If they weren't in the kernel, they'd need to be in some userspace library (ew).
They work better in user space -- there's more flexibility there and the basic concept of a directory has nothing to do with resource allocation between users, which is what the kernel is for. Many OSes do them outside the kernel. The only reason they have to be in the kernel in Unix is that the kernel deletes files implicitly based on directory references. And as I've been saying, we'd be better off without that.
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