Six years after the Mumbai Police closed the matter as an accidental death, the CBI has registered an FIR on the direction of the Bombay High Court. The same order that directed the investigation also directed that nobody be treated as an accused merely because a name has surfaced in the controversy. Nothing has been established, and no charge has been framed against anyone.
Mumbai: The Central Bureau of Investigation has registered a First Information Report into the death of celebrity manager Disha Salian, acting on a direction of the Bombay High Court passed earlier this month in a petition filed by her father [Satish Salian v. State of Maharashtra and Others].
The FIR was registered on Monday, two days after the complainant recorded his statement before the agency. It is the first FIR in a matter that the Mumbai Police had, in June 2020, recorded only as an Accidental Death Report.
The background
Disha Salian, then 28, died on June 8, 2020 after a fall from a residential building in Malad, Mumbai. She had worked for a period as manager to the actor Sushant Singh Rajput, who was found dead at his Bandra residence six days later, on June 14, 2020. The proximity of the two deaths generated years of speculation about whether they were connected, though the two matters were investigated separately.
The Mumbai Police treated Salian’s death as an accidental death and did not register an FIR. Her family disputed that conclusion. Her father moved the Bombay High Court seeking a fresh investigation, contending that the initial handling was cursory and that forensic material and witness accounts had not been properly examined.
At an earlier stage of the proceedings, a Division Bench of Justice Bharti Dangre and Justice Manjusha Deshpande had questioned why only an Accidental Death Report had been registered in the face of the family’s allegations, and had recorded that copies of the post-mortem report and the ADR had not been furnished to the family even five years after the death.
ALSO READ: Disha Salian Died by Suicide, No Signs of Rape or Murder: Mumbai Police Tells Bombay HC
What the High Court directed
By its order of September 2, 2026, the High Court directed the CBI to take over the investigation, to record the complainant’s statement, to register an FIR, and to appoint a senior officer to supervise the probe. The Malvani police station was directed to hand over all records relating to the death. The Court also provided for the opposite outcome, directing that if no cognizable offence is made out, the agency is to file an appropriate closure report before the competent court.
One direction in that order has received far less attention than it deserves, and it governs how the next phase of this case ought to be reported and understood. The Court expressly protected the position of persons whose names have come up in the controversy, directing that nobody is to be treated as an accused merely because his or her name has surfaced.
That safeguard matters because the complainant has, in his statement to the agency and in earlier complaints and public statements made through his counsel, named a number of well-known people whose roles he wants examined. Those named over the course of the proceedings include the Shiv Sena (UBT) leader and former minister Aaditya Thackeray and his father, former Chief Minister Uddhav Thackeray, the actors Dino Morea and Sooraj Pancholi, Rhea Chakraborty and Showik Chakraborty, and former police officers.
None of those persons has been charged with any offence in this matter, none has been convicted, and the allegations against them remain untested assertions by a complainant. Reports indicate that the FIR sets out offences including murder, gang rape, criminal conspiracy, destruction of evidence and furnishing false information, and records the complainant’s request that the alleged suppression of records and misuse of public machinery be investigated. It is not clear from the material available publicly whether any of the persons named by the complainant has been arrayed as an accused in the FIR, as distinct from being named for their role to be examined. Those two things are not the same, and the distinction should not be collapsed.
What an FIR is, and what it is not
An FIR is the trigger for an investigation, not its conclusion. Under the law as settled by the Constitution Bench in Lalita Kumari v. Government of Uttar Pradesh, registration is mandatory once information discloses a cognizable offence, and the question of whether the information is credible is not examined at that stage. Registration therefore says nothing about whether the allegations are true.
The sections cited in an FIR reflect the offences alleged by the informant. They are routinely dropped, altered or added as the investigation proceeds, and the investigating agency may ultimately file a chargesheet, or a closure report, or a chargesheet naming only some of the persons originally named. Only a court taking cognizance and framing charges places a person on trial, and only a verdict after trial establishes guilt.
That distinction is not academic in this case. The Bombay High Court has already, in 2025, initiated contempt proceedings against an advocate over what it described as scandalous remarks made in connection with this very matter, an indication of how closely the Court has been watching the public conduct of the litigation.
The competing accounts
The two accounts before the Court are irreconcilable, and it is worth setting out both.
The Mumbai Police told the Bombay High Court in 2025 that Disha Salian had died by suicide and that there were no signs of rape or murder. That remains the position of the investigating agency that handled the matter for five years, and it was arrived at after an inquiry, a post-mortem and a review.
The complainant’s case is that the death was neither a suicide nor an accident, that his daughter was assaulted and killed, and that what followed was a cover-up involving political influence and the suppression of records. He has said publicly that he gave the agency a full account and a list of names. His counsel has previously described the case as a gangrape and murder.
Deciding between those accounts is precisely what the CBI has now been directed to do, and it is a question on which no court has yet recorded any finding.
The Sushant Singh Rajput proceedings
The related matter also remains formally open. The CBI, which took over the investigation into Sushant Singh Rajput’s death on the Supreme Court’s direction in August 2020, filed a closure report concluding that he had died by suicide. That report has been submitted to the Special Court in Mumbai, which is yet to decide whether to accept it or to direct further investigation. The actor’s family has publicly disputed the closure report’s conclusions.
Why it matters
Two things are in tension here, and the High Court’s order attempts to hold both.
The first is the entitlement of a family to a proper investigation. A death recorded as accidental, with the post-mortem report reportedly withheld from the next of kin for five years, is a serious institutional failure irrespective of what the eventual findings are. The delay itself now carries an evidentiary cost, since six years erodes memory, degrades physical material and overwrites electronic records, which means the CBI begins at a disadvantage that is not of its making.
The second is the position of people whose names circulate in a case of this profile. The coverage of the 2020 deaths produced one of the most heavily criticised episodes of media trial in recent Indian memory, and the Bombay High Court itself, in Nilesh Navlakha v. Union of India in 2021, laid down guidelines restraining television coverage that attributes guilt or conducts a parallel trial during an ongoing investigation. Those guidelines were framed in the aftermath of this very cluster of events. The High Court’s direction that nobody be treated as an accused merely because a name has surfaced should be read against that history.
For readers, the practical position is straightforward. An investigation has been ordered by a constitutional court, an FIR has been registered in compliance, allegations have been made and a great many names are in circulation. Nothing beyond that has been determined by anybody.
Case Title: Satish Salian v. State of Maharashtra and Others [Criminal Writ Petition No. 1612 of 2025]
Court: High Court of Judicature at Bombay
Date of order directing CBI investigation: September 2, 2026 | FIR registered: September 14, 2026
Status: Investigation ordered and FIR registered. No charge has been framed and no finding has been recorded against any person.
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