This is in response to the public comment submitted by the Integration Panel here. (Link:https://www.icann.org/en/public-comment/proceeding/root-zone-label-generation-rules-version-6-rz-lgr-6-17-06-2025/submissions/integration-panel-27-06-2025)

1. Addition of Devanagari Chandrabindu (U+0901) and Bengali Chandrabindu (U+0981) as variants:

This is a valid suggestion and can be incorporated. 

2. Addition of Devanagari Halanta (U+094D) and Bengali Hasanta (U+09CD) as variants:

This pair can only be admitted as a variant on a conditional basis. The condition being that the Halanta/Hasanta is the last character of the label. If the Hasanta/Halanta is between two consonants, then it totally loses its shape and manifests in the form of a conjunct, the shape of which depends on the two adjoining consonants between which the halanta/hasanta is placed. These shapes are not predictably similar even if the adjoining consonants are variants. This is exemplified below:

Devanagari Consonant म (092E) is already a variant with Bengali Consonant ম (09AE). Let us create a conjunct with itself using the respective Halanta/Hasanta in their scripts.

Devanagari: म ् म = म्म

Bengali: ম ্ ম = ম্ম

As can be seen, the resultant shape is not similar even in case of those consonants which are actually variants. This is even more prominently different when the participating consonants are different. Adding stand-alone Halanta/Hasanta as variants will assume this equivalence which is not the case, hence this kind of occurrence of halanta/hasanta cannot be admitted as a variant. 

In instance when it comes as the last character of the label, it retains its shape and on the basis of that, it can be termed as a variant. This is exemplified below:

Devanagari: म ् = म्

Bengali: ম ্ = ম্

Hence the recommendations are as follows:

i. The Devanagari Chandrabindu and the Bengali Chandrabindu can be added as the variants. 

ii. The Devanagari Halanta (094D) can be considered as variant with Bengali Hasanta