Replying to the legal notice issued last month by former Pradesh Congress Member K K Benson, Modi, through his advocates K N Subba Reddy and Vivek Reddy, asked him not to initiate any "false, frivolous and adventuristic complaint against him."
"Inspite of this advice, if you (Benson) were to institute any such false and frivolous complaint..., I will not only be constrained to defend the same, but also initiate appropriate legal proceedings against you, both civil and criminal, at your sole risk and cost," Modi said in the reply.
Modi termed as not true the statement that by calling the PM as "night watchman" he has insulted, degraded and defamed him in public and added that the demand that he apologise for it "is wholly untenable."
Benson had served a legal notice to Modi asking him to apologise and withdraw his remarks calling Prime Minister a "night watchman" of the Sonia Gandhi family.
Without naming Manmohan Singh, Modi on March 3 had said the Congress appointed a "night watchman" to keep the seat warm for the first family of the Congress.
"They did not realise that the night will be so long and dark. As a buffer, they appointed an economist to the post," Modi had said.