1. Your argument should, at the very outset, answer : WDWTW. Who did what to whom? Legal issues can come later.

2. Storytelling is key. Use choice details to paint a vivid image.

3. Carefully sift admitted and disputed facts. Narrow down the point of controversy.

4. Concede bad facts. Be fair. Build credibility. Be objective.

5. Humanise the Client (though not always!)

6. Pre-empt challenges/arguments from your opponents. Deal with them in the affirmative arguments itself. Confront them – take the sting out of them.

7. Don’t carpet bomb. Arguments, like evidence, are weighed not counted. (yaha wajan hota hai ginti nahi). Choose your arguments. Not every idea deserves to be tested in final arguments. Pls remember : each idea shot down (on law or facts) makes you lose credibility.