Earlier this week, three Independents had withdrawn their support to the Nayab Singh Saini government.
The Congress submitted a memorandum addressed to Haryana governor here on Friday with a demand to dismiss the "minority" BJP government in the state and order fresh elections under the President's rule.
Senior Congress leader BB Batra, chief whip, Congress Legislature Party, accompanied by Deputy CLP leader Aftab Ahmed, submitted a memorandum addressed to Haryana Governor Bandaru Dattatreya regarding the present political situation in the state.
Earlier this week, three Independents had withdrawn their support to the Nayab Singh Saini government in Haryana.
The party said that another Independent MLA Balraj Kundu had withdrawn support a couple of years back and is opposed to the current Haryana government.
In its memorandum, the party claimed it is "crystal clear" that the Haryana government has been reduced to a minority in the House.
The 90-member Haryana assembly at present has an effective strength of 88 with the Karnal and Rania assembly seats being vacant.
The Congress, in its memo, said, "It is crystal clear that 30 (Congress) +10 (Jannayak Janta Party)+1 (INLD)+3 (Independents who withdrew support) +1 (Independent Balraj Kundu) = 45 MLAs are opposing this government which is more than the 43 MLAs now supporting the Haryana government."
"This shows that this government has lost the confidence of the majority of the MLAs in the present House," it said.
Replying to reporters, Mr Batra, who is also a Congress MLA, said that the party has no intention to form the government in the present scenario.
"We are demanding dismissal of this government and holding of fresh elections under President's rule. We will go to people and seek their mandate. We will not form a government in this scenario," he said.
The President's rule should be imposed "so that no horse trading takes place", Mr Batra said.
In the two-page memorandum, Leader of Opposition Bhupinder Singh Hooda has referred to the situation arising after three Independent MLAs-- Sombir Sangwan (Dadri), Randhir Singh Gollen (Pundri) and Dharampal Gonder (Nilokheri) -- withdrew support to the ruling BJP in Haryana on Tuesday and announced that they would back the grand old party.
The memorandum stated that ideally, Chief Minister Nayab Singh Saini should resign on moral grounds "but this government is unabashedly seeking shelter under sheer technicalities or rather unconstitutionality by claiming that they have the majority".
"In view of the facts placed before you, you are requested to exercise your constitutional authority to dismiss this minority government immediately and order fresh elections under President rule and uphold the democratic values," it said.
"If the Governor does not dismiss the minority government, then immediately Vidhan Sabha should be convened and the Chief Minister be directed to seek a vote of confidence on the floor of the House," stated the memorandum.
It stated that affording an opportunity to the minority government to gather support "through illegal and undemocratic methods will put technicalities above the spirit of the democratic principles".
"Your prompt action in this matter will restore the faith of the people in our democratic system and enhance the dignity of your high office," the party said in the memo.
After withdrawal of support by the three Independents, the government has no moral authority, no constitutional validity and no confidence of the people to remain in office even for a moment, it said.
"..The Congress has 30 MLAs who are opposed to this government from the beginning," the party said.
"The JJP, its earlier coalition partner, has withdrawn its support from the government and demanded imposition of President's rule through a letter addressed to you. Similarly, the lone MLA of INLD Abhay Singh has also demanded imposition of President's rule," the memorandum stated.
Aftab Ahmed said, "majority MLAs are in opposition of this government and it has lost the moral right to continue".
"If the Governor says, we are ready to parade our 30 MLAs," said Mr Ahmed.
Mr Batra said that they handed over the memorandum to the Governor's secretary as Mr Dattatreya "had left for Telangana for some work." When asked if Congress may contemplate moving the court, Mr Batra said, "Governor is the constitutional head, let him first take a decision in the matter".
Asked about Chief Minister Nayab Saini is saying his government is not in any danger, Mr Batra quipped, "he should say where he has the numbers".
Earlier, on Thursday the Congress had sought time to meet the Haryana governor in the wake of the situation arising out of three Independent MLAs withdrawing support to the BJP government.
Congress leader Bhupinder Singh Hooda had said the "minority" dispensation should resign on moral grounds.
However, Chief Minister Saini has repeatedly asserted that his government was not in trouble.
The government has the support of two of the Independent legislators and HLP member Gopal Kanda.
Polling for 10 Lok Sabha seats in Haryana will be held in the sixth phase of elections on May 25. State Assembly elections are due in October.
(Except for the headline, this story has not been edited by NDTV staff and is published from a syndicated feed.)