"Both the PM and Amit Shah grossly and as part of a coordinated campaign carried out illegal rallies which are so brazen in the scope and extent of their violation that the Commission is left with no choice but to take action. We request a written order be passed," the Congress memorandum submitted to the EC said.
"As we have seen over the last month and a half, non-intervention leads to an escalation in the illegal activities of these two individuals who take the EC's silence as a tacit stamp of approval," said the memorandum.
Citing an instance of Shah's violation of electoral laws, the Congress said that during his rally on April 22 at Krishnanagar (West Bengal), the BJP chief mentioned the Pulwama terror attack and the subsequent Indian air strikes across the border.
"Mr Amit Shah is aware of the injunction on the use of the armed forced, but despite this prohibition he delivered a campaign speech premised solely on seeking credit for the victory of the armed forces. This was to seek petty political gains for his party, the BJP, in the ongoing elections," said Congress memorandum.
Earlier on April 9 at Nagpur, Maharasthra, Shah also violated the poll panel's guidelines, the opposition party said.
Congress leader Jairam Ramesh slammed the PM saying his road show on Tuesday in Gujarat went from Balolnagar to Nishant School in Sabarmati Assembly segment of the Gandhi Nagar Lok Sabha constituency.
"He is a habitual, egregious, completely uncaring offender. He doesn't care for Election Commission. The Prime Minister of this country does not fall under the 9th schedule. He has no immunity from electoral laws, when he is campaigning. It is very distressing and sad, the very credibility, the very stature of the independent policemen of elections is at stake," he said.
Ramesh said the delegation showed the EC a video of the Prime Minister's campaigning and violating Model Code of Conduct.