This question is again being asked after the latest investigation by a retired Supreme Court judge found that Congress leaders either incited or helped mobs to attack Sikhs.
The riots, in which more than 3,000 Sikhs died, were sparked by the assassination of then PM Indira Gandhi by Sikh bodyguards on 31 October 1984.
The resignation of Indian cabinet minister Jagdish Tytler, who was implicated in the riots, has not helped matters.
Nor has the resignation from a Delhi government position of Congress parliamentarian Sajjan Kumar - also named in the investigation report - placated the Sikhs, the opposition or the media.
Too little, too late
For the angry and hurt Sikh community and the outraged media, it is a classic case of too little, too late.
They are not wrong.
In the cases of many Congress leaders who could have been re-investigated it is too late.
Federal interior minister at the time of the riots and former prime minister PV Narasimha Rao is dead. A senior Congress leader named in the investigation HKL Bhagat is old and critically ill.
The then lieutenant governor of Delhi, PG Gavai, told a news channel recently that Mr Rao "hid like a rat" when the riots were taking place.
This is the not the first time that politicians believed to be guilty of inciting or leading communal riots have literally gone scot-free.
Three years on, no one has been brought to justice over the Gujarat riots either.
More than 1,000 people, mostly Muslim, were killed. Independent groups have placed the figure closer to 2,000.
The Bharatiya Janata Party (BJP)-led Gujarat administration, led by chief minister Narendra Modi, has been accused of doing little to prevent the bloodshed.
Investigations into the 1992 riots between Muslims and Hindus in Mumbai (Bombay) in which hundreds of people were killed have met a similar fate.
Partisan
This is despite the fact that the inquiry criticised the nationalist right-wing party, Shiv Sena, and its leader Balasaheb Thackeray for inciting the riots.
The report by a judicial commission also found the city's police were partisan and anti-Muslim.
Ayodhya is another case in point. Hundreds of people died in the violence which followed the destruction of the historic mosque there by Hindu militants in 1992. It was the trigger for the violence in Bombay.
BJP leader LK Advani is still facing charges that he incited Hindus to attack the mosque. He had a court appearance as recently as July 2005.
Why does justice reach a dead end in India while investigating such high-profile riots?
Delhi-based lawyer KTS Tulsi says the way the ruling Congress party-led government has treated the latest inquiry into the 1984 riots is "shameful".
He says mere probability of complicity in a crime should be enough reason to launch a criminal investigation against a person.
The problem starts here.
The police and investigative agencies in most Indian states are heavily politicised and influenced by their political masters.
Complicity
Independent research has shown that riots in India usually happen with the complicity of police who either covertly participate or turn a blind eye to the violence.
Social worker Teesta Setalvad says the fallout from the 1984 anti-Sikh riots and the 1992 Mumbai riots prove this point.
"The latest inquiry into the 1984 riots named police officials. The Mumbai riots inquiry named 15 policemen for their involvement. But the governments failed to take any action against them."
The riots, he says, showed the creeping criminalisation of Indian politics
''Before the 1984 riots, there were no criminals in politics. Criminals just followed the politicians. But 1984 made them realise people leading mobs and killing others could get elected and become leaders," says Mr Phoolka.
"So a way was opened for criminals to make politics a profession."
Analysts feel inquiry commissions are used by the state to delay action and protect politicians, policemen and civil servants.
They say the pussy-footing over the 1984 investigation by the ruling government proves that very little has changed.
'Cover-up'
Indian Prime Minister Manmohan Singh has apologised to the Sikhs and promised those named in the report will be investigated.
There is a feeling of deja-vu about this attempt to atone.
Congress chief Sonia Gandhi apologised for the 1984 riots over a decade ago and promised action.
No wonder the Sikhs are bitter and the media is sceptical.
The Asian Age summed the mood up in a front-page headline that simply said: "Mother of All Cover-Ups."
Newspapers are already talking about the need for something along the lines of South Africa's post-apartheid truth and reconciliation commission to unravel the truth and heal the wounds.
Because, as The Pioneer newspaper said, "justice delayed, also denied".
