Additional Chief Metropolitan Magistrate (ACMM) SPS Laler expressed displeasure over the non-appearance of the investigating officer (IO) in the case and non-filing of the status report called by the court.
The court directed the CBI's Superintendent of Police to appear before it on February 22 and explain why the report on further probe ordered by it in the case was not filed.
It had also said that as CBI had filed closure reports in the case several times, it would therefore now on monitor the probe every two months so that no aspects of the matter is left uninvestigated.
During the hearing, the court asked the CBI prosecutor regarding the status report to which he said the IO was not present.
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The case pertains to the riots at Gurudwara Pulbangash in north Delhi where three people were killed on November 1, 1984, a day after the assassination of then Prime Minister Indira Gandhi.
The court's order had come on a protest petition filed by complainant Lakhvinder Kaur, whose husband Badal Singh was killed in the violence, challenging the CBI's closure report exonerating Tytler.
The court had noted that statement given by Verma to CBI in which he claimed that Tytler had sent the son of Surinder Singh Granthi, a key witness against him, to Canada cannot be a "sheer coincidence" and the agency should probe if the facts disclosed by Verma were true.