Bombay HC Holds Padma Awards Cannot Be Used as Prefix or Suffix to Awardees’ Names [Read Order]

Mumbai: The Bombay High Court has ruled that recipients of India’s highest civilian honours, including the Padma Shri, Padma Bhushan, Padma Vibhushan and Bharat Ratna, cannot use the name of the award as a prefix or suffix to their personal names. The ruling was delivered by a single-judge Bench of Justice Somasekhar Sundaresan while adjudicating a petition involving a Padma Shri awardee who had styled himself with the award title in official and public contexts.

The Court observed that the use of civilian awards as part of a person’s name is impermissible under the constitutional framework and the statutes governing national honours. The Bench noted that Padma awards do not constitute “titles” of nobility or honour in the sense contemplated by the Constitution and are conferred purely as civilian honours recognising distinguished service in various fields such as art, literature, science, and public service. It was emphasised that these awards cannot be appropriated as nominal extensions of an individual’s identity in either formal or informal usage.

Quoting from the judgment, the Court observed:
“The honours conferred upon a citizen under the Padma Awards scheme are not intended to be used as titles or forms of address in a manner that becomes part of the awardee’s name. Such usage dilutes the constitutional ethos of Article 18(1), which abolishes titles and prevents any conferment of titles by the State.”
The Bench held that continued use of the award’s name as a prefix or suffix could lead to confusion regarding the nature of the honour and blur its distinction from formal titles, which are proscribed under the Constitution.

The Court examined existing constitutional and statutory provisions, including Article 18(1) of the Constitution, which abolishes titles and states that “no title, not being a military or academic distinction, shall be conferred by the State.” While Padma awards are civilian honours and not titles in the strict sense, the Court reasoned that including the award designation as part of one’s name could create an impression akin to a title, contrary to the constitutional principle underlying the prohibition of titles. It further noted that recipients are expressly informed by the Government at the time of conferment that the awards are not to be used as pre-nominal or post-nominal identifiers.

The ruling reiterates the longstanding position that, while civilian awards recognise exceptional service and achievement, they do not confer any titular style or result in legal or social elevation distinct from the recipient’s actual name and identity.

Case Details:
Dr Sharad Hardikar v. Union of India & Ors.
Court: High Court of Judicature at Bombay
Bench: Justice Somasekhar Sundaresan
Advocates Appearing:
For the petