and support their parents,51 safeguard unity,52 uphold the Constitution,53 honour and defend the motherland,54 and pay taxes.55 This conception of duties as limiting the rights, especially as some have interpreted implicit restrictions on rights such as the freedom of speech. 4. Minor references So far in the sections in this part of the paper the key historical Constitutions that reference duties prominently are reviewed. There are other historical Constitutions that contain minor references to duties. The ‘Draft of Indian Woman’s Charter of Rights and Duties, 1946,’ prepared by the All-India Women’s Conference sets out seven duties in Part XII titled the ‘Duties of Woman’. These duties are preceded by Chapters II and III which set out the fundamental rights and civic rights of all citizens. By contrast, the duties, which include social, cultural and political duties, are addressed specifically to women. The duties in Part XII include a ‘duty of women, equal to that of men, to serve the nation when the need so arises, be it in cases of natural calamity or national crisis.’56 Apart from the political duty to offer national service, the social duties of women include the duty to educate oneself and one’s children.57 Finally, Part XII includes a cultural duty to ‘set and maintain a high standard of morality in all spheres of life.’58 The duties set out in this draft Constitution distinctly move away from the socialist and Gandhian models of duties in that they are specifically cast upon women. Unsurprisingly, this model finds little resonance in subsequent Constituent Assembly Debates or in the Constitution of India 1950. The Manipur State Constitution Act of 1947 also contained fundamental duties. Ordered to be drafted by Maharaja Bodhchandra Singh in the political and historical context of India’s imminent independence, prior to Manipur’s eventual merger with the Union of India, it sought to reflect the democratic desires of the people of Manipur. Chapter X of the Act is promisingly titled Fundamental Rights and Duties of Citizenship. However, on closer review, it enumerates only the rights of citizens and does not set out any discrete duties to be performed by citizens. The only duties mentioned are duties to be fulfilled by the officials of state.59 Article 49, Constitution of China, 1982. Article 52, Constitution of China, 1982. 53 Article 53, Constitution of China, 1982. 54 Articles 54 and 55, Constitution of China, 1982. 55 Article 56, Constitution of China, 1982. 56 IWC.12, Part XII Duties of Women, Draft of Indian Woman's Charter of Rights and Duties (All India Women's Conference, 1946). 57 Part XII (3) and (5), Draft of Indian Woman's Charter of Rights and Duties (All India Women's Conference, 1946). 58 Part XII (6), Draft of Indian Woman's Charter of Rights and Duties (All India Women's Conference, 1946). 59 Article 55, Chapter X, Manipur State Constitution. See also Article 9(d) and Article 15, Manipur State Constitution. 51 52 Journal of the National Human Rights Commission, Vol. 22, 2023 31