Suspended IPL commissioner Lalit Modi is set to reply to the third show cause notice issued by BCCI, and repeat his request that the board president Shashank Manohar and secretary N Srinivasan recuse themselves from participating in the proceedings. Later tonight Modi will email his response to the notice, which accuses him of irregularities in the awarding of theatrical rights during the third IPL season. Mehmood Abdi, Modi's legal counsel, will submit the hard copy tomorrow.

"There is a continuous issuance of notices wherein the allegations are wholly misconceived and irresponsible," Abdi told PTI. "The notices are being issued despite full knowledge that no material warranting their issuance existed."

Abdi was highly critical of Srinivasan's role in the proceedings. "Modi's application seeking Srinivasan's exclusion from proceedings against him is still undecided," he said. "Despite this, the honorary secretary continues to issue further notices to him. Therefore in the interest of justice and fair play it is incumbent upon Srinivasan to totally exclude himself."

Abdi said there was no need for the third show cause notice and that the BCCI had exaggerated a non-issue. "It seems that in BCCI somebody has not done his homework properly, otherwise the matter would not have necessitated any show cause. It's a matter of routine internal procedure and record. Still we are submitting our explanation covering all angles and concerning all the issues. Though I don't want to trivialise the issue, still with a view to slap another show cause notice, a mountain has been made out of a molehill," Abdi said. He also said the reply would consist of approximately 50 pages, while the attachments would consist of nearly two dozen.