1. Point out that state governments weren’t competent to suspend the laws.

- refer to the
judge
2. Scientific evidence – what evidence does
3. As I already pointed out that Article 19(5) -  either in the interests of the general
public 
4. Samant N. Balakrishna Etc vs George Fernandez- report - A news item
without any further proof of what had actually happened through witnesses is of
no value. It is at best a secondhand secondary evidence. It is well-known that
reporters collect information and pass if on to the editor who edits the news item
and then publishes it. In this process the truth might get perverted or garbled. Such
news items cannot be said to prove themselves although they may be taken. into
account with other evidence if the other evidence is forcible.
5. Violence has not been stated in this case. This is merely an assumption. There is no
instance of the public order being disrupted. The respondents are deliberately
misleading the court by stating that the workers tried to travel by road due to the
report. There is no such statement made in the prop and it is merely an assumption.
6. Migrant worker do not read newspaper – incorrect interpretation. Clarification point
states that the
7. Damages is not we want. The law of India is not applicable to a private company in
USA. The laws that have been stated by the resps is applicable to India onl
8. A five Judge Bench of the Supreme Court in Hindustan Antibiotics Ltd. v. Workmen,
(AIR 1967 SC 948, para. 9), noted that "the social and economic upliftment of the
labour is important for securing industrial peace which is essential to increase the
national productivity."
9. Only 785?- This doesn’t matter. Does it?
10. Public emergency-
11. Repugnancy state cannot make - The effect of Art. 253 is that if a treaty agreement or
convention with a foreign State deals with a subject matter within the competence of
the State Legislature, the Parliament alone has, notwithstanding Art. 246(3) the power
to make, laws to implement the treaty agreement or convention.
12. It can be seen that Article 253 contains non-obstante clause. Article 253, thus,
operates notwithstanding anything contained in Article 245 and Article
246. Article 246 confers power on the Parliament to enact laws with respect to
matters enumerated in List I of the Seventy Schedule to the Constitution. Entries
10 to 21 of List I of the Seventh Schedule pertain to International Law. In making
any law "under any of these entries, parliament is required to keep Article 51 in
mind.
State Of West Bengal vs Kesoram Industries 
13. Migrant workers cannot move to supreme court and high courts. Even if they are able
to will put burden upon hon’ble court which has other issues to deal with.
14. No mention that the convention was ratified and a legislation was passed under the
same to bind the union to it. Art. 253
15. Disaster
16. Doctor will share details- Informed consent is not
17. Multiple FIRs harsament – 124A