The Seoul Central District Court turned down a request sought by prosecutors on Monday for the warrant to arrest Lee on charges of bribery, embezzlement and perjury.
Investigators said Lee gave or promised some 43 billion won (USD 36.3 million) worth of bribes to Park's jailed confidante Choi Soon-Sil.
The payment was allegedly in return for the state pension fund's backing of a merger of two Samsung affiliates -- deemed crucial for Lee's hereditary succession of power at Samsung, the world's largest smartphone manufacturer and a key part of the South Korean economy.
"It is difficult to accept the reasons, need and justification" to issue the warrant, it said in a statement released by the prosecutors, citing the lack of clear-cut evidence.
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