Bombay High Court Bars Civilian Awards as Name Prefixes

The Bombay High Court has reiterated that India’s highest civilian honours, including the Bharat Ratna and Padma Awards, are not titles and cannot be used as prefixes or suffixes to an individual’s name. The court underlined that while such honours signify national recognition, they do not alter a person’s legal identity and must not be reflected as honorific titles in judicial or official records.

Context of the Judicial Observation

The clarification came during the hearing of a writ petition involving a 2014 Padma Shri awardee, Dr Sharad Hardikar. A single-judge bench objected to the manner in which the respondent was described in the case title, where the award name was used as a prefix. The court directed that the reference be corrected, emphasising accuracy and legal propriety in court documentation.

Legal Position on Civilian Honours

The bench observed that the practice of using civilian awards as titles runs contrary to settled law. It noted that such honours are recognitions of merit and service, not formal titles that can be appended to a person’s name. The court stressed that judicial proceedings must adhere strictly to established legal norms and constitutional principles.

Supreme Court Precedent and Constitutional Mandate

The High Court referred to a 1995 Constitution Bench judgment of the Supreme Court of India, which categorically held that national honours do not confer titles. The judgment clarified that awardees should not use the names of these honours before or after their names. The High Court further pointed out that under Article 141 of the Constitution, the law declared by the Supreme Court is binding on all courts across the country.

Imporatnt Facts for Exams

• Article 18 of the Constitution abolishes titles, except military and academic distinctions.
• Padma Awards are announced annually on the eve of Republic Day.
• The Padma Awards have three categories: Padma Shri, Padma Bhushan, and Padma Vibhushan.
• The Bharat Ratna is India’s highest civilian honour.

Significance for Legal and Administrative Practice

The ruling reinforces the distinction between social honour and legal identity. It serves as a reminder to courts, government bodies, and individuals that civilian awards, despite their prestige, cannot be incorporated into official names. The judgment aims to ensure uniformity, constitutional compliance, and clarity in formal and legal usage, while preserving the symbolic value of national honours.