"The decision on succession will be made in accordance with Article 48 of the Code of Civil Procedure," Aurimas Zukauskas, a spokesman for Vilnius City District Court, told BNS on Wednesday.
"If succession is not possible, the case is to be closed," he said.
In Lithuania, legal successors are usually relatives of the deceased.
People who lost their family members during the January 1991 events continued efforts to hold Gorbachev responsible until his death.
Earlier this year, family members of four people who died in the Soviet crackdown – Vidas Maciulevicius, Algimantas Petras Kavoliukas, Virginijus Druskis and Apolinaras Juozas Povilaitis – filed a civil lawsuit against Gorbachev seeking to prove that, as commander-in-chief of the Soviet Armed Forces, he had control of the army on January 11-13, 1991, but failed to take steps to prevent an international crime of aggression from being committed.
The Soviet Union used military force in its attempt to remove the legitimate government of Lithuania which declared independence on March 11, 1990.
Fourteen civilians were killed and hundreds more were injured when the Soviet troops stormed the TV Tower and the Radio and Television Committee building in Vilnius in the early hours of January 13, 1991.
Vilnius City District Court last May sent the civil lawsuit's documents to the Russian Foreign Ministry, asking it to hand them to Gorbachev.
"There is no information about the service of the documents," Zukauskas, the court's spokesman, told BNS.
The victims' relatives say that Lithuania has failed to assess and properly investigate the then Soviet leader's role in the events.
Prosecutors refused to name Gorbachev as a special witness in a criminal case over the bloody events of January 13, 1991 in Vilnius.
In 2017, Vilnius Regional Court sent a summons to Gorbachev to question him as a special witness in the mass trial, but Russia refused to serve it.