Relevance of Fundamental Duties Under The Constitution Of India In Society: Implications, Challenges And Remedies

- By Gaurav Kumar, Ph.D. Senior Research Fellow, University of Delhi, India.

- DOI 10.5281/zenodo.10121683

I. INTRODUCTION

“The true source of right is duty. If we all discharge our duties, rights will not be far to seek. If leaving duties unperformed we run after rights, they will escape us like will-o’-the-wisp, the more we pursue them, the farther they fly.”

- Mahatma Gandhi

“Everyone has duties to the community in which alone the free and full development of the personality is possible.”[1]

The Fundamental Duties enshrined in the Indian Constitution represent an often underappreciated and yet profoundly significant aspect of the country's legal and moral framework. These duties were introduced through the 42nd Amendment Act of 1976, which aimed to reinforce the essence of responsible citizenship by drawing inspiration from the Directive Principles of State Policy. The Swaran Singh Committee in 1976 recommended the addition of Fundamental Duties in the Constitution of India as their necessity was felt during the internal emergency of 1975-77.

The 42nd Amendment Act of 1976 added 10 Fundamental Duties to the Indian Constitution. The 86th Amendment Act 2002 later added the 11th Fundamental Duty to the list. While they are non-justiciable in nature, their relevance in contemporary Indian society cannot be overstated. This article explores and delves into the deep-seated relevance and enduring importance of Fundamental Duties, elucidating their philosophical underpinnings, practical implications in contemporary India, challenges faced in their implementation, related legislation, the question of sanctions, and offers effective remedies to foster their observance.

II. RELEVANCE OF FUNDAMENTAL DUTIES

A chapter on fundamental duties was added into the Constitution over a quarter century after the people of India gave it to themselves. Fundamental Duties, while non-justiciable in nature, play a pivotal role in shaping India's social and moral fabric. Rooted in Indian ethos, they echo the philosophy of "Dharma" and uphold constitutional values. Duty to preserve the nation's rich heritage and protect its sovereignty, the duty to uphold the spirit of fraternity, and the duty to promote scientific temper are just a few examples of how these duties contribute to the well-being of the Indian society. They serve as a reminder to citizens of their responsibilities towards the nation and society. This paper also delves deep into the philosophical underpinnings of these duties and their symbiotic relationship with Fundamental Rights.

III. PHILOSOPHICAL UNDERPINNINGS AND CONSTITUTIONAL VALUES

At the heart of the Fundamental Duties lie deep philosophical roots that resonate with Indian ethos. The concept of "Dharma," which encapsulates one's moral and ethical duty, finds a parallel in these duties. They are a reflection of the nation's commitment to constitutional values such as justice, liberty, equality, and fraternity. For instance, the duty to promote harmony and the spirit of common brotherhood amongst all citizens underscores the importance of fostering social cohesion, an essential element of a thriving democracy. Moreover the true source of Right is duty and all fundamental duties are of constitutional significance.

In AIIMS Students Union V. AIIMS[2], it was observed by the Hon’ble Supreme Court of India that “Fundamental duties, as defined in Article 51A, are not made enforceable by a writ of court just as the fundamental rights are, but it cannot be lost sight of that duties in Part IVA - Article 51A are prefixed by the same word fundamental which was prefixed by the founding fathers of the Constitution to rights in Part III.” In the case of State of Gujarat V. Mirzapur Moti Kureshi Kasab Jamat[3], Hon’ble Supreme Court held that the Fundamental Duties in Part IV-A could be guiding factor in testing reasonableness of restriction under Article 19(2) to 19(6).

IV. COMPLEMENTING FUNDAMENTAL RIGHTS

The Fundamental Duties are not standalone obligations; they work in tandem with Fundamental Rights. This synergy ensures a balanced framework that harmonizes individual liberties with societal responsibilities. For example, while Fundamental Rights provide citizens with freedom of speech, the duty to uphold the sovereignty, integrity, and unity of India places an ethical constraint on the exercise of these rights. In essence, Fundamental Duties serve as a moral compass, guiding citizens to exercise their rights responsibly.

In AIIMS Students Union V. AIIMS[4] it was observed by the Hon’ble Supreme Court of India that “State is, all the citizens placed together and hence though Article 51A does not expressly cast any fundamental duty on the State, the fact remains that the duty of every citizen of India is the collective duty of the State.”

