Chapter 2 | Page 69 by the State.114 It is therefore held that the principle of non-retrogression is an extremely crude measure of compliance.115 Under Article 4 of the ICESCR, limitations are allowed for reasons of ‘promotion of general welfare’ but not for reasons of ‘national security’, ‘public order’ or ‘public morals’. The purpose of this is to give States flexibility in balancing individual rights with public interests.116 However, such limitations are to be determined by law, which is not required in the case of derogations.117 Alston and Quinn argue that, in the present context, Article 4 was clearly seen by its drafters as dealing with limitations other than those that could be imposed under Article 2(1) on the grounds of limited resource availability.118 The permissive function of the limitations clause is to allow States to impose limitations where: (1) an unlimited interpretation of a right would lead to absurd results and would deny a state the necessary authority to enact detailed regulatory provisions; and (2) the various rights would otherwise clash with each other or with the legitimate interests of the state.119 Examination of the drafting history of the Covenant reveals the kinds of difficulties that were encountered in identifying suitable approaches to the inclusion of limitations to the ESC rights in the text.120 For example, the United States delegation insisted that: ‘It was not always possible to grant the same thing to everybody at the same time and in the same way’,121 therefore 114 CESCR General Comment No 3, E/1991/23, above n 49, [9]. 115 Mary Dowell-Jones, Contextualizing the International Covenant on Economic, Social and Cultural Rights: Assessing the Economic Deficit (Martinus Nijhoff Publishers, Leiden, 2004), 52. 116 Amrei Muller, 'Limitations to and Derogations from Economic, Social and Cultural Rights' (2009) 9 Human Rights Law Review 557-601, 570. 117 Ibid., 565. 118 Alston and Quinn, above n 1, 194. 119 Ibid., 197. 120 Summary record of the 236th meeting of the Commission on Human Rights, above n 73, 4-5. 121 Ibid., 6.