The Bombay High Court has directed the CBI to register an FIR and take over the investigation into the death of Satish Salian's daughter, who died in June 2020 under circumstances her father has always insisted were suspicious. A division bench of Justice Sarang V. Kotwal and Justice Ranjitsinha Raja Bhonsale passed the order on September 2, 2026, after hearing a batch of connected petitions filed by Salian.
Background
Salian's daughter, who had worked with actor Sushant Singh Rajput, was found dead after allegedly falling from the 12th-floor flat of her fiancé, Rohan Rai, at Malad, between the night of June 8 and June 9, 2020. Police initially treated it as suicide and closed the file under Section 174 of the CrPC - a provision meant only to record the apparent cause of death, not to investigate a crime. Salian's counsel, Nilesh Ojha, argued this was never a genuine criminal probe since no FIR was ever registered despite repeated complaints.
He submitted his client had no equally effective remedy left except approaching the High Court, since a magistrate cannot direct a CBI investigation. The State, represented by Public Prosecutor Shishir Hiray, along with intervenors, opposed the plea, pointing out that two separate inquiries - one in 2020 and another after reinvestigation was ordered in December 2023 - both concluded it was suicide.
Court's Observations
The bench listed several unexplained gaps: the spot panchnama was drawn up nearly nine hours after the incident, blood traces expected from a high-rise fall were missing, the postmortem showed no facial bone fractures despite the claim that she fell face-down, and the FSL flagged discrepancies over vaginal and anal swabs versus smears.
The court observed,
"we find that there are too many glaring discrepancies which necessitated proper and substantive investigation under the provisions of Sections 154 to 173 of Cr.P.C.. That was not done in the present case."
It clarified it was not commenting on anyone's culpability, adding that the CBI "shall not be influenced by any observations made in this order."
Decision
The court directed the CBI's Mumbai in-charge officer to appoint a senior investigating officer, record Salian's statement, register an FIR, and investigate the case under the BNSS. It declined the request to place the probe under judicial supervision, stating it had no reason to doubt CBI's fairness.
No individual is to be treated as an accused unless evidence justifies it, the bench ruled, disposing of the petition along with all connected applications.
Case Details
- Case Title: Satish Salian vs. State of Maharashtra and Others
- Case Number: Criminal Writ Petition No. 1612 of 2025 (with connected Interim Applications)
- Judges: Justice Sarang V. Kotwal and Justice Ranjitsinha Raja Bhonsale
- Decision Date: September 2, 2026