V. PRACTICAL IMPLICATIONS AND IMPACT IN CONTEMPORARY INDIA

The practical implications of Fundamental Duties are palpable across various facets of contemporary Indian society. Civic responsibility, a cornerstone of these duties, manifests in citizens' active participation in the democratic process. It translates into responsible voting, engagement in community service, and a heightened awareness of one's obligations towards society. The duty to renounce practices derogatory to the dignity of women, for instance, fosters gender equality and empowers women by challenging regressive norms.

In the case of Rangnath Mishra V. Union of India[5] Hon’ble Apex observed that fundamental duties should not only be enforced by legal sanctions but also by social sanctions. After all, rights and duties are co-relative. Directions were issued to the Centre to consider and take appropriate steps expeditiously for the implementation of the recommendations of Justice J. S. Verma Committee’s report on the operationalisation of fundamental duties.

In Balaji Raghavan v Union of India[6], the Court upheld the constitutional validity of National Awards such as the Bharat Ratna, Padma Vibhushan, Padma Bhushan, and Padma Shri as conferring these awards is not violative of the principles of equality as these awards recognized merit and observed that “Article 51A(j) of the Fundamental Duties chapter exhorts citizens to strive towards excellence in all activities. A system of instituting awards is necessary to incentivise citizens and to recognise excellence in the performance of these duties”.

VI. STRENGTHENING SOCIAL COHESION AND ETHICAL CONSCIOUSNESS

Fundamental Duties play a pivotal role in strengthening social cohesion and promoting ethical consciousness among citizens. The duty to develop the scientific temper and the spirit of inquiry underscores the importance of fostering a scientific mindset. This has far-reaching implications, as it encourages critical thinking and innovation, which are essential for the nation's progress. Additionally, the duty to safeguard public property instills a sense of collective responsibility, discouraging acts of vandalism and promoting a culture of public care.

The practical implications of Fundamental Duties extend to various facets of life. These duties encompass ethical behaviour, respect for all, and the promotion of a just and harmonious society. Their impact is tangible in the form of strengthened civic responsibility, improved social cohesion, and enhanced ethical consciousness among citizens. Further examples and case studies will illustrate how adherence to these duties can lead to a more responsible and progressive society.

VII. CHALLENGES IN IMPLEMENTING AND ENFORCING FUNDAMENTAL DUTIES UNDER THE INDIAN CONSTITUTION

Despite their significance, Fundamental Duties face formidable challenges in their implementation. Widespread unawareness, inadequate enforcement mechanisms, cultural diversities, and varying interpretations pose significant hurdles. Efforts have been made to meticulously examine these challenges, shedding light on the complex task of instilling these duties in the collective consciousness of a diverse nation.

The Fundamental Duties enshrined in the Indian Constitution are a testament to the nation's commitment to responsible citizenship. However, their effective implementation and enforcement present an array of challenges and issues that warrant thorough examination. The various hurdles faced in ensuring compliance with Fundamental Duties in Indian society have been discussed below.

1. Lack of Awareness and Education: One of the most pervasive challenges in implementing Fundamental Duties is the widespread lack of awareness among citizens. Many Indians remain unaware of the existence of these duties, let alone their implications. This knowledge gap arises from a lack of proper education and awareness campaigns. This lack of awareness hinders voluntary compliance and the realization of these duties' true potential.

2. Non-Justiciable Nature: Unlike Fundamental Rights, which are justiciable and enforceable through legal action, Fundamental Duties are non-justiciable. This means that citizens cannot approach the courts for redress if these duties are violated. This non-justiciable nature raises questions about the practical enforceability of these duties and diminishes their perceived significance. This implies that there is an inadequacy of existing enforcement mechanisms and therefore Fundamental Duties lack direct legal remedies. Citizens may not perceive tangible consequences or sanctions for non-compliance, which diminishes their incentive to fulfil their duties diligently.

3. Cultural and Regional Diversity: India's cultural and regional diversity poses a significant challenge to the uniform implementation of Fundamental Duties. Interpretations and priorities regarding these duties may vary across regions and communities. What is considered a priority in one region may not hold the same importance in another, making it challenging to create a standardized approach to duty fulfilment.

4. Lack of Monitoring Mechanisms: There is a notable absence of effective monitoring mechanisms to track compliance with Fundamental Duties. Unlike some Fundamental Rights, which are subject to regular reporting and review, there are no corresponding mechanisms for Fundamental Duties. This lack of oversight leaves room for non-compliance to go unchecked.

