- Achintya Anita Gurumurthy*
I. Introduction
Given recent discussions on the attack on constitutional and democratic values, it would be useful to inquire into how different constitutional provisions can be re-excavated. The Fundamental Duties – a compelling part of the Indian Constitution – were absent in the original draft of the Constitution. This piece reimagines Fundamental Duties by centring Ambedkar, to critique the largely liberal imagination of rights and duties as conceptualised within the social contract, which is tethered to the protection of private property. An Ambedkarite position, in contrast, illustrates an imagination of democratic participation that has a firm anti-caste basis, rooted in an anti-discrimination focus. While rights must remain a central framework to conceptualise how constitutional measures can preserve democratic practices, duties can offer a complementary extension. This piece suggests that Ambedkarite refashioning of duties does not confine the term to its narrow construction of being read with rights but enables us to conceptualise a just society.
This essay argues that in the Ambedkarite sense, duties can be reimagined in a range of ways: public duty, democracy as duty, duty for fraternity, and duty of social justice movements. First, this piece will illustrate that Ambedkar's approach is not uncritical. He locates the word ‘duty’ within its scriptural and cultural role in the Hindu order in which a conception of duties perpetuates marginalisation of and violence against oppressed castes. Second, this piece will contextualise the current importance of re-reading duties, by highlighting how the Ambedkarite reading of the term can be extricated from its contemporary usage within capitalist and fascistic formulations. Furthermore, the piece delves into how he offers new meanings of the word. Third, by imagining an Ambedkarite rewriting of Fundamental Duties, it will show how Ambedkar asserts the duty of the majoritarian oppressor group to do justice, instead of marginalising oppressed communities. Fourth, it will demonstrate the citizen’s duty to fight for democracy and resist the social forces that result in exclusion and non-participation. Fifth, the piece will analyse how fraternity and rejection of untouchability form the fulcrum of Ambedkar’s perception of duty. Finally, the piece will explore how Ambedkar also uses the word to emphasise the duty of formulating a path for the anti-caste movement.
II. Sanctifying Oppression: How the Hindu Order Relies on Duty
To appreciate Ambedkar’s radically liberating ideas of duty, we must first turn to his critique. Ambedkar argues that ‘duty’ within the varna and jati (caste) system is characterised by deep violence – as symbolised in the “penalty of death”[1] that was meted out to Shambuka.[2] He describes how because Hinduism “knows only rights and privileges”, it is a system that is characterised by an asymmetry of duty. Duty within the caste order then exists as a structure to sanction the exploitation of human beings, in which oppressor castes can extract labour and deprecate the labourer in the name of divine duty.[3] In ‘Philosophy of Hinduism’, for instance, Ambedkar reflects on such an understanding of duty by pointing to the Manusmriti in which it is detailed that if any priest is instructed about his duty by a Shudra (lowest varna), then the king should order that “hot oil to be dropped into his mouth and his ear”.[4] Here, the duty of the Brahmin (highest varna) is one of arrogance, one that enslaves.
Additionally, Ambedkar identifies that the Hindu order cannot allow individuals to have a “sense of duty to fallen humanity”.[5] He says that “no amount of sense of duty can enable him (a Hindu) to overcome his duty to preserve his caste”.[6] Thus, it is essential to note that Hinduism[7] is characterised by a sense of duty that perpetuates oppression and prevents any collective aspirations for the pursuit of justice and dignity. This criticism is necessary to note in light of casteist notions of duty that continue to permeate modern social relations. For instance, a large majority of the individuals performing manual scavenging and sanitation work continue to belong to marginalised caste positions.[8] It is therefore necessary to retrieve the construction of duty from a location of such disparity and discrimination, in order to imagine its role within a democratic society.
III. Current Context – The Necessity for Re-reading ‘Duty’
The historical legacy of the Fundamental Duties provisions in Part IVA of the Constitution is questionable. This portion was added during the Emergency, as part of the extensive changes introduced by the State through the 42nd Amendment, during which there was a concerted attempt to produce an obedient citizenry.[9] Tracing its Ambedkarite roots can be contested further because ‘States and Minorities’, an important document that is considered as Ambedkar’s preliminary draft of the Constitution,[10] does not include any provision on duties. However, a closer reading of Ambedkar’s writings offers us a new imagination of the word ‘duty’, one that points to a just and more participatory democratic practice.
