Furthermore, The Supreme Court in quite a few cases has been seen protecting the fundamental duties which only goes to show that the fundamental duties have an important status in our society and that the judicial reforms and introduction of Article 51-A via the 42nd Amendment Act and 86th Amendment Act were not bad in law or unnecessary.

On the other hand, they have done something positive for the country if at all they have done something.

In M.C. Mehta v. Union of India[26], the Supreme Court made it compulsory for all educational institutes to organise a one-hour lecture on protecting and preserving the natural environment and made the Central Government duty-bound to make this a rule in all such institutes and make it a part of their curriculum and issued certain directions in general to the Central Government and citizens on maintaining a healthy ecology and preserving the natural environment;

With a view to strike a balance between fundamental rights and fundamental duties, the petitioner in Rangnath Mishra v. Union of India[27] addressed a letter to the President of India to pass directions to the State Government to raise awareness by educating citizens on fundamental duties

This was taken up by the Supreme Court as a writ petition when at the same time the National Commission after reviewing the Constitution submitted its report to the Government which recommended the Government to create awareness among citizens and follow the procedure as laid down in the Justice Verma Committee Report for implementing the fundamental duties

In Dr. Dasarathi v. State of Andhra Pradesh[28], 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 above examples only go to show that the insertion of Article 51-A was in a way necessary and a need of the hour as it is a means to hit a balance between civic rights, liberties and freedoms and civic obligations.

The said article has gained and retained the confidence of all political parties and has remained on the statute book for more than 35 years.

Moreover, the addition of Article 51-A brings our Constitution in line with Article 29(1) of the Universal Declaration of Human Rights, 1948 which provides that:

Everyone has duties to the community in which alone the free and full development of the personality is possible.”[29] and Constitutions of other major countries.