The Opposition party also demanded setting up of an independent panel to inquire into the snooping incident and also phone tapping by the Home Department.
The demands were part of a memorandum submitted to Governor Kamla Beniwal by a State Congress delegation.
"Gujarat Chief Minister Narendra Modi has violated the Indian Telegraph Act and hence, a complaint should be lodged against him. An inquiry should be conducted into phone tappings ordered by the State Government and collection of 93,000 Call Data Records (CDRs)," the memorandum read.
The delegation, led by Leader of Opposition Shankarsinh Vaghela, consisted of leaders like Arjun Modhwadia and Shaktisinh Gohil, among others.
The State Government last week set up a two-member commission to probe the snooping scandal, which relates to alleged surveillance on a young woman at the behest of Modi's close political aide Amit Shah, a former junior Home Minister.
Terming the panel, headed by a retired Gujarat High Court Judge, as an "eyewash", Gujarat Congress had dubbed it as "Save Modi Commission".
According to the memorandum, the surveillance saga and suspension of IAS officer Pradeep Sharma, who has alleged victimisation by the BJP Government for knowing about "intimacy" shared by Modi with the architect, should be investigated in an independent manner.
Two investigative news portals had claimed on November 15 that Shah had ordered illegal surveillance of the woman at the behest of one "Saheb" in 2009.
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