The development came after the high court transferred the case to the Central Bureau of Investigation (CBI) and asked it to consider whether it was a case of suicide or homicidal death.
"If it comes to a conclusion that it is a homicidal death, then further investigation be made to find out who is the perpetrator of the crime and accordingly action be taken," a division bench of Justice V.M. Kanade and Justice P.D. Kode had said in its order July 3.
A US citizen, Jiah Khan was found hanging from a ceiling fan in her Mumbai home June 3 last year in a case of apparent suicide. Police later recovered a suicide note purportedly penned by her.
The court had ordered the agency to take over the probe from a Special Investigation Team (SIT) of Maharashtra Police following a plea filed by the actress' mother Rabia Khan in October 2013, seeking a probe by the CBI.
"The case is handed over to the CBI for further investigation and to assess whether Jiah Khan committed suicide or was murdered," the division bench said last month.
The court said it was not expressing any opinion on the merits of the probe done by Mumbai police.
The court had directed the Maharashtra government and police to provide all necessary support to the CBI in investigating the case.
The judges said the forensic opinion obtained privately by petitioner Rabia Khan was at variance with that of Mumbai police, suggesting there was a "lacuna" in the probe.
Moreover, the SIT constituted following court directives consisted of officers who were part of the earlier team that had probed the case and reached the conclusion that Jiah Khan's death was a suicide.
Police had subsequently arrested Jiah Khan's boyfriend, Sooraj Pancholi, the actor-son of actors Aditya Pancholi and Zarina Wahab, and charged him with allegedly abetting her suicide.
Not satisfied with the probe, Rabia Khan had moved the high court, submitting reports by independent experts to support her contention that Jiah Khan was murdered.
The court had pulled up the CBI for its reluctance to take up the case investigation on grounds of shortage of manpower, as stated by CBI counsel Vedika Gonsalves.
"It is not expected of the CBI to come out with such an excuse - that they do not have enough officers to conduct a probe. In a country of one billion people, an agency like the CBI should not take such a stance otherwise, where will the citizens go to seek justice?" Justice Kanade observed.
He said two officers of the US consulate remained present throughout the hearing as the deceased was an American citizen.
"This shows how much concern that country has for its citizens. Look at our own agency which is refusing to do the probe... they (CBI) should learn from their (US) example," he added.
The presence of the US consulate officials came in the wake of Rabia Khan's letter to then US envoy Nancy Powell seeking help from the Federal Bureau of Investigation (FBI) in the probe, and the US agency saying it was prepared to do so if India permitted.
In October 2013, Rabia Khan did not insist on a CBI probe after the court directed police to record her statements and investigate the death as a murder case.
Police, however, again concluded that Jiah Khan had committed suicide and charged Sooraj with abetting it.
Undeterred in her quest for unravelling the truth behind her daughter's death, Rabia Khan mentioned several circumstances in her petition which indicated that Jiah Khan could have been killed, and how police had allegedly discarded the opinion of a private forensic expert she had provided.
Accordingly, the CBI has now registered a case and started a probe into the death.
