"The Enforcement Directorate (ED) show cause notices reveal that ED has been investigating alleged violations under FEMA in relation to BCCI contracts and in respect of the general conduct of the Indian Premier League(IPL).

"The allegations reflect collective responsibilities rather than personal responsibilities. It is significant to note that the Enforcement Directorate has not identified any specific contravention under FEMA committed by our client," a legal firm representing Modi said in its reply to the Directorate submitted on September 3.

The 11 notices were issued by the ED against BCCI, Modi and six others for alleged contravention of Foreign Exchange Management Act (FEMA) involving about Rs 1,317.20 crore in November last year in connection with the conduct of IPL in South Africa during 2009.

"My responses to the show cause notices show my commitment to complying with all requests made to me by the authorities in order to clear my name of any association with these investigations," said Modi.

He said the notices are to establish whether or not an inquiry should be held for the purpose of making an adjudication.

"I continue to remain confident that I have done nothing to warrant the continued investigation of my role as Chairman of the IPL," Modi, who is in London, said. According to Modi's reply, all activities of IPL had approval of the Governing Council, headed by him and involving members of the BCCI.

"All activities of IPL are acts that have documented approval from collective Governing Council or Working Committee Meetings in accordance with BCCI/IPL process.

"Our client has earlier provided documentary evidence to the complainant which illustrate collective council or board approval for all activities. Thus, no action of our client can be termed as unauthorised, unilateral actions on his behalf," the reply said.

It said that IPL like any other committee of BCCI for example finance committee, legal committee or marketing committee is merely to assist and aid the BCCI.

"The members of such Committees including the Chairman thereof cannot be said to be person in-charge or responsible to the BCCI for the conduct of business of the BCCI.

"This is so because IPL is merely a sub-committee of the BCCI and has no control over the affairs of BCCI rather it is controlled by BCCI. IPL also has no say upon any financial drawings, disbursements or remittances as such matters are controlled by persons who are incharge of BCCI namely the President, the Secretary and the Treasurer. IPL does not also have any separate existence," the reply said.

The counsel for Modi also termed as "unreasonable, arbitrary and disproportionate" the action seeking impounding of passport of the former IPL chief.

Modi's passport was revoked by the Government in March 2011 after he was allegedly found to be eluding investigating agencies looking into the alleged forex contraventions.