MEMORANDUM

April 16th, 2019

Ref: 0027A/2019

HATEFUL/DIVISIVE SPEECHES BY TOP BJP LEADERS

INDEX

SL.NO Particulars Page

No.s
1. Representation

2. Annexure I :
Copy of this Hon’ble Commission’s orders dated
April 15th, 2019

3. Annexure II:
Copies of news articles reporting PM Narendra
Modi’s speeches.

4. Annexure III:
Copies of various news items reporting Shri Amit
Shah’s speech.

5. Annexure IV:
List comprising of the electoral and penal laws
violated by Prime Minister and his party president
Shri Amit Shah.

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 MEMORANDUM

April 16th, 2019

Ref: 0027A/2019
To,

Chief Election Commissioner &

His Companion Election Commissioners of India

The Election Commission of India,

Nirvachan Sadan
New Delhi - 110001

Dear Sirs,

RE: HATE SPEECHES BY PRIME MINISTER NARENDRA

MODI & BJP PRESIDENT AMIT SHAH

REQUEST FOR URGENT AND NECESSARY INTERVENTION

AGAINST PM NARENDRA MODI’S CONTINUED AND BRAZEN
VIOLATION OF THE MODEL CODE OF CONDUCT & IN
PARTICULAR THE HATEFUL & DIVISIVE COMMENTS BY
HIM & BJP PRESIDENT AMIT SHAH & VIOLATING THE
DIRECTIONS CONTAINED IN ECI ORDER DATED 15.04.2019

We, the undersigned are in receipt of your order numbered 437/UP –

HP/ 2019 dated April 15th, 2019 and we are grateful for this Hon’ble
commission prompt action on Complaints made by the Indian National
Congress.

A copy of this Hon’ble Commission’s orders dated April 15th, 2019 are
annexed herewith and marked as ANNEXURE – I.

I.
The immediate consequence of the order is that the Prime Minister and
the BJP Party President would also be bound by its operation.

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This is because they are the fountainhead from which all such language
flows and in turn authorizes lesser party workers to disseminate
communal messages with impunity.

The Prime Minister Narendra Modi and his party president, Shri Amit
Shah have used hateful, communal and divisive language on various
occasions.

On a previous occasion we brought to the Hon’ble Commission’s

attention, a speech given by the Prime Minister on April 1st, 2019 where
he said;

“How can the Congress be forgiven for insulting

the Hindus in front of the world? Weren’t you hurt
when you heard the word ‘Hindu terror’? How can
a community known for peace, brotherhood and
harmony be linked with terrorism? In the
thousand years of history, not a single incident
shows an act of Hindu terrorism. Even the British
historians could never find it,”

Thereafter, the Prime Minister while speaking at the rally in Nanded,

Maharashtra, said;

“Congress ke naamdaar ne microscope le kar bharat mein

ek aisi seat khoji hai jahan par vo muqabala karne ki
taakat rakh sake. Seat bhi aisi jahan par desh ki
majority minority mein hai.”

A copy of the news articles publishing the PM’s speech and the video are
annexed herewith and marked as ANNEXURE - II

Shri. Amit Shah while addressing a poll rally in Nagpur again continued
on this deliberately divisive messaging and said –

“Rahul baba apne gathbandhan ke liye

Kerala ke andar aisi seat par jakar khade
hai malum hi nahi padta juloos nikalta hai
toh bharat hai ya Pakistan ka juloos hai.”

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A copy of the news articles publishing the Shri Amit Shah’s speech in
Nagpur, Maharashtra and the video are annexed herewith and marked as
ANNEXURE – III.

A list comprising of the electoral and penal laws violated by Prime

Minister and his party president Shri Amit Shah is annexed herewith and
marked as ANNEXURE – IV.

There has been a continuous and blatant violation by the Prime Minister
and his party president, Shri Amit since the Model Code of Conduct came
into force.

The PM’s and Shri Amit Shah’s violations have in fact, grown
ever more brazen and audacious in their actions and
comments. Given its recent (and laudable) order of April 15th,
2019 the ECI must take immediate steps or risk establishing a
clear double standard.

The Commission must not forget that no one is above the law, be it the
Prime Minister of the country or the Party President of the Ruling
Regime. It’s high time this Hon’ble Commission takes stern steps and sets
a precedent by taking action against the source and authors of all hate
speeches.

In light of the gravity of these incidents and their potential for completely
disrupting a free and fair electoral process, we request this Hon’ble
Commission to utilize its powers under Article 324 of the Constitution of
India and treats this matter with utmost seriousness it deserves.

Warm regards,