5. Difficulty in Measuring Compliance: Measuring compliance with Fundamental Duties is inherently complex. Unlike quantifiable metrics, such as economic indicators, compliance with duties often involves assessing intangible aspects of behavior and morality. This subjectivity makes it challenging to determine whether individuals and institutions are fulfilling their obligations.

6. Limited Legal Framework: While the Indian Constitution outlines the Fundamental Duties, it provides limited legal framework and mechanisms for their enforcement. Unlike Fundamental Rights, which have corresponding legal provisions and remedies, the absence of detailed legal guidelines for enforcing Fundamental Duties complicates their implementation.

7. Lack of Public Discourse: Public discourse and debate around Fundamental Duties are relatively limited compared to discussions about Fundamental Rights. The absence of sustained public discourse on these duties diminishes their visibility and reinforces the perception that they are secondary to rights.

8. Balancing Rights and Duties: There is a continual challenge in balancing Fundamental Rights and Duties. Citizens may sometimes perceive their rights as more immediate and tangible compared to their duties. This perception can lead to a neglect of duties, as individuals may prioritize their personal interests over societal responsibilities. In Re: Ramlila Maidan Incident Dt. 4/5.6.2011 Versus Home Secretary, Union of India and Others[7] it was observed that “Common thread runs through Parts III, IV and IVA of the . One Part enumerates the fundamental rights, the second declares the fundamental principles of governance and the third lays down the fundamental duties of the citizens. While interpreting any of these provisions, it shall always be advisable to examine the scope and impact of such interpretation on all the three Constitutional aspects emerging from these parts.”

9. Changing Social Norms and Values: As society evolves, so do its norms and values. Changing social norms can sometimes conflict with traditional interpretations of Fundamental Duties, creating confusion and resistance. For instance, evolving views on gender roles may challenge certain aspects of these duties to give certain new meanings and interpretations.

10. Lack of Public Accountability: In the absence of effective monitoring and accountability mechanisms, public officials and institutions may not feel sufficiently accountable for promoting the observance of Fundamental Duties. This can result in a lack of leadership and commitment in fostering a culture of responsibility.

11. Resource Constraints: Implementing and promoting awareness of Fundamental Duties require resources, both financial and human. In a country with diverse socio-economic challenges, allocating resources for this purpose may not always be a priority, hindering efforts to raise awareness and ensure compliance.

12. Political Priorities: The political landscape can influence the emphasis placed on Fundamental Duties. Depending on the government's priorities and agenda, the promotion of these duties may receive varying levels of attention and support.

13. Legal Gaps and Ambiguities: Some Fundamental Duties are vaguely worded, leaving room for interpretation. This ambiguity can result in differing interpretations and hinder uniform enforcement. Clearer specific definitions and guidelines may be necessary to address this issue.

14. Enforcement Challenges for Certain Duties: Certain Fundamental Duties, such as the duty to protect and improve the natural environment, present unique enforcement challenges. Balancing environmental conservation with developmental needs requires nuanced policies and strategies.

15. Social Inequities and Disparities: The prevalence of social inequities and disparities in India can impact the effective enforcement of Fundamental Duties. Individuals facing socio-economic challenges may prioritize survival over their responsibilities, leading to non-compliance.
    

VIII. LEGISLATIONS AND PENALTIES: FOSTERING THE OBSERVANCE OF FUNDAMENTAL DUTIES IN INDIA

Recognizing the importance of fostering adherence to Fundamental Duties, the Indian government has introduced legislation and penalties to encourage compliance. Several specific Acts made for this purpose as well as provisions in other laws incentivize compliance and provide punitive measures for non-compliance of these fundamental duties. These legal measures aim to instill a sense of responsibility and deter individuals from neglecting their duties.

However, the effectiveness of these legal measures is a subject of debate. While they create a legal framework, their implementation and enforcement remain challenging. The absence of specific penalties for each duty and the non-justiciable nature of these obligations raise questions about the practicality of relying solely on legal sanctions.

The observance of Fundamental Duties under the Indian Constitution is not merely a moral obligation but also a legal one. These laws aim to incentivize and enforce the observance of Fundamental Duties, ensuring better and more uniform implementation by Indian citizens.

There are various legislations which give teeth to fundamental duties like the Prevention of Insults to National Honour Act, 1971, the Protection of Civil Rights Act, 1955, the Unlawful Activities (Prevention) Act, 1967, the Representation of the People Act, 1951, the Environment (Protection) Act, 1986, and the Forest (Conservation) Act, 1980 and indirectly impose obligations, provide for specifications, penalties and punishments and act as stringent regulations.

