In a memorandum to Chief Election Commissioner V.S.Sampath, K.C. Mittal of the Congress legal department, sought de-recognition of Bharatiya Janata Party and action against its prime ministerial candidate Narendra Modi.
The memorandum said Modi had addressed a public rally in Varanasi where the portrait of Lord Shiva was used in the backdrop.
Citing media reports, it said supporters of BJP had given a new twist to "har har Modi (Hail Modi)" slogan and were using the slogan "Dil mein Modi, Ghar mein Modi, Kashi ke kan kan mein Modi (Modi in heart, Modi in home, Modi in every part of Kashi)".
"Lord Shiva or Mahadev and the ancient Kashi Vishwanath temple at Varanasi have religious sanctity throughout the world. Hindus and all devotees of Lord Mahadev chant 'Har Har Mahadev, Ghar Ghar Mahadev' with deep sense of devotion to seek blessings of the Lord. No human being can replace Lord Mahadev in the said chant," the memorandum said.
It said BJP supporters had been chanting "har har Modi, ghar ghar Modi" slogan.
"It also seems to be part of BJP's strategy to present Modi as Lord Mahadev to exploit religious sentiments of people for electoral gains and polarise votes," the party said.
Referring to the "new slogan" coined by party's supporters, the party said that it "also aims at arousing religious sentiments and feelings of the people...'Kan kan mein Bhagwan (God is omnipresent)' is a well-known religious slogan which has been changed to kankan mein Modi',' the memorandum said.
It said the BJP's official slogan "Abki baar, Modi sarkar (this time, Modi government)" was "unconstitutional and undemocratic"."In Indian democracy, the system of political parties alone has a legal sanction to form government and not any individual," it said.
"It is requested that the commission may be pleased to take all possible actions against BJP, including derecognition, Modi and their supporters for violation of model code of conduct," the memorandum said.