The Bombay High Court has reportedly raised serious questions about the manner in which the Mumbai Police handled the investigation into the death of celebrity manager Disha Salian, particularly regarding the absence of a First Information Report (FIR) and the continued reliance on an Accidental Death Report (ADR) inquiry.
During a hearing connected with a petition filed by Disha Salian’s father, Satish Salian, the court examined the scope and legal framework of the police investigation. According to the details reported by ABP Majha, the bench stressed that the matter must be viewed with sensitivity because a father has lost his daughter and is seeking answers through the legal process.
The hearing focused on an important legal question: why was the matter investigated for years under an ADR process rather than through a formal FIR and a statutory criminal investigation?
Court Questions Absence of FIR
According to the reported court proceedings, the High Court questioned the Mumbai Police over the decision not to register an FIR despite complaints that allegedly raised cognizable issues.
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Add Hunterfly on GoogleThe court reportedly observed that when information relating to a cognizable offence is received, the legal process may require registration of an FIR followed by a proper investigation under the applicable criminal procedure.
A preliminary inquiry, the court reportedly noted, could have helped clarify whether the allegations disclosed a criminal offence requiring a formal investigation.
The distinction is significant because an ADR inquiry and a criminal investigation operate within different legal frameworks. An ADR is generally used to record and examine cases involving unnatural or accidental deaths, while a formal FIR can initiate a more comprehensive criminal investigation when there is information suggesting a cognizable offence.
Concerns Over Investigation Under CrPC Section 174
A major point raised during the hearing reportedly concerned the scope of an investigation conducted under Section 174 of the Code of Criminal Procedure, which governed such proceedings at the relevant time.
The court reportedly noted that the police had been examining the matter for several years while continuing to proceed through the ADR route.
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Add Hunterfly on GoogleThe bench also questioned whether the legal limitations of an inquiry under Section 174 affected the value and scope of the investigation carried out so far.
This distinction could have significant implications in the case. A statutory criminal investigation following the registration of an FIR has a different procedural structure from an inquiry into the cause of an unnatural or accidental death.
The reported court observations appeared to focus on whether the investigative approach adopted by the police was sufficient to address the concerns raised by Disha Salian’s father.
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Add Hunterfly on GoogleCourt Questions the Value of the Earlier Investigation
The Bombay High Court also reportedly raised questions about the practical consequences of the investigation conducted so far.
According to the reported proceedings, the court questioned whether years of inquiry under the ADR framework could adequately resolve the issues now being raised before it.
The bench reportedly referred to a closure report and noted that such findings could still be subject to legal challenge by Disha Salian’s father.
The court also reportedly made it clear that the possibility of registering an FIR and carrying out a formal statutory investigation remained open, depending on the facts, legal requirements, and decisions of the competent authorities.
It is important to note that court observations during a hearing do not necessarily amount to a final finding on the facts of the case. The legal proceedings and any directions issued by the court would ultimately determine the next procedural steps.
High Court Focuses on Legal Investigation, Not Political Allegations
According to the reported hearing, the Bombay High Court made it clear that its focus was not on political allegations or complaints involving political personalities.
Instead, the court reportedly emphasized the need to examine the legal issues surrounding the investigation and to ensure that the matter reaches a proper conclusion through a lawful and transparent process.
The case has attracted considerable public attention over the years, including speculation and political controversy. However, the central issue before the court, based on the reported proceedings, concerns whether the investigation into Disha Salian’s death was conducted through the appropriate legal process.
The court’s approach reportedly placed emphasis on the petitioner’s position as a father seeking answers about his daughter’s death.
Satish Salian Questions Police Investigation
Disha Salian’s father, Satish Salian, has raised questions about the investigation into his daughter’s death and has sought a fair and thorough examination of the case.
The petition before the Bombay High Court has brought renewed attention to the procedural history of the investigation.
At the heart of the matter is the question of whether the available information required a formal criminal investigation and whether the ADR inquiry was sufficient under the circumstances.
The court’s reported observations indicate that the distinction between an accidental death inquiry and a statutory criminal investigation is now a key issue in the ongoing legal proceedings.
Disha Salian’s Death in 2020
Disha Salian died on June 8, 2020. Her death subsequently became the subject of public debate and extensive media attention.
Information from the postmortem report, as described in the material provided for this article, recorded injuries and identified severe head injuries as the cause of death. The report also recorded other observations, including bleeding from the nose and mouth.
The report, according to the information provided, did not record sexual assault or rape.
Any discussion of medical or forensic findings should rely on authenticated official documents and verified reporting. In an ongoing or legally contested case, allegations and interpretations should not be presented as established facts unless they have been confirmed through official investigative or judicial findings.
Why the Court’s Questions Matter
The Bombay High Court’s reported questions are significant because they go beyond the facts of one high-profile case and address the legal procedure followed when authorities investigate an unnatural death.
The core issues include:
- Whether the information received by police required registration of an FIR.
- Whether an ADR inquiry was legally sufficient in the circumstances.
- What limitations apply to an investigation conducted under the relevant accidental death provisions.
- Whether a more formal statutory investigation remains possible.
- Whether earlier findings or closure reports can be legally challenged.
The eventual outcome of the proceedings could clarify what further action, if any, the investigating authorities may be required to take.
What Happens Next?
The legal proceedings will determine the next stage of the case. The Bombay High Court may examine the submissions of the petitioner, the Mumbai Police, and other parties before reaching any decision on the issues raised.
A court hearing and the questions raised during proceedings should not be confused with a final verdict.
The legal process may still involve further submissions, examination of official records, responses from authorities, and judicial directions. Any decision regarding an FIR, further investigation, or the legal status of earlier findings would depend on the applicable law and the final orders of the competent court or investigating authority.
For now, the reported High Court hearing has renewed focus on a central question in the Disha Salian death case: whether the investigation followed the appropriate legal framework and whether additional statutory steps may still be available.
As the proceedings continue, official court orders, verified police records, and authenticated documents will be crucial in establishing the next developments in the case.

