1. The Constitution of India

The very foundation of Fundamental Duties lies within the Indian Constitution itself. While the Constitution does not prescribe specific penalties for non-compliance with these duties, it establishes the overarching legal framework within which these obligations must be fulfilled. The Constitution sets the tone for the observance of these duties as essential to upholding the values of the nation.

2. The Indian Penal Code (IPC)

While the Indian Penal Code primarily focuses on criminal offenses, it contains provisions that indirectly support the observance of Fundamental Duties. For instance, Section 153A of the IPC deals with promoting enmity between different groups on grounds of religion, race, place of birth, residence, and language. This aligns with the duty to promote harmony and the spirit of common brotherhood and can be seen as a means of penalizing actions that violate this duty.

Similarly, Section 292 of the IPC deals with the sale, distribution, or exhibition of obscene material. This indirectly enforces the duty to renounce practices derogatory to the dignity of women. While these provisions are not explicitly linked to Fundamental Duties, they contribute to fostering a culture of responsibility.

3. The National Integration Council Act, 1962

The National Integration Council Act, 1962, establishes a framework for promoting national integration and communal harmony. It recognizes the importance of upholding Fundamental Duties that promote unity and fraternity. While this act does not directly impose penalties for non-compliance, it sets the stage for discussions and initiatives aimed at fostering the observance of these duties.

4. The Environment (Protection) Act, 1986

The duty to protect and improve the natural environment is a significant Fundamental Duty. The Environment (Protection) Act, 1986, is a key legislation in this context. While it primarily focuses on environmental conservation, it indirectly reinforces the duty to protect the environment. This act contains provisions for penalties, fines, and even imprisonment for activities that harm the environment. By enforcing these penalties, the government indirectly promotes the observance of the corresponding Fundamental Duty.

5. The Legal Services Authorities Act, 1987

The Legal Services Authorities Act, 1987, aims to provide free and competent legal services to the weaker sections of society to ensure justice for all. It indirectly supports the Fundamental Duty to promote justice. While not focused on penalties, this act establishes mechanisms to ensure access to justice for citizens, thus contributing to the observance of their duties.

6. State-Specific Legislation

Some Indian states have also enacted state-specific legislations to promote the observance of Fundamental Duties. These laws may include penalties for non-compliance or provide for the creation of awareness programs and campaigns to educate citizens about their responsibilities.

7. International Agreements and Conventions

While not legislations per se, international agreements and conventions to which India is a signatory indirectly influence the observance of Fundamental Duties. For instance, India's commitment to international human rights conventions reinforces its dedication to upholding Fundamental Duties related to human dignity and equality.

In conclusion, these laws establish penalties for non-compliance, creating a legal framework to incentivize citizens to fulfill their responsibilities towards the nation and society. While challenges in enforcement and awareness persist, these legislations represent crucial steps toward fostering a culture of responsible citizenship and ensuring the uniform implementation of Fundamental Duties in India.

IX. EFFECTIVE SANCTIONS FOR FUNDAMENTAL DUTIES IN INDIA: CHALLENGES AND SOLUTIONS

Critics argue that Fundamental Duties in India lack proper and effective sanctions, leading to nominal compliance. It has to be seen whether punitive measures are essential for their effective observance or whether the emphasis should be on education and awareness. The debate surrounding sanctions for non-compliance with Fundamental Duties is multifaceted. Proponents argue that introducing sanctions is essential to ensure the seriousness of these duties. They contend that without punitive measures, citizens may view these duties as optional, undermining their significance. Sanctions, in this view, serve as a necessary deterrent.[8]

However, opponents emphasize that sanctions should not be the primary means of fostering duty observance. They argue that the focus should instead be on education, awareness, and voluntary compliance. The absence of sanctions, they claim, reflects the framers' intention to nurture a sense of moral duty rather than relying on punitive measures. Moreover, concerns are raised about the potential misuse of sanctions, which could stifle dissent and freedom of expression.

The historical context of the absence of sanctions is also essential to consider. When the Fundamental Duties were incorporated into the Constitution, they were envisioned as moral and ethical obligations rather than legal mandates. This historical perspective sheds light on the reasoning behind their non-justiciable nature.

