of fundamental rights, and rights of citizens were to be protected by imposing duties on citizens. For instance, the right accrued to one was the duty to be performed by another, a neighbour, where the right of the wife to equality was the duty of the husband to respect such equality. Thus, rights and duties go together, two faces of the same coin. This conception of duties would mean that they are included in the Constitution as rights necessarily contemplated duties regardless of explicit mention. This view of duties resembles the Hohfeldian logical model of rights and duties.85 N.G. Ranga builds on the Gandhian model of citizen duties and suggests that for fundamental rights to be enjoyed and protected, each individual must do their duty to safeguard these rights, much like the satyagrahis of the Gandhian independence struggle.86 Ranga went further to claim that the enjoyment of rights was contingent on the performance of duties; hence, dissident groups who would not do their duty towards society had no sense of responsibility, restraint or morality should not be allowed to benefit from their rights.87 This argument drew on an analogy between citizen duties and the duty of satyagraha88 that deserved a fuller clarification but was not pursued further. While Ranga invoked a Gandhian view of duties, V. Subramaniam developed a fuller cultural duty of citizens to work along with the state to carry out the Constitution in letter and in spirit, making reference to both fundamental rights and the directive principles of state policy.89 Subramaniam refers to duties as emanating from dharma, but not as varna as a method of structuring society or as a means of dictating set occupations and further entrenching distinctions based on birth or status.90 A similar distinction between duties arising out of dharma and out of democracy was made by Ammu Swaminathan who stated that for the Constitution to work and for India to be a democratic state, all citizens must know not just their rights but also their duties, so as to not see freedom as license.91 Wesley Newcomb Hohfeld, ‘Fundamental Legal Conceptions as Applied in Judicial Reasoning’ (1917) The Yale Law Journal, Vol. 26, No. 8. 86 7.70.131, 9 December 1948 https://www.constitutionofindia.net/debates/09-dec-1948/ (accessed 9 October 2023). 87 7.70.133, 9 December 1948 https://www.constitutionofindia.net/debates/09-dec-1948/ (accessed 9 October 2023). 88 7.70.142, 9 December 1948 https://www.constitutionofindia.net/debates/09-dec-1948/ (accessed 9 October 2023). 89 11.164.97, 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). This duty to carry out the Constitution was also stated during the same session by Kaka Bhagwant Roy, specifically in the context of the duty of people to eradicate discrimination. 11.164.115, 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). 90 11.164.98, 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). Dharma was once again invoked as a path to societal betterment in the same session by Shri Har Govind Pant. 11.164.191, 24 November 1949, https://www.constitutionofindia.net/debates/24nov-1949/ (accessed 9 October 2023). 91 11.164.211, 24 November 1949, https://www.constitutionofindia.net/debates/24-nov-1949/ (accessed 9 October 2023). 85 Journal of the National Human Rights Commission, Vol. 22, 2023 35