The BJP cited the March 29 speech Rahul made in Yamunanagar, saying he alleged the PM took away Rs 30,000 cr from youth and gave it to an industrialist and on April 10 he mischievously quoted the SC to support his allegations against the PM.

"In a contempt petition filed in the Supreme Court Rahul Gandhi has accepted that his statement is false and he expressed 'regret' over his false statement," said the BJP memrorandum.

The memorandum said Rahul went on to accuse BJP chief Amit Shah of being a "murder accused" and attacked his family members, who have nothing to do with politics.

"In making references to Jay Shah, Rahul Gandhi violated the model code," the BJP said, adding "these are but just a few instances of brazen and utterly false allegations."