Responding to an Election Commission notice, issued on Tuesday, he said it ''has not taken the whole alleged speech into consideration and only referred to two lines'' from his speech.
The EC had issued the notice to Udhayanidhi Stalin for his alleged remarks that Swaraj and Jaitley died as they were ''unable to tolerate the pressure and torture'' given by Prime Minister Narendra Modi.
The EC had asked him to respond to the notice before 5 pm on Wednesday, ''failing which the Commission shall take a decision without any further reference to you''.
In his reply, Udhayanidhi Stalin said the ''tenor and intention of his entire speech must be appreciated'' to decide the context of the extracted two lines uttered and urged the EC to furnish a transcript of the entire speech for him to furnish a full and proper reply.
''At the outset I deny that I have committed any breach of the Model Code of Conduct,'' he said.
The clause referred by the Commission only prohibits criticism of private life of leaders and workers of other parties, he said and added that the said lines if appreciated in spirit of the delivery of the entire speech taken as a whole, do not breach the MCC.
The notice had said the EC received a complaint from the BJP alleging that Udhayanidhi Stalin, while addressing a political gathering at Dharapuram on March 31, made a statement that ''Sushma Swaraj and Arun Jaitley (both Union ministers) died unable to tolerate the pressure and torture given by Prime Minister Narendra Modi''.
The Commission said it is of the view that the contents of the speech made by him violated the provision of MCC which states that ''criticism of other political parties, when made, shall be confined to their policies and programme, past record and work.'' ''Parties and candidates shall refrain from criticism of all aspects of private life, not connected with the public activities of the leaders or workers of other parties.
Criticism of other parties or their workers based on unverified allegations or distortion shall be avoided,'' it had said.
Elaborating, Udhayanidhi Stalin said he was only responding to Modi's accusation against him at a poll rally that he had reached high political office in DMK through short cut methods.
''The impugned speech is nothing but answer to that criticism wherein I have said that Mr Narendra Modi became Prime Minister only through short cut methods overlooking other senior leaders in BJP party while he was Chief Minister of Gujarat.'' ''I said that I was having a list of senior leaders who were sidelined by him. I gave the names of Mr (LK) Advani, Mr Yashwant Sinha, Late Mrs Sushma Swaraj and Mr Arun Jaitley. The words pressure and torture were not used by me in the said context as sought to be projected in the show cause notice,'' he claimed.
His entire speech in Tamil conveyed a ''totally different'' meaning, he claimed, adding, the notice did not establish he spoke about anyone's private life.
Stating that he held Modi, Swaraj and Jaitley in ''high esteem in their public life and personal capacity,'' Udhayanidhi Stalin said he had no ill will against them.
Many ''unsavoury and tasteless'' comments had been made against him but his party chief MK Stalin had asked him to take them in his stride and questioned why the EC has not taken action against those who had commented on his personal life and family, including his grandfather and late DMK president M Karunanidhi.
He requested the Commission to accept his ''interim reply'' and permit him to give a detailed one after he received the full text of the speech in contention and the BJP's April 2 complaint.
After a high octane campaign for the Tamil Nadu elections ended on April 4, voting in 234 Assembly seats was held on Tuesday.