Bombay High Court: Bharat Ratna and Padma Awards Are Not Titles

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 clarified that while these 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.

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Bombay High Court: Bharat Ratna and Padma Awards Are Not Titles

Context of the Judicial Observation

The clarification arose during the hearing of a writ petition involving a 2014 Padma Shri awardee, Dr Sharad Hardikar.
A single-judge bench objected to the case title where the award name was used as a prefix to the respondent’s name. 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 using civilian awards as titles is contrary to settled law. Such honours are recognitions of merit and service, not formal titles that may be appended to a person’s name.
The court stressed that judicial proceedings must strictly adhere to constitutional principles and established legal norms.

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 and must not be used before or after names.

The court also highlighted Article 141 of the Constitution, which makes the law declared by the Supreme Court binding on all courts across India.

Significance for Legal and Administrative Practice

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

Exam-Oriented Key Facts

• Bharat Ratna is India’s highest civilian honour
• Padma Awards are not titles and cannot be used as name prefixes/suffixes
• Article 18 abolishes titles (except military and academic distinctions)
• Article 141 makes Supreme Court law binding on all courts
• Padma Awards categories: Padma Shri, Padma Bhushan, Padma Vibhushan

Question & Answer

Q1. Which High Court reiterated that Bharat Ratna and Padma Awards are not titles?
(a) Delhi High Court
(b) Madras High Court
(c) Bombay High Court
(d) Calcutta High Court
Answer: Bombay High Court

Q2. Which constitutional provision abolishes titles in India, except military and academic distinctions?
(a) Article 14
(b) Article 18
(c) Article 21
(d) Article 32
Answer: Article 18

Q3. Which article makes the law declared by the Supreme Court binding on all courts?
(a) Article 124
(b) Article 136
(c) Article 141
(d) Article 226
Answer: Article 141

Q4. How many categories do the Padma Awards have?
(a) Two
(b) Three
(c) Four
(d) Five
Answer: Three

Q5. The Bharat Ratna is best described as which of the following?
(a) A hereditary title
(b) A legal designation
(c) India’s highest civilian honour
(d) A constitutional office
Answer: India’s highest civilian honour

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