In his nine-page reply filed this evening before the Commission, a day ahead of the deadline, Modi said he has only exercised his right of free speech by criticizing the policies and work of Congress and thus has not violated the Model Code.

"I am of the clear opinion that I have not violated the said provision," he said.

Modi said even though he has himself been subjected to much criticism, including use of abuses against him, he has maintained the dignity of political discourse and has not made personal attacks on any of his opponents.

Though Modi has sent a reply to the EC, a delegation of senior BJP leaders led by party vice president Mukhtar Abbas Naqvi will meet Chief Election Commissioner VS Sampath and two other Election Commissioners on Wednesday to hand over a copy of Modi's reply officially.

The BJP leaders will also complain against Congress leaders, including its vice-president Rahul Gandhi, accusing them of continuously violating the Model Code by making all kinds of statements and allegations against Modi and BJP.

Modi has said he has not made any wild allegation against the Congress and its leaders and whatever said by him is not unverified and is very much in public domain.

He said criticism of an opponent is inevitable in an election and the 'khooni panja' (bloody claw) and 'zalim haath' (ruthless hand) remarks are popular Hindi expressions used only figuratively.

"It is used as a colloquial metaphor," he said. The Election Commission had asked Modi to reply to its notice over his "khooni panja" remark by November 20.

The EC had issued a notice to Modi on November 13 to reply as to why action should not be initiated against him for his "khooni panja" remarks, allegedly in reference to the Congress poll symbol, which is a picture of a hand.

The Congress had complained to the Commission, which had got a copy of the video CD of Modi's speech of November 7 in Dongargarh Rajnandgaon of Chhattisgarh along with the remarks of the Returning Officer before the notice was served on the BJP prime ministerial candidate.

Modi while campaigning in Chhattisgarh had said, "When Atal Behari Vajpayee formed Chhattisgarh, whose hands did it first go into...Do you want such a "khooni panja" gain... Brothers and sisters, don't commit that mistake again. Even by mistake, don't ever let Chhattisgarh go into the hands of a 'Zalim Panja'."

"Whereas, it has been, prima facie, observed that by making the aforesaid statements, you have violated the provisions of the Model Code of Conduct," the EC notice had said.

(Agencies)

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