In today’s context, an Ambedkarite reading of the notion of ‘duty’ helps extricate the term from its capitalist origins in social contract theory, which are exclusionary and premised on a reciprocal State-citizen relationship. Within such a system, the duty of the citizen to maintain law and order is tied to the duty of the State to protect existing property relations. Any imagination of rights within such a social system is embedded within exploitative property relations. Since the legitimacy of the State is premised on protecting private property and not the welfare of citizens, the interest of the law tends toward the powerful classes.[11] In this regard, Marx argues – “the practical application of man’s right to liberty is man’s right to private property”.[12] Therefore, within social contract imaginations of State, the primary concern is the continued exploitation of the working class in the interest of private property. Scholars have illustrated how the State excludes both women and and marginalised communities from public institutions and voting, because they do not own private property, when it is based on social contract. This conception is hence problematic, since such a conception of rights and duties enshrines racist and patriarchal connotations.[13]
Even beyond the modern capitalist State, the term ‘duty’ can be excavated from its location within fascist ideology and politics. Nivedita Menon, for instance, argues that the usage of the term “Fundamental Duties” within the NEP 2020 document, and the conspicuous absence of the use of “Fundamental Rights”, reveals its “RSS patronage”.[14] Here, it is apparent that repressive or authoritarian projects often use the conception of duties to dilute rights. A dichotomy emerges in which rights are made contingent on and available to only those citizens who obediently perform duties. In this manner, duties are frequently relied on by several oppressive ideological projects.
A. Public Duty and Public Office
Ambedkar flips the given conceptions of duty exclusively imposed on the citizen, instead asserting that it is necessary for the oppressor community that dominates public institutions to abide by certain duties. A recurrent theme in his foundational document – ‘States and Minorities’ – reflects how it is necessary for individuals and representatives in public office to protect the oppressed against tyranny that is both social and official.[15] Further shifting the gaze and burden, he argues that the system of democracy and the structure of the electorate is not an “exclusive concern of the minority”.[16] Here, it is amply visible that Ambedkar envisions the political majority that is “born”[17] – or the oppressor caste communities dominating the political institutions – as carrying the burden of duty to preserve democracy.
Ambedkar cautions that the representatives of democracy may act to aggrandize themselves to the great detriment of citizens.[18] This is because, public representatives may “love their class more than their duty”.[19] In this regard, he points out that every representative is torn among three duties – to himself, to the class, and to the voter.[20] Considering these conflicting duties, it is necessary to have robust legal mechanisms to ensure accountability. This framework is reflected in Ambedkar’s emphasis on fundamental rights. Within such a structure, it is necessary for the State to acquire its powers from “those whose rights it is charged with the duty to protect”.[21] Therefore, because the duty of the State necessarily emerges along with the rights and consent of the citizens, one of the imaginations of duties for the State that Ambedkar offers is inbuilt into the provisions for Fundamental Rights. Additionally, because these rights are justiciable, they offer a more robust framework for democracy. Through this joining of rights and duties, Ambedkar is able to overcome the dichotomy between the two, by creating reciprocal ties between citizen and State.
Ambedkar also imposes a duty of representation upon the oppressor majority. He argues that it is necessary for socially degraded and educationally backward communities to have legal safeguards in the form of representation in public institutions. Therefore, he imposes this duty of ensuring representation upon the State – to recognise the “duty towards social progress” and cultivate a legal mechanism by which 'Depressed Classes' may find space within governmental institutions.[22] It is in this regard that Ambedkar proposes the idea of balanced representation in his important address, ‘Communal Deadlock’.[23] This aspect of balanced representation is visible in the reservation of political positions for oppressed groups.