The Fundamental Duties enshrined in the Indian Constitution represent the moral and ethical obligations of citizens towards the nation and society. While these duties are vital for fostering responsible citizenship, a longstanding debate revolves around whether they lack proper and effective sanctions for enforcement. It needs to be critically examined whether Fundamental Duties in India lack adequate sanctions, and what are its implications. Also effective solutions and remedies needs to be identified to ensure their better implementation.

The argument that Fundamental Duties in India lack proper and effective sanctions revolves around several key challenges:

1. Non-Justiciable Nature: Fundamental Duties are non-justiciable in nature, which means they are not enforceable through legal action. Unlike Fundamental Rights, which can be defended in courts, there are no direct legal remedies for non-compliance with Fundamental Duties. This non-justiciable nature raises questions about the practical enforceability of these duties.

2. Ethical and Moral Obligations: Fundamental Duties are often seen as ethical and moral obligations rather than legally binding responsibilities. This perception leads to a belief that compliance should be voluntary and driven by a sense of duty rather than the fear of sanctions. Consequently, individuals may not perceive tangible consequences for non-compliance, which diminishes their incentive to fulfill their duties.

3. Cultural Context and Diversity: India's cultural diversity and regional variations can complicate the imposition of uniform sanctions for Fundamental Duties. Different communities and regions may have varying interpretations of these duties, and imposing sanctions that do not account for these diversities may lead to unintended consequences and resistance.

4. Historical Context: When Fundamental Duties were incorporated into the Constitution, they were envisioned as guiding principles rather than strict legal obligations. This historical context influences the debate over sanctions and whether they should be applied retroactively to duties initially intended as moral guidelines.
   

X. IMPLICATIONS OF THE LACK OF PROPER SANCTIONS

The lack of proper and effective sanctions for Fundamental Duties in India has several implications:

1. Perceived Irrelevance: Some citizens may perceive Fundamental Duties as non-binding and irrelevant to their lives due to the absence of enforceable sanctions. This perception can lead to neglect and indifference towards fulfilling these duties.

2. Reduced Accountability: The absence of sanctions can reduce accountability among citizens, public officials, and institutions for promoting the observance of Fundamental Duties. Without consequences for non-compliance, there may be a lack of motivation to actively promote and enforce these duties.

3. Challenges in Enforcement: The lack of legal remedies for non-compliance can make it challenging for authorities to enforce Fundamental Duties. This may result in limited action against those who violate these duties.

4.Potential Misuse of Sanctions: There are concerns that the introduction of sanctions for Fundamental Duties could potentially be misused for political or ideological purposes. Sanctions, if not carefully implemented, may infringe on individual freedoms and rights.

XI. SOLUTIONS AND REMEDIES

To overcome the challenges in implementing Fundamental Duties, a multifaceted approach is needed. The role of education in promoting awareness, the need for sustained awareness campaigns, and the importance of civil society organizations in instilling a sense of duty among citizens needs to be emphasized.

To address the challenges in implementing Fundamental Duties and encourage their observance, a multifaceted approach is essential. Education and awareness campaigns play a pivotal role in promoting these duties. Schools, colleges, and other educational institutions can incorporate lessons on Fundamental Duties to ensure that future generations are aware of their responsibilities as citizens.

Civil society organizations also have a vital role to play. They can organize awareness programs, workshops, and community initiatives to instill a sense of duty among citizens. Grassroots efforts, driven by civil society, can significantly contribute to creating a culture of responsibility.

Legal reforms may be necessary to strengthen the observance of Fundamental Duties. While punitive measures should not be overly harsh, introducing mild penalties for repeated non-compliance with certain duties may serve as an effective deterrent. Additionally, creating mechanisms for citizens to report instances of non-compliance can promote accountability.

Addressing the issue of the lack of proper and effective sanctions for Fundamental Duties in India requires a balanced and multifaceted approach:

1. Education and Awareness: Promoting education and awareness campaigns is essential to ensure citizens understand the significance of Fundamental Duties. Schools, colleges, and other educational institutions can incorporate lessons on these duties, emphasizing their importance as ethical and moral obligations.

2. Public Discourse and Debate: Encouraging public discourse and debate around Fundamental Duties can create a culture of responsibility. Open discussions can help citizens recognize the relevance of these duties in contemporary society and foster a sense of collective duty.

3. Voluntary Compliance: While considering legal sanctions, it is crucial to emphasize voluntary compliance. Citizens should be motivated to fulfill their Fundamental Duties driven by a genuine sense of duty and responsibility rather than the fear of legal repercussions.

