Bombay High Court Questions Disha Salian Death Probe, Calls ADR Inquiry ‘Futile’
Bombay HC questions prolonged ADR inquiry into Disha Salian’s death, citing gaps in evidence, post-mortem procedure and failure to register an FIR despite her father’s suspicions.
Bombay High Court questions gaps in Mumbai Police’s investigation into Disha Salian’s 2020 death.
The Bombay High Court has questioned the validity of the investigation into the death of Disha Salian, former manager of actor Sushant Singh Rajput, with the court describing the prolonged inquiry as potentially “futile” and questioning why a proper criminal investigation was not initiated despite several discrepancies in the case.
Court's observations came while hearing a plea by Salian's father, Satish Salian, seeking a fresh investigation into her June 2020 death. Court questioned the continued reliance on an Accidental Death Report (ADR) inquiry, gaps in the evidence collected by Mumbai Police and the legal basis for reopening the inquiry years after its initial conclusion.
Salian died on June 8, 2020, after falling from a residential building in Mumbai's Malad area. Mumbai Police registered an ADR and subsequently treated the death as suicide. Her father has alleged that she was gang-raped and murdered and has sought registration of an FIR and a fresh probe. The allegations remain subject to judicial consideration.
The original inquiry was conducted under Section 174 of the Code of Criminal Procedure [now Section 194 of the Bharatiya Nagarik Suraksha Sanhita (BNSS)] and its report was accepted in February 2021. The provision outlines the exact procedure for police officers to investigate and report on unnatural or suspicious deaths.
The matter was reopened for reassessment in December 2023.
During the latest hearing on August 27, 2026, court questioned how a Section 174 inquiry could be reopened and continued for several years, and also examined whether such an inquiry could provide a legally sustainable closure to the case.
Court questioned the evidentiary value of an ADR inquiry as compared with a regular criminal investigation following registration of an FIR. It noted that statements recorded during a Section 174 inquiry have limitations and questioned why the possibility of an FIR and a formal investigation had effectively been closed.
Court also found several aspects of the evidence requiring scrutiny. It noted that there was no direct CCTV footage showing the precise location from where Salian fell. Court examined conflicting accounts about a locked door at the premises: while witnesses referred to the door being locked, the panchnama did not record corresponding physical damage.
The post-mortem procedure was another issue before the court. It noted that Maharashtra guidelines require autopsies in such circumstances to be conducted by two doctors, whereas Salian's post-mortem was conducted by one doctor.
Earlier this month, the high court had also questioned Mumbai Police over its failure to register an FIR despite Salian's father raising suspicion about her death. Court had further questioned why the ADR and post-mortem reports had not been provided to him despite the passage of several years.
The Maharashtra government has defended the investigation. During the hearing, the prosecution relied on witness statements, forensic material and other investigative records to argue that the evidence did not indicate foul play or sexual assault and supported the original conclusion of suicide.
The State has also questioned the delay in Salian's father approaching the court with allegations of murder. The high court, however, noted that his state of mind after the death of his daughter could be relevant while considering the delay.
Salian's death has also remained part of public debate surrounding the death of Sushant Singh Rajput, who died days later. During the latest hearing, however, the bench said it was concerned with the investigation and not the political allegations surrounding the case.
The plea was heard by Justices Sarang V Kotwal and Ranjitsinha R Bhonsale.