On Thursday, the trio comprising of Arun Shourie, Prashant Bhushan, and Yashwant Sinha knocked on the doors of the central investigating agency—the CBI—asking it to register an FIR against PM Modi and others under the Prevention of Corruption Act, for their respective roles in the Rafale deal.

The 33-page letter submitted to the Alok Kumar Verma, Director of the CBI, asks the agency to register a “complaint under Section 7, Section 13(1)(d)(ii), & Section 13(1)(d)(iii) of unamended Prevention of Corruption Act, 1988, and Section 7 read with Explanation 2 of amended Prevention of Corruption Act, 1988, against Prime Minister, Mr. Modi, and the then Defence Minister, Mr. Manohar Parrikar” as well as a “complaint against other persons involved for abetment of said offences.”

The trio has also called upon the central investigating agency to register an FIR against Dassault Aviation, its CEO Mr. Eric Trappier, and Anil Ambani.

The letter reads: “Mr. Narendra Damodardas Modi is a public servant presently occupying the office of the Prime Minister of India. Mr. Anil Ambani is his long time friend and close associate who is the Chairman of Reliance ADA group of companies. Mr. Anil Ambani’s companies have been verging at the point of insolvency. Creditors of his group companies have initiated proceedings against his companies to recover their dues (Annexure 1A- 1D). Reliance ADA group of companies has for some time been in dire financial health. Reliance ADA has had to sell many of its precious assets to pay off its interest obligations and stave off insolvency proceedings (Annexure 2). In these circumstances, a conspiracy was hatched by the two of them, by way of which, Mr. Modi obtained an ‘undue advantage’ from Dassault Aviation, for awarding a contract for 36 Rafale aircrafts in ‘fly-away’ condition, by abusing the authority of his office and doing his public duty dishonestly and improperly. The ‘undue advantage’ has been received by his close associate and friend Mr. Ambani. As a consideration for abusing his official authority and doing his public duty dishonestly, Mr. Modi compelled Dassault to choose Mr. Ambani as an offset partner, by way of which Mr. Ambani received, and is receiving, and will continue to receive, for the next 40 years, an ‘undue advantage’. That is to say that though the offence commenced on 10th of April, 2015, it is, as of date, a continuing offence.”

According to the letter, “the facts mentioned above clearly show two things: (a) that Prime Minister, Mr Modi, asked Dassault to give the major offset contracts in this deal to Anil Ambani’s defence company as a condition for getting the contract; & (b) that the offset contracts worth tens of thousands of crores which have been awarded to Reliance Aerostructure Limited are not and cannot be considered to be legal remuneration for services actually rendered or services which could credibly be rendered by Reliance Aerostructure Limited. Therefore, these offset contracts and the payments made/to be made for them are at least in large part in the nature of undue advantage/illegal gratification/commissions to be paid to the Reliance Aerostructure Limited under this deal.”

“It is clear therefore that Mr. Modi, has used his position as the Prime Minister heading the government, to give an undue advantage to Anil Ambani’s Reliance Aerostructure Limited company as a consideration for the discharge of his function as a public servant to award the contract of purchasing 36 Rafale jets from Dassault in a ‘fly away’ condition.”

The trio has also mentioned how asking the CBI to investigate the PM is “peculiar.” “We are also aware that this will place you in the peculiar situation, of having to ask the accused himself, for permission to investigate a case against him. We realise that your hands are tied in this matter, but we request you to at least take the first step, of seeking permission of the government under Section 17(A) of Prevention of Corruption Act for investigating this offence and under which, “the concerned authority shall convey its decision under this section within a period of three months, which may, for reasons to be recorded in writing by such authority, be extended by a further period of one month”.

You can read the 33-page complaint letter to CBI  here.