In December 1993, the Delhi government under the Chief Minsitership of Madan Lal Khurana of the BJP, set up a committee under Justice (retd.) R.S. Narula seeking its recommendations to "review the status" of the recommendations made by Potti-Rosha, Kapur-Mittal and Jain-Aggarwal commissions after the 1984 Anti-Sikh Riots. In its report submitted in January 1994, the Narula committee recommended registration of cases against H K L Bhagat, Sajjan Kumar, and Jagdish Tytler.