In its complaint, the party termed Gandhi as a "habitual offender" and termed Congress as a "history-sheeter" party in violating the model code of conduct and laws of the land.
The complaint has sought stern action against Gandhi in the wake of the poll body expressing displeasure over his certain remarks against BJP and his linking the Muzaffarnagar riot victims to Pakistan's ISI and asking him to be more cicumspect in future.
He claimed the use of the word "chor" (thief) to describe a party and its leaders is a "clear cut violation of the model code of conduct" and demanded stern action from the poll watchdog.
Naqvi said a delegation of BJP leaders will also meet the Chief Electoral Officer of Chhattisgarh and demand action besides presenting another memorandum to him.
Rahul Gandhi today dubbed BJP as a "party of thieves" and accused it of "looting natural resources" of Chhattisgarh.