A delegation of Congress leaders has filed a complaint with the Gujarat state election commission against Chief Minister Narendra Modi for violating the model code of conduct.

The alleged violation of the code took place on December 3 at Dhoraji, where Modi had, in his public meeting, said, "Give me lotus and I will give you Lakshmi."

"This is a clear violation of the code rules," said general secretary Girish Parmar and Khurshid Sayeed in their complaint.  They demanded action against Modi.