The Bombay High Court has directed the Central Bureau of Investigation (CBI) to register an FIR and conduct a comprehensive investigation into the death of Disha Salian, the former manager of late actor Sushant Singh Rajput, in a significant development nearly six years after her death.
A Division Bench comprising Justice Sarang Kotwal and Justice Ranjitsinha Bhonsale passed the directions while dealing with a petition filed by Salian’s father, Satish Salian, who had sought a fresh and independent investigation into the circumstances surrounding his daughter’s death.
Salian died on June 8, 2020, after falling from a high-rise residential building in Mumbai’s Malad area. The Mumbai Police had initially registered an Accidental Death Report (ADR) and investigated the circumstances surrounding the incident. The matter subsequently became the subject of sustained public and legal scrutiny, particularly because Sushant Singh Rajput died days later.
Salian’s father approached the High Court alleging that the circumstances of his daughter’s death had not been properly investigated. He has alleged that she was assaulted and murdered, claims which have not been established and remain subject to investigation.
The High Court’s decision follows a series of questions raised during the hearing over the manner in which the original inquiry was conducted. The Bench had questioned the continued reliance on an ADR inquiry and sought explanations regarding various aspects of the investigation, including the medical and forensic material collected by the authorities.
The State had maintained that Salian had died after falling from the building and defended the investigation conducted by the Mumbai Police. A Special Investigation Team had also examined the matter and, in July 2025, informed the High Court that it had found no evidence of foul play at that stage.
The High Court has now directed the CBI to undertake the investigation and register an FIR in accordance with law. The Mumbai Police has been directed to hand over the relevant case records and material collected during its earlier inquiry to the central agency.
The Court has also made it clear that the CBI investigation must proceed on the basis of evidence. Any person named or suspected in the course of the investigation cannot be treated as an accused unless material emerges to justify such a conclusion.
The Court further indicated that if the CBI investigation ultimately does not disclose the commission of any offence, the agency would be at liberty to submit an appropriate closure or summary report before the competent court.
Salian’s father has also been permitted to challenge the outcome of the CBI investigation in accordance with law, ensuring that the conclusion reached by the investigating agency remains open to judicial scrutiny.
The order assumes significance because the case had remained confined for years to an ADR-based inquiry, despite repeated demands for a formal criminal investigation. During the recent hearing, the High Court had questioned whether continuing such an inquiry after a prolonged period could serve any meaningful investigative purpose, particularly in view of the discrepancies brought before it.
The Court’s direction does not, at this stage, record a finding that Salian was murdered or that any particular individual was responsible for her death. Those questions will now fall within the ambit of the CBI investigation and will have to be determined strictly on the basis of evidence collected during the probe.
The development marks a fresh investigative chapter in a case that has remained under intense public scrutiny since June 2020 and has, over the years, also been discussed in connection with the death of Sushant Singh Rajput.
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