Because of the spread of the international human rights law, scholars and courts have puzzled about whether, and how, a treaty obligation is incorporated into the domestic law. The classic debates between monist and dualist theories argue that either the treaty norms become part of the state’s legal order automatically or they need to be translated to be incorporated into the legal order. A dualist system, in which Parliament has to turn treaties into law before they are enforceable, is generally followed in India, given that it has a written constitution, a federal structure and a history of colonial law. However, the Supreme Court applies and applies international conventions to interpret constitutional guarantees, mainly in absence of domestic laws. This paper examines the incorporation of human rights treaties in India in comparison with the constitutional mechanisms in monist, mixed or directive approaches countries like the Netherlands, South Africa, Argentina and Tanzania. It relies on doctrinal analysis of constitutional text (like Article 253 of the Indian Constitution, Article 75(22) of the Argentine Constitution, Section 231-233 of the South African Constitution, Article 93 and 94 of the Dutch Constitution and Article 9 of the Tanzanian Constitution) and some characteristic Supreme Court decisions (e.g., Vishaka, National Legal Services Authority, Makwanyane, Simón and Ephrahim v. Pastory) India has a dualist system and the paper contends that it has been democratically legitimised through its incorporation of treaties in Parliament, but judicial invocation of unincorporated treaties has consecrated the extension of rights, thereby eroding a strict dualism. Comparative analysis indicates that the explicit incorporation in the constitution, as in the case of the Netherlands and Argentina, does not necessarily result in an effective domestic mechanism. One important factor to consider is the independence of the courts and their interpretative powers. The paper ends with suggestions to strengthen India’s treaty implementation in other jurisdictions.