The BJP on Saturday submitted a memorandum to governor Kalraj Mishra, complaining of “anarchy” and “breakdown of law and order” in Rajasthan, seeking to build a case of constitutional crisis in the state.

The BJP accused chief minister Ashok Gehlot of violating Section 124 of the IPC with his “threat suggesting gherao of the governor’s house and expressing inability to provide security”.

Section 124 of the Indian Penal Code relates to punishment for assaulting the President or governor with an intent to compel or restrain the exercise of any lawful power.

“Due to internal clash in the ruling party there is a state of complete anarchy in the state,” the BJP memorandum to the governor said.

“In the past two days, a situation of breakdown of law and order is prevailing due to the kind of language used by the chief minister and his activities along with his ministers and MLAs,” the memorandum added, accusing the chief minister and his MLAs of “terrorising” the governor.

Although the imposition of central rule in the Congress-ruled state by the use of Article 356 would not be easy, the BJP is trying to build a case to allege a constitutional crisis by accusing the chief minister of threatening the governor.

“The chief minister is the head of the state and he said that he would not be responsible for providing security to the Raj Bhavan. If not him, then who will be responsible? He should tender his resignation for using such language,” leader of the Opposition Gulab Chand Kataria said.

The BJP on Friday had appeared stumped by Gehlot’s move to call an Assembly session to prove his majority. The party is worried that the chief minister will prove his majority if the House is allowed to be convened, and the crisis triggered by the rebellion of deputy chief minister Sachin Pilot will end.

“What is the urgency to convene an Assembly session when there are 35,000 Covid-19 cases in the state?” the deputy leader of the BJP in the Assembly, Rajendra Rathore, asked.

When the crisis broke, the BJP had initially demanded that Gehlot prove his majority. But it quickly changed its line. Pilot has the support of 18 MLAs so far, not enough to topple the government.

The party memorandum also said the assembling of the MLAs on the lawns of the Raj Bhavan was in violation of the Epidemic Act.

At the same time, state BJP chief Satish Poonia, who led the delegation, said Gehlot had lost the trust of his MLAs and the people of Rajasthan. “The chief minister has locked his MLAs in the hotel because he has lost their trust,” Poonia said.

Around 100 Congress MLAs had accompanied Gehlot in a show of strength when he went to meet the governor and demand that the Assembly be convened so that he could prove his majority. They raised slogans for an Assembly session.

Rushing to the governor a day after, the BJP kept its focus on the chief minister’s suggestion that the people might gherao the Raj Bhavan and accused Gehlot and his MLAs of “terrorising” a constitutional authority by raising slogans.