4. Legal Reforms: Exploring legal reforms to introduce graduated penalties for repeated non-compliance with certain Fundamental Duties may be considered. These penalties should be reasonable and proportionate, ensuring that they do not infringe on individual freedoms.

5. Regional and Cultural Sensitivity: Sanctions, if introduced, should be sensitive to India's cultural diversity. Regional variations and cultural contexts should be considered when implementing sanctions to avoid unintended consequences and resistance.

6. Review and Accountability Mechanisms: Establishing review and accountability mechanisms, similar to those for Fundamental Rights, can help monitor compliance with Fundamental Duties. Independent bodies can oversee the implementation and report on the progress.

7. Integration with Existing Laws: Efforts should be made to integrate the observance of Fundamental Duties with existing laws, such as environmental regulations and anti-discrimination laws. This can indirectly enforce certain duties while maintaining legal coherence.

In Dr. Dasarathi v. State of Andhra Pradesh[9], the Court held that it is the duty of every citizen to constantly strive towards excellence in the various spheres of life and continuously make relentless efforts to achieve accolades and that is how the nation as a collective body of its citizens will constantly move towards new levels of excellence.

The Supreme Court in Minerva Mills Ltd.v. Union of India,[10] held that “There may be a rule which imposes an obligation on an individual or authority and yet it may not be enforceable in a court of law and therefore not give rise to a corresponding right in another person. But it would still be a legal rule because it prescribes a norm of conduct to be followed by such individual or authority. The law may provide a mechanism of enforcement. A rule imposing an obligation or duty would not therefore cease to be a rule of law because there is no regular judicial or quasi-judicial machinery to enforce its command. Such a rule would exist despite of any problem relating to its enforcement. Otherwise, the conventions of the Constitution and even rules of international law would no longer be liable to be regarded as rules of law.”

XII. CONCLUSION

The debate over whether Fundamental Duties under the Indian Constitution lack proper and effective sanctions is complex. While there are challenges associated with imposing sanctions, there is a growing recognition of the need to promote these duties as essential to responsible citizenship. Balancing voluntary compliance, education, and awareness with reasonable legal measures is key to ensuring that Fundamental Duties are not just symbolic but integral to the nation's progress. Ultimately, the goal should be to create a culture where citizens willingly fulfil their duties, understanding their significance in building a harmonious and responsible society.[11]

Fundamental Duties under the Indian Constitution are not mere legal obligations; they are the moral and ethical foundation of responsible citizenship. Their philosophical underpinnings, complementarity with Fundamental Rights, and practical implications make them indispensable in contemporary Indian society. However, challenges in implementation, the question of sanctions, and the need for practical remedies must be acknowledged.

Balancing legal measures with education and awareness is the key to fostering a culture of responsibility. India's strength lies in its diversity, and by embracing this diversity, the nation can promote a sense of duty that transcends regional and cultural boundaries. Ultimately, Fundamental Duties are not just a legal requirement; they are guiding principles for a responsible and harmonious society, where citizens recognize their role in shaping the nation's destiny.

In sum and substance, the effective implementation and enforcement of Fundamental Duties under the Indian Constitution face a multitude of challenges. These challenges range from a lack of awareness and education to the non-justiciable nature of these duties, cultural diversity, and resource constraints. Addressing these issues requires a multi-pronged approach, including education, awareness campaigns, legal reforms, and public discourse, to foster a culture of responsible citizenship and ensure that Fundamental Duties are not just symbolic but integral to the nation's progress.Top of FormBottom of Form

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ENDNOTES

[1] Article 29(1), Universal Declaration of Human Rights.

[2] AIR 2001 SC 3262

[3] AIR 2006 SC 212

[4] AIR 2001 SC 3262

[5] Writ Petition (C) No. 239 of 1998, JT 2003(7) SC 206

[6] (1996) 1 SCC 361

[7] [2012] 2 MLJ (CRL) 32

[8] Tewari, G. S. (1999). Need for strict Compliance of Fundamental Duties Enshrined in the Constitution of India. The Indian Journal of Legal Studies, 19, 73.

[9] 1984 SCC OnLine AP 107.

[10] (1980) 3 SCC 625.

[11] Rao, V. K. R. V., & Singh, S. S. (1976). Fundamental duties and directive principles under the proposed amendments to the constitution [with concluding remarks by the Chairman Sardar Swaran Singh]. India International Centre Quarterly, 3(4), 266-284.