The court had been petitioned by a rights group named Sikhs For Justice.
Mrs Gandhi is currently in the US for a medical check-up. Under US laws, the summons has to be personally served to initiate legal proceedings.
"Summons issued almost 30 years after the event when the Congress president is on a medical visit is, to put it mildly, astonishing. Undoubtedly, appropriate legal action will be taken," said Congress spokesperson Abhishek Manu Singhvi.
Hundreds of Sikhs were killed in riots that began after Prime Minister Indira Gandhi was assassinated by her Sikh bodyguards in 1984.
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