Bombay High Court Transfers Disha Salian Death Investigation to CBI

The Bombay High Court has directed the Central Bureau of Investigation to register an FIR and conduct a substantive investigation into the circumstances surrounding celebrity manager Disha Salian’s death in June 2020.

The order was pronounced on September 2, 2026, by a division bench comprising Justice Sarang V. Kotwal and Justice Ranjitsinha Raja Bhonsale in a petition filed by Disha’s father, Satish Salian.

The court directed the officer in charge of the CBI’s Mumbai region to appoint a suitably experienced and senior officer as the investigating officer. Mumbai’s Malvani police station must hand over all necessary papers and articles connected with the case.

The ruling marks a major procedural change after two rounds of inquiry by Mumbai Police. Crucially, however, the High Court has not concluded that Disha was murdered, accepted the allegations against any named person or declared anyone an accused.

What the Bombay High Court Ordered

The operative portion of the 44-page order contains several specific directions:

• A senior and suitably experienced CBI officer must be appointed to investigate the case.

• The investigating officer must record Satish Salian’s statement and register an FIR.

• The CBI must investigate every aspect of the circumstances in which Disha died.

• No person can be treated as an accused unless the investigating officer finds sufficient grounds, based on collected material, to raise reasonable suspicion.

• The investigation must proceed under the Bharatiya Nagarik Suraksha Sanhita, 2023.

• If evidence discloses an offence, the appropriate report must be filed before the competent court.

• If no offence is established, the CBI may file the appropriate summary report.

• Satish Salian will have the right to challenge such a report through a protest petition.

• Malvani Police must transfer the relevant records and articles to the CBI.

The court rejected the request that it directly supervise the investigation, observing that there was no reason at this stage to doubt the CBI’s ability to conduct a fair, impartial and effective inquiry.

Why the Court Considered a Fresh Investigation Necessary

Disha Salian died following a fall from a residential building in Malad during the night of June 8–9, 2020. Mumbai Police initially examined the death through Accidental Death Report No. 85 of 2020 under Section 174 of the Code of Criminal Procedure.

According to the High Court order, the first inquiry concluded in October 2020 that Disha had died by suicide and that no foul play was involved. That conclusion was accepted by the relevant police authority in February 2021.

Following a Maharashtra government communication in December 2023, the matter was examined again. The second inquiry reached the same conclusion in April 2026, and its summary was accepted in May 2026.

The High Court distinguished these inquiries from a regular criminal investigation. It explained that proceedings under Section 174 of the CrPC have a limited purpose and cannot be equated with an investigation into a cognizable offence following registration of an FIR.

The bench observed that the inquiry had unfolded in two stages over approximately six years and said the police investigation raised “more questions than it answers.” It therefore found an FIR-based investigation necessary.

Discrepancies Identified in the Court Order

The High Court referred to multiple issues in the existing records while making it clear that these observations were not final findings of fact.

Among the matters identified for further examination were:

• the timing of the spot panchnama;

• inconsistencies concerning the timing and contents of the accidental-death report;

• CCTV material showing police officers at the building before certain events recorded in the official timeline;

• questions arising from witness accounts and evidence collected from the location;

• aspects of the injuries documented during the post-mortem;

• correspondence concerning the amount of blood found on articles sent for forensic examination;

• a discrepancy between references to swabs and smears in medical and forensic records;

• questions concerning the handling of Disha’s clothes; and

• the delayed seizure and examination of her laptop and mobile phone.

The court said these circumstances required a proper investigation but repeatedly cautioned that its observations should not influence the CBI’s eventual conclusions.

Some of the issues—including the interpretation of injuries and forensic material—will require expert examination. The order itself does not settle what caused the discrepancies or what they ultimately prove.

What the Court Has Not Decided

The direction to register an FIR does not amount to a judicial declaration that a murder, sexual offence or conspiracy occurred.

Satish Salian’s petition contained serious allegations and named individuals whom he wanted investigated. Those claims remain allegations. The High Court deliberately avoided making adverse findings against any person and left the assessment of evidence entirely to the CBI.

The bench expressly stated that nobody should be treated as an accused merely because they were named in a complaint or court proceeding. An individual can be treated as a suspect or accused only if the investigating officer finds adequate material creating reasonable grounds for suspicion.

This distinction is particularly important because the case has been surrounded by political claims, online speculation and unverified narratives since 2020.

Mumbai Police’s Position Before the Court

The Maharashtra government, through the public prosecutor, defended the earlier inquiries.

As recorded in the judgment, the state submitted that both police exercises concluded that Disha died by suicide and that investigators found no evidence of foul play. It also argued that Disha’s parents had not initially raised suspicion against another person in the statements recorded after her death.

The state further maintained that the medical and forensic records supported the conclusion reached by police. These were submissions made before the court; the bench nevertheless found the inquiry under Section 174 inadequate for resolving the issues appearing in the record.

The CBI investigation must now examine the evidence independently rather than begin with a predetermined conclusion of either suicide or homicide.

What Happens Next in the Disha Salian Case?

The CBI’s Mumbai-region head must first select a senior investigating officer. That officer will record Satish Salian’s statement, register the FIR and obtain the case material held by Malvani Police.

The agency will then be free to examine witnesses, police documentation, medical and forensic records, electronic evidence and any other relevant material. It may apply, add or remove legal provisions based on what the investigation produces.

Two broad outcomes are contemplated by the order. If the CBI finds evidence of a cognizable offence, it may proceed against the person or persons supported by that evidence and file the appropriate report before a court. If it concludes that no offence is made out, it may submit a closure or summary report, which Satish Salian can contest.

The Celebrity Hour Take

The most important aspect of the judgment is not that the High Court has endorsed a particular theory about Disha Salian’s death it has not. The significance lies in the court’s conclusion that the earlier accidental-death process was insufficient and that an FIR-based investigation is now required.

The order attempts to balance two competing concerns: a family’s right to a proper investigation and the right of individuals not to be publicly branded guilty without evidence.

Responsible coverage must preserve that balance. The CBI direction creates a new investigative process; it does not provide a licence to recycle unverified allegations as established facts. The evidentiary findings of the agency, and their assessment by a competent court, will determine what happens next.

Sources & Verification

This report was prepared primarily from the Bombay High Court’s 44-page order in Satish Salian v. State of Maharashtra and Others, Criminal Writ Petition No. 1612 of 2025, pronounced on September 2, 2026. The operative directions, earlier police findings, parties’ submissions and issues identified by the bench were checked directly against the judgment. Contemporary court reporting from established legal and news publications was used to verify procedural context. Allegations in the petition have not been presented as proven facts.