could be exercised by citizens in Article 13 of the Draft Constitution (Article 19, Constitution of India, 1950), Algu Rai Shastri urged that constitutional freedoms are not absolute and unabridged.76 Shastri emphasised that in an independent India these freedoms must not be endangered or misused and the duty to be good citizens necessarily implied restrictions.77 This invocation of citizen duties as a limitation on rights found no further support in the Assembly in the 1948 Debates, but reappeared in 1949. 2. 1949 Deliberations Kishorimohan Tripathi reaffirmed the view that limited fundamental rights implied corollary citizen duties.78 His observation with respect to the right to property did not draw a direct engagement.79 However, Nandkishore Das, in a separate thread of the debate, went further to suggest the inclusion of enumerated rights correlated with enumerated duties to be performed by citizens to be eligible for their rights.80 In a later session, G. Durgabai also lamented the lack of explicit duties of citizens in the Constitution,81 but suggested that they were implicit as citizens owe an obligation and duty to the state from which rights and protections are demanded.82 Unlike other references to citizen duties, Durgabai explicitly recognises citizen duties to be owed to the state rather than fellow citizens. The most elaborate view on fundamental duties in relation to fundamental rights was presented by B. Pattabhi Sitaramayya.83 Sitaramayya noted that despite the inability to enumerate these duties, fundamental rights necessarily implied and included within them duties in any case.84 He clarified that duties arose from the horizontal application 7.65.103 - 7.65.109, 2 December 1948 https://www.constitutionofindia.net/debates/02-dec-1948/ (accessed 9 October 2023). 77 7.65.110, 7.65.111, 2 December 1948 https://www.constitutionofindia.net/debates/02-dec-1948/ (accessed 9 October 2023). 78 10 September 1949 https://www.constitutionofindia.net/debates/10-sep-1949/ (accessed 9 October 2023). Fundamental duties were explicitly also mentioned by Prabhudayal Himatsingka, who lamented the absence of fundamental duties along with fundamental rights. However, this was stated overarchingly in the context of the working of the Constitution and the people in charge of its implementation. To target these lacunae, Himatsingka proposed that fundamental duties, had they been incorporated, could have helped with the difficulties that could arise in the context of fundamental rights. 11.159.105, 18 November 1949 https://www.constitutionofindia.net/debates/18-nov-1949/ (accessed 9 October 2023). 79 9.137.119, 10 September 1949 https://www.constitutionofindia.net/debates/10-sep-1949/ (accessed 9 October 2023). 80 23 November 1949, https://www.constitutionofindia.net/debates/23-nov-1949/ (accessed 9 October 2023). 81 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). 82 11.164.91, 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). 83 25 November 1949, https://www.constitutionofindia.net/debates/25-nov-1949/ (accessed 9 October 2023). 84 11.165.178, 25 November 1949, https://www.constitutionofindia.net/debates/25-nov-1949/ (accessed 9 October 2023). 76 34 Journal of the National Human Rights Commission, Vol. 22, 2023