Therefore, a citizen’s duty to participate in democratic practices and processes cannot be extricated from the legal obligation of the State to ensure reservations for oppressed castes as a right. Only this duty of the State can actively foster democratic participation such that citizens may aspire to hold office. Thus, the dialectic of State along with citizen must be fleshed out. However, it is still necessary to introduce more stringent mechanisms to make the caste character of public institutions and welfare measures more egalitarian. Any attempt to dissolve the dominant caste character of public institutions must be seen “as a goal in itself”.[24] Altering the caste character of public institutions by means of participation and representation is therefore integral.[25]
B. Democracy as Duty
Ambedkar’s idea of duty also involves an understanding that citizens must imbibe a duty towards preserving and promoting democratic ideals. For instance, his emphasis on democracy as duty is apparent in his views on Nazism and the Second World War. When the fascist scourge was taking over global politics, Ambedkar argued for citizens to be “true and loyal” to democracy and said that there was a “heavy duty to see that democracy does not vanish from the earth”.[26] The conception of citizenship is therefore premised on a duty and fidelity towards democratic practice. This is resonated in Article 51A(a) that lays down a duty to “abide by the Constitution and respect its ideals and institutions”.
However, as Narrain illustrates, such a democratic spirit must necessarily be governed by constitutional morality because in the Indian parliamentary democracy, disadvantaged minorities are dominated by the political majority.[27] Ambedkar indicates that the representative function of democracy should not define it.[28] Instead, it is necessary for public institutions to also have an anti-discrimination focus. While this includes having institutional mechanisms in place for wider representation in public institutions, it also includes radical structural changes in social relations and the State, which have to be struggled for.
Moreover, in reimagining a duty towards democracy, Ambedkar points out that there must be a duty to strive against hereditary entitlements. For instance, in ‘Federation Versus Freedom’, Ambedkar points out that while many may hold the view that a Prince is entitled to ruling, it may be important to pose the question “what is more important, the right of the Prince or the welfare of the people?”.[29] Offering a picture of popular sovereignty and democratic spirit in which hero worship is absent, he declares, “I am no worshipper of idols”.[30] Thus, Ambedkar’s idea of duty towards democracy/duty as democracy is profound. It is one that situates political participation firmly outside of the social privileges and networks that dominant castes create and enjoy within the Hindu order. It is one that attempts to resist the entitlements, social capital, and norms of reciprocity that characterise feudal society.
Additionally, Ambedkar’s views on voting also deserve mention. The practice of voting is often invoked as a citizen’s duty. In the Constituent Assembly debates, several prominent political leaders expressed that only those who are educated should be entitled to the vote.[31] In contrast to such a patronising idea of participation, Ambedkar’s conception of voting in a democracy as a duty is imposed on ruling classes. He argues, that “adult suffrage is irresistible” and that illiteracy is not the fault or prerogative of the underprivileged and illiterate citizen.[32] By expressing suffrage as “irresistible” he illustrates how political participation is an exercise that individuals do not relinquish themselves from, but are instead excluded from. It is, therefore, a burden upon the State to educate its citizenry, and build an inclusive electoral process that does not heed or discriminate on the basis of educational qualifications. This reflects Ambedkar’s non-elitist expression of citizen participation, in which free and political expression is not a burden imposed on the citizens alone.
Traces of such a conception of duty can be located in the current framework. Article 51A(a) urges that citizens must abide by the Constitution and respect its just ideals. While what constitutes constitutional morality remains varying and numerous,[33] Bhatia points out that its essence still continues to remain “dangerous’ to the dominant classes and their clasp over power.[34] By foregrounding the importance of the Constitution in mapping the futures of Indian democracy, one can unearth the footsteps of Ambedkar in Article 51A(a). In a time when democracy remains under threat, an Ambedkarite retelling of duty can enable a democratic ethic in citizens and public institutions.
C. Duty Towards Fraternity and Against Untouchability
While Ambedkar’s resistance against caste entailed a structural and revolutionary struggle – and was fundamentally premised on its annihilation – it also included eradicating the evil of untouchability. Bhaskar argues that the provision of Article 17 prohibiting untouchability within fundamental rights was essential because it is what enabled citizens to enjoy the other Fundamental Rights.[35] The duty against untouchability still remains integral to the imagination of democracy in India today. This resonates in Part IVA. Article 51A lays down the duty to “promote harmony and the spirit of common brotherhood”, hence echoing the Ambedkarite idea of fraternity.
In ‘What Congress and Gandhi Have Done to the Untouchables’, Ambedkar points to how Brahminical control over knowledge and its production has led to a society of “ignorance and poverty”.[36] This firm conviction in the importance of education in building human dignity is an essential aspect of the anti-caste agenda of Ambedkar’s democracy. Hence, it is also necessary to include a duty to educate in order to realise a true reimagining of Fundamental Duties. Here, the duty against untouchability further extends to the other deprivations and degradations that oppressed castes face in Hindu society.
For Ambedkar, the duty against untouchability is a necessary precondition to realise fraternity. Arguing that law cannot perform the task of holding together ‘touchables’ and ‘untouchables’, Ambedkar aspires to create a just society in which “the possibility of love” can be realised only through the absolute annihilation of the caste order and the eradication of untouchability.[37] Ambedkar imagines that all individuals must practice companionship, societal unity, and fraternity. This is reflected in ‘Castes in India’, in which Ambedkar illustrates that caste entails “the superposition of endogamy on exogamy”.[38] The use of the word “superposition” shows the violent and imposed manner in which caste relations are foisted onto human society in which individuals otherwise tend towards free and open collaboration. It is in this regard that Ambedkar suggests that there is no caste in the singular, but only “castes” that fragment social unity and undermine free relations. Ambedkar assumes an important line of questioning in ‘Annihilation of Caste’, in which he describes that an ideal society should be characterised by “full and free interplay” with extensive association between the social groups.[39] Any Ambedkarite conception of Constitutional duties must, hence, emphasise the importance of fraternity and social endosmosis.[40]
D. Duty and the Politics of Movements
One of the important aspects of an Ambedkarite reconstruction of duty includes his conception of cadre and the duty of the social justice movement. Ambedkar’s understanding of rights is fundamentally critical of an individualistic ideal of democracy. But he does argue that an individual is “an end in himself”,[41] alongside the collective that he sees as playing an important part in politics. The duty of the movement therefore exists in Ambedkar’s idea of duties. Thus, the successes of Constitutional law are not only attributable to Ambedkar’s foresight and drafting, but also to the ownership of the Constitution exercised by anti-caste struggles in implementing and imagining the Constitutional project.[42]
By highlighting that the powerful would refuse to surrender their power,[43] Ambedkar imposes the duty of realising rights on social justice movements. He also points to how the fragmentation of the social order imposed by caste society needs to be dismantled in order to build a nation and morality. He says that without an anti-caste movement “anything that you will build on the foundations of caste will crack and will never be a whole”.[44] Since caste is organised as a structure of graded inequality, it “authorises an ascending scale of respect or reverence and a descending scale of contempt and hatred”.[45] This in turn implies that within caste society, the personhood of any individual is fragmented and diminished, as it is always defined in a graded manner. Any resistance to the caste order is therefore an assertion of full personhood, a claim to be “whole”.
Underscoring the importance of building organisation and possessing firm political ethic, Ambedkar argues that it is necessary to firstly have a duty to be of “sterling character”[46] and “to see that democracy lives everywhere”.[47] Here it is essential to recognise that Ambedkar embodies a particular radical zeal and revolutionary optimism. In formulating how individuals are duty-bound to organise within radical movements, Ambedkar affirms that it is the larger project of dismantling oppressive structures that should finally guide all duty.
This important interconnection between movements and their duty further points to the Ambedkarite conception that rights are not “given” by the oppressor but are instead struggled for by the oppressed.[48] This interrelation between the rights of individuals and the duties of movements is essential – because it provides a counter to the emerging idea of duties (as within the Hindu Rashtra) and enables resistance against the continuous dispossession of oppressed groups of their rights.
III. Conclusion
The existence of caste as a hierarchical order perpetuates the rift between the Constitution and its promise of reform. The brutality of caste dominance confronts an ill-equipped Constitutional framework that is not “sufficient” by itself to “turn civil society in the direction of social justice”.[49] An Ambedkarite reading could nudge a “moral vocabulary of love, care, and concern”, which Guru suggests is lacking within the current paradigm.[50] In a call for democracy, fraternity, and public spiritedness, an Ambedkarite reading of duty offers the tools to overcome scepticism surrounding the capacity of the Constitution to be a document for social change.
