked herself in a bedroom and that she was crying. The statement of the friends mention that Rohan forcefully opened the door. In that case it was expected that there was some damage to the lock or to the door but the spot panchnama does not show any such damage.

Discrepancy Pointed Out by FSL

viii] Discrepancy pointed out by FSL: There is one more glaring feature which requires some consideration. The postmortem report mentions in column No.21 that the anal swab and vaginal swab were taken for examination. The description of the Medical Officer’s letter to the FSL mentions that the ‘vaginal swab’ and ‘anal swab’ were sent but the exhibit found in the envelope were ‘vaginal smear on slide’ and ‘anal smear on slide’. The FSL sought explanation regarding this discrepancy and they addressed a letter dated 20.8.2020 to the Medical Officer, Borivali postmortem center. Said letter is at page Nos.355 & 357 in compilation “C”. These two swabs were important in the context of the allegations. The Medical Officer responded by sending a letter dated 25.9.2020 and it was mentioned that vaginal swab and the anal swab were not taken but vaginal smear and anal smear were taken. It was mentioned that the form sent to the FSL inadvertently mentioned vaginal swab and anal swab and that the FSL should read it as vaginal smear and anal smear instead of vaginal swab and anal swab. (Page-344, Compilation “C”) This discrepancy is also important in the context of the case. Because the C.A. Report at Page-347 in compilation “C” mentions that no male DNA was detected in those slides.

Police Query Regarding Deceased’s Clothes

ix] The police themselves sent a letter dated 12.8.2020 at page No.338 in compilation “C” to the doctor conducting the postmortem examination as to why the body was nude. That is surprising because the police themselves had effected the seizure panchnama of her clothes. The clothes were kept on the stretcher. They were identified by Rohan Rai. If the police were already aware of seizure of the clothes then there was no occasion to ask the doctor as to why there were no clothes on the body.

Belated Seizure of Laptop and Mobile Phone

x] The Petitioner’s daughter’s laptop and mobile phone were important part of the evidence. They were seized and examined much belatedly on 17.6.2020 from custody of Rohan Rai. They were not seized during the spot panchnama of the flat conducted on 9.6.2020.”

High Court Finds Investigation Inadequate and Insufficient

Quite forthrightly, the Bench points out in para 39 that, “Thus, we find that there are too many glaring discrepancies which necessitated proper and substantive investigation under the provisions of Section 154 to 173 of Cr.P.C.. That was not done in the present case. Therefore, we are of the considered opinion that this case deserves registration of FIR and investigation in a cognizable offence.”

Alternative Remedy Before Magistrate Rejected

Most forthrightly, the Bench observes in para 40 that, “Though Shri Pasbola and the learned Public Prosecutor submitted that the Petitioner has an option to approach the Magistrate and pray for investigation under the provisions of Section 175 of the BNSS, we have noted history of this case. The investigation was carried out in two phases by the police. It was going on for almost more than six years. Therefore, in the facts of this case it would not be proper to ask the Petitioner to approach the Court of Magistrate and seek police investigation. As rightly submitted by Shri Ojha, the Magistrate has no power to direct the CBI to investigate into the offence. In this particular case, we are of the opinion that the police had sufficient opportunity to investigate the offence but they have not registered the FIR and have not carried out the investigation of a cognizable offence. Instead, they conducted investigation under the provisions of Section 174 of Cr.P.C.. which according to us was inadequate and insufficient in the facts of the present case.”

Most rationally, the Bench states in para 41 that, “Therefore, in this case, another investigating agency like CBI is required to investigate the offence. We agree with Shri Ojha that the Petitioner does not have any equally efficacious and effective remedy in this particular case except to seek investigation by CBI.”

Bombay High Court’s Final Directions to CBI

Finally, the Bench then concludes by directing and holding in para 45 that, “As a result of the above discussion, we pass the following order :

:: O R D E R ::

i. The officer attached to Central Bureau of Investigation [CBI], who is in-charge for Mumbai region, shall appoint a suitably experienced and senior CBI Officer as an Investigating Officer in this case.

ii. Such officer shall record the statement of the Petitioner and register the FIR.

iii. The Investigating Officer shall conduct the investigation regarding all aspects surrounding the circumstances in which the Petitioner’s daughter lost her life.

iv. Nobody shall be treated as an accused unless in the opinion of the Investigating Officer there are sufficient grounds to raise reasonable suspicion against him depending on the material collected during the investigation.

v. The investigation shall be carried out under the provisions of the Bharatiya Nagarik Suraksha Sanhita, 2023. If the offence is made out, appropriate report be filed before the competent Court.

vi. In case the investigation reveals that no offence is made out, then appropriate Summary be filed before the competent Court; but in that case, the Petitioner shall have a right to file the Protest Petition challenging such report.

vii. The concerned officers of Malvani police station, Mumbai shall hand over all the necessary papers and articles to the Investigating Officer of CBI.

viii. The Petition is disposed of in the aforesaid terms. With disposal of the Petition, all the connected applications are also disposed of.”

Conclusion

In conclusion, the Bombay High Court has taken an absolutely justified stand and accorded reasons for the same. So now CBI investigation will be conducted as directed by the Court but no person shall be treated as accused unless and until there is sufficient material. This 44-page brief, brilliant, bold and balanced judgment merits reading in its entirety!