Bombay High Court Clarifies Padma Awards and Bharat Ratna Are Not Titles, Bars Use as Name Prefix or Suffix

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Bombay High Court Clarifies Padma Awards and Bharat Ratna Are Not Titles, Bars Use as Name Prefix or Suffix

The Bombay High Court has reiterated that India’s highest civilian honours — including the Padma Shri, Padma Bhushan, Padma Vibhushan and the Bharat Ratna — are not official titles and cannot be used as prefixes or suffixes to a person’s name. The court termed such usage legally impermissible and directed strict adherence to the settled legal position.

The observation was made on Wednesday by Justice Somasekhar Sundaresan while hearing a petition in which Padma Shri awardee Dr. Sharad Moreshwar Hardiker was a party. The court took exception to the manner in which the petitioner’s name had been mentioned as “Padma Shri Dr. Sharad Moreshwar Hardiker” in the case records.

Justice Sundaresan objected to the usage, stating that civilian awards cannot be treated as honorific titles. He noted that such practice runs contrary to established law and must not be followed in judicial proceedings. The court directed that the award prefix be removed from the name in the petition.

Referring to a landmark 1995 judgment of the Constitution Bench of the Supreme Court, the High Court emphasised that the legal position on the issue is settled and binding. In that verdict, the apex court had categorically held that national honours such as the Padma Awards and the Bharat Ratna do not confer any title and should not be used before or after an individual’s name.

Justice Sundaresan pointed out that under Article 141 of the Constitution, the law declared by the Supreme Court is binding on all courts across the country. “The directions of the Supreme Court are clear and must be followed strictly,” the judge said, adding that courts and litigants are expected to ensure compliance in all future filings.

The High Court’s clarification comes amid frequent public and official use of award names as honorifics, particularly in formal documents, invitations and media references. Legal experts note that while such usage is common in social practice, it has no legal sanction and cannot be recognised by courts.

Padma Awards are among India’s most prestigious civilian honours and are announced annually on the eve of Republic Day. They are conferred in three categories — Padma Shri, Padma Bhushan and Padma Vibhushan — to recognise distinguished service in fields ranging from arts, literature and education to medicine, science, sports, social work and public affairs. The Bharat Ratna stands above the Padma Awards as the country’s highest civilian honour.

The court’s ruling serves as a reminder that these honours signify national recognition but do not alter an individual’s legal identity. By restating the constitutional position, the Bombay High Court has underscored the need for precision and restraint in the formal use of civilian awards, particularly in judicial and official contexts.

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