The Bombay High Court has issued a significant reminder, stating that prestigious civilian honours like the Padma Shri and the Bharat Ratna are not titles and must not be used as prefixes or suffixes to an awardee's name. This observation came during a routine hearing, underscoring the binding nature of a decades-old Supreme Court verdict on the matter.
A Judicial Reminder During Proceedings
Justice Somasekhar Sundaresan of the Bombay High Court made this clarification while hearing a petition on December 26, 2025. The court took note of how one of the parties was named in the case title. The writ petition was listed as "Dr. Trimbak V. Dapkekar versus Padmashree Dr. Sharad M Hardikar & Ors." Dr. Hardikar had received the Padma Shri award in 2004 for his contributions to medicine.
Justice Sundaresan pointed out this usage, calling it an "incidental point" but emphasized the court's duty to draw attention to the established law. He directly referenced a landmark judgment by a five-judge Constitution Bench of the Supreme Court in the case of Balaji Raghavan/SP Anand v. Union of India.
The Supreme Court's Landmark Ruling
The apex court's Constitution Bench had conclusively answered whether national awards like the Bharat Ratna, Padma Vibhushan, Padma Bhushan, and Padma Shri qualify as "titles" under Article 18(1) of the Constitution, which abolishes titles.
The Supreme Court had held that these awards do not constitute titles. Crucially, it ruled that they should not be used as suffixes or prefixes. The court further stated that any individual found using them as such would risk forfeiting the award. This forfeiture would follow the procedure detailed in Regulation 10 of the notifications that established these national awards.
Directive for Compliance
The Bombay High Court stressed the imperative for all parties and courts to comply with this declared law. As a result, the court directed the involved parties to ensure their conduct in the proceedings adhered to the Supreme Court's ruling.
Furthermore, the order instructed that courts across the country must also ensure compliance under Article 141 of the Constitution, which mandates that the law declared by the Supreme Court is binding on all courts within India.
The underlying petition itself pertained to a trust matter, challenging an order by the joint charity commissioner in Pune. The issue involved correcting the date of a trustees' meeting from January 20, 2016, to January 21, 2016, in official records. The High Court allowed this amendment, noting the records indicated the later date.
This judicial intervention serves as a powerful reminder that India's highest civilian awards are symbols of recognition and respect, but they are constitutionally distinct from aristocratic or hereditary titles, and their usage is strictly governed by law.
