Bombay High Court Clarifies Civilian Honours Are Not Legal Titles

High Court Reiterates Constitutional Position

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

Case That Prompted the Observation

The clarification arose during the hearing of a writ petition involving a Padma Shri awardee , Dr Sharad Hardikar , who received the honour in 2014. A single-judge bench objected to the manner in which the respondent was described in the case title, where the award name had been used as a prefix. The court directed that the description be corrected, stressing that legal documents must reflect accuracy and constitutional propriety.

Legal Understanding of Civilian Awards

The High Court noted that the use of civilian awards as titles is inconsistent with established legal principles. Such honours, it observed, are meant to acknowledge exceptional service or achievement but do not confer any formal status that can be attached to a person’s name. Courts, the bench said, must strictly follow constitutional norms when recording names in judicial proceedings.

Supreme Court Ruling and Constitutional Backing

Referring to a 1995 Constitution Bench judgment of the Supreme Court , the High Court recalled that the apex court had categorically ruled that national honours do not amount to titles. Award recipients are therefore prohibited from using these distinctions before or after their names. The bench also cited Article 141 of the Constitution , which makes Supreme Court rulings binding on all courts in India.

Broader Administrative Significance

The judgment reinforces the constitutional separation between honour and title , ensuring uniformity in legal and administrative practice. It serves as a reminder to individuals, courts and government institutions that civilian awards, despite their prestige, must remain symbolic recognitions and not become part of an individual’s official or legal identity.

Important Facts for Exams

• Article 18 of the Constitution abolishes titles, except military and academic

• Bharat Ratna is India’s highest civilian honour

• Padma Awards include Padma Shri, Padma Bhushan and Padma Vibhushan

• Supreme Court judgments are binding under Article 141