Tytler was accused of instigating a rioting mob, which murdered three men - Badal Singh, Thakur Singh and Gurcharan Singh - who had taken shelter at a north Delhi gurudwara on Nov 1, 1984.
Overruling all allegations against Tytler, the investigative agency the Central Bureau of Investigation (CBI) led by the then chief Ashwani Kumar had given a clean chit to him. Dr Ashwani Kumar, who in 2007 and 2009 had claimed that there were no evidence against Tytler, is the present Governor of Nagaland.
The Delhi court delivered its latest verdict in connection with the plea which was filed by Lakhwinder Kaur, the widow of one of the men killed. Mrs Kaur had challenged CBI's closure report in 2009. She insisted that the CBI has not recorded the testimony of two key eyewitnesses who have since moved to the United States.
CBI prosecutor, during the previous court hearing on April 4, had sought the dismissal of Lakhwinder Kaur's petition. The prosecutor claimed that Tytler was not present at the Pulbangash Gurudwara on Nov 1, 1984.
The prosecutor argued that at the time of the incident, the Congress was at Teen Murti Bhawan, the residence of late Prime Minister Indira Gandhi, who had been assassinated by her Sikh security guards the previous day.
However, this was not the first time when Tytler's role in the riot has come under scanner. Earlier another court in 2007 had asked agencies to re-investigate Tytler's alleged role.
The riots broke out on the evening of Oct 31, 1984, the day the then Prime Minister Mrs Gandhi was assassinated. Over the next few days, more than 8,000 Sikhs were killed across the country, 3,000 of them in the national capital.