Slamming Shah for "stoking communal fire", Congress approached the Commission demanding "stern action" against him as well as BJP and its PM candidate Modi, including derecognition of the party, for the alleged violation of mode of conduct.
In the complaint, K C Mittal, Secretary of AICC's Legal department, accused BJP UP incharge of "creating animosity between communities".
Appealing to people of all castes and creed in the country to give no quarter to those spreading the communal poison and trying to divide the society, Congress spokesman Randeep Surjewala said that they should be taught a befitting lesson.
Campaigning in western Uttar Pradesh which goes to polls on Monday, Shah has spoken of the current election being an opportunity to take "revenge for the insult" during the violence in Muzaffarnagar last year.
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Coming down heavily on the BJP, Surjewala said "Narendra Modi and Co" were once again laying the gameplan to replicate the Gujrat violence in 2002 all over the country.
Surjewala said that the "real manifesto" of the opposition party has come out in the open with elections approaching as Modi and Shah are resorting to unabashedly low level campaigning.
"They are only talking of cutting into pieces, killing, taking revenge and destroying. This is the real manifesto of BJP which has come to the fore when the elections are nearing," he told reporters.
Surjewala said, "We will make a demand to the state government and election commission that a criminal is lodged against Amit Shah and Muzaffarnagar riots accused MLA Suresh Rana and they should be prevented from campaigning in any part of the country. There should be a complete ban (on them)."