The bodies of Hema Updhyay and her lawyer, found near a Mumbai drain on Saturday, had only undergarments on them.
A police officer has said the deceased only had undergarments on them.
The bodies, with their hands and legs tied, were stuffed inside cardboard boxes before being wrapped in plastic sheets that were sewn up.
The bodies of well-known painter and installation artist Hema Upadhyay and her lawyer Harish Bhambhani were found packed inside cardboard boxes lying near a drain in suburban Mumbai.