The significance of an Ambedkarite retelling of duty is that it provides the radical tools to strengthen rights and constitutionalism in a progressive sense. It is necessary to note that the tendencies for reform that are ingrained in the Constitution are largely the contributions of Ambedkar. Bhaskar importantly illustrates that it was Ambedkar’s unwavering efforts to ensure universal adult franchise, reservation for oppressed castes in education, services, and legislatures, and the abolition of untouchability as rights within the Constitution.[51] An Ambedkarite reading of Part IVA therefore could imbue a flavour of social revolution and act as a “modernizing force”[52] to an otherwise discarded and neglected portion of the Constitution. This in turn could strengthen our conception of democracy by making it more inclusive and participative.
In conclusion, an Ambedkarite reading offers us a new picture of duty that neither celebrates caste culture nor sanctions an uncritical and aggressive imagination of obedience and nationalism. Instead, his ideas offer an image of democracy premised on justice and anti-discrimination. An Ambedkarite imagination of duty is suffused with an idea of collective participation, an absence of majoritarian tyranny, dismantling of caste oppression, a celebration of fellowship and fraternity, and the cultivation of a democratic enthusiasm in the minds and hearts of citizens.
*Achintya Anita Gurumurthy is a law student who is interested in Ambedkarite and Marxist theory and politics. They are curious about the relationships between people’s movements and the law, and the ways in which caste, class, and gender encounter the law.
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References
[1] B R Ambedkar, ‘Annihilation of Caste’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 1 (Dr Ambedkar Foundation 2014). [2] In the story of Shambuka from the Ramayana, Rama beheads Shambuka, an oppressed caste individual, for attempting to become a hermit, because spiritual asceticism was an occupation solely meant for Brahmins. See Devdutt Pattanaik, Sita: An Illustrated Retelling of Ramayana (Penguin Random House India 2013). [3] Ambedkar, ‘Annihilation of Caste’ (n 1) 77. [4] B R Ambedkar, ‘Philosophy of Hinduism’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 3 (Dr Ambedkar Foundation 2014). [5]Ambedkar, ‘Annihilation of Caste’ (n 1) 53. [6] ibid 68. [7] Aravind Narrain, ‘What Would an Ambedkarite Jurisprudence Look Like?’ (2017) 29(1) National Law School of India Review 1. [8] ‘Cleaning Human Waste’ (Human Rights Watch, 25 August 2014) <https://www.hrw.org/report/2014/08/25/cleaning-human-waste/manual-scavenging-caste-and-discrimination-india> accessed 13 July 2022. [9] Gautam Bhatia, ‘Rights, duties and the Constitution’ The Hindu (26 February 2020) <https://www.thehindu.com/opinion/lead/rights-duties-and-the-constitution/article30915951.ece> accessed 25 January 2022. [10] Anurag Bhaskar, ‘Ambedkar’s Constitution: A Radical Phenomenon in Anti-Caste Discourse?’ (2021) 2(1) CASTE: A Global Journal on Social Exclusion 109. [11] Alan Hunt, ‘Law, State, and Class Struggle’ (Marxism Today 1976) 178-187 <https://legalform.files.wordpress.com/2017/08/hunt-law-state-and-class-struggle-19761.pdf> accessed 27 February 2023. [12] Karl Marx, ‘On the Jewish Question’ (1843) <https://www.marxists.org/archive/marx/works/1844/jewish-question> accessed 13 July 2022. [13] T L Lott, ‘Patriarchy and slavery in Hobbes’s political philosophy’ in Julie Ward and Tommy Lott (eds), Philosophers on Race: Critical essays (Blackwell Publishers 2002). [14] Nivedita Menon, ‘NEP 2020 – elitist and corporatized education under Hindu Rashtra’ (KAFILA, 2019) <https://kafila.online/2020/09/08/nep-2020-elitist-and-corporatized-education-under-hindu-rashtra/> accessed 25 January 2022. [15] B R Ambedkar, ‘States and Minorities’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 1 (Dr Ambedkar Foundation 2014) 381-450. [16] B R Ambedkar, ‘Joint vs Separate Electorates’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 17, part-II (Dr Ambedkar Foundation 2014) 292. [17] B R Ambedkar, ‘Communal Deadlock and the Way to Solve It’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 1 (Dr Ambedkar Foundation 2014) 377. [18] B R Ambedkar, ‘Public Services’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 2 (Dr Ambedkar Foundation 2014) 396. [19] Ambedkar, ‘States and Minorities’ (n 15) 426. [20] B R Ambedkar, ‘Mr Gandhi and the Emancipation of the Untouchables’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 9 (Dr Ambedkar Foundation 2014) 409. [21] B R Ambedkar, ‘India and the Pre-requisites of Communism’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 3 (Dr Ambedkar Foundation 2014) 98. [22] B R Ambedkar, ‘Provincial Executive’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 2 (Dr Ambedkar Foundation 2014) 346. [23] Ambedkar, ‘Communal Deadlock and the Way to Solve it’ (n 17) 377. [24] Disha Wadekar and Sana Irshad, ‘At CEDE we believe representation ought to be a goal in itself’ (The Satyashodak, 1 July 2021) <https://thesatyashodhak.com/at-cede-we-believe-representation-ought-to-be-a-goal-in-itself/> accessed 10 February 2023. [25] Gail Omvedt, ‘Twice-Born’ Riot against Democracy’ (1990) 25(39) Economic and Political Weekly 2195. [26] B R Ambedkar, ‘If Democracy Dies, It Will be Our Doom’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 17, part-III (Dr Ambedkar Foundation 1979) 260. [27] Narrain (n 7). [28] B R Ambedkar, ‘Provincial Executive’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 2 (Dr Ambedkar Foundation 1979) 337-431. [29] B R Ambedkar, ‘Federation versus Freedom’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 1 (Dr Ambedkar Foundation 1979) 340. [30] ibid 209. [31] Sandipto Dasgupta, ‘Language which is Foreign to Us: Continuities and Anxieties in the Making of the Indian Constitution’ (2014) 34(2) Comparative Studies of South Asia, Africa and the Middle East 228. [32] Ambedkar, ‘Provincial Executive’ (n 28) 338. [33] Nakul Nayak, ‘Constitutional Morality: An Indian Framework’ (2021) <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3885432> accessed 27 February 2023. [34] Gautam Bhatia, ‘India’s attorney general is wrong. Constitutional morality is not a ‘dangerous weapon’’ (Scroll, 21 December 2018) <https://scroll.in/article/905858/indias-attorney-general-is-wrong-constitutional-morality-is-not-a-dangerous-weapon> accessed 10 February 2023. [35] Bhaskar (n 10). [36] B R Ambedkar, ‘What Congress and Gandhi have done to the Untouchables’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 9 (Dr Ambedkar Foundation 1979), 469. [37] ibid 140. [38] B R Ambedkar, ‘Castes in India: Their Mechanism, Genesis and Development’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 1 (Dr Ambedkar Foundation 1979) 9. [39] Ambedkar, ‘Annihilation of Caste’ (n 1) 64. [40] ibid 67. Ambedkar writes, An ideal society should be mobile, should be full of channels for conveying a change taking place in one part to other parts. In an ideal society there should be many interests consciously communicated and shared. There should be varied and free points of contact with other modes of association. In other words, there must be social endosmosis. This is fraternity, which is only another name for democracy. [41] Ambedkar, ‘States and Minorities’ (n 15) 409. [42] Bhaskar (n 10). [43] Ambedkar, ‘What Congress and Gandhi have done to the Untouchables’ (n 36) 226. [44] Ambedkar, ‘Annihilation of Caste’ (n 1) 66. [45] V Geetha, ‘A Part Apart: Dr Ambedkar’s Indictment of the Hindu Social Order’ in Kalpana Kannabiran (ed), Violence Studies (Oxford University Press 2016). [46] B R Ambedkar, ‘Be Men of Sterling Character’ in Vasant Moon (comp), Dr. Babasaheb Ambedkar Writings and Speeches, vol 17 III (Dr Ambedkar Foundation 1979) 201. [47] Ambedkar, ‘What Congress and Gandhi have done to the Untouchables’ (n 36) 238. [48] Bhaskar (n 10). [49] Gopal Guru, ‘Constitutional Justice: Positional and Cultural’ in Rajeev Bhargava (ed.), Politics and Ethics of the Indian Constitution (New Delhi: Oxford University Press 2008) 239. [50] ibid. [51] Bhaskar (n 10). [52] Granville Austin, The Indian Constitution: Cornerstone of a Nation (Oxford University Press 1999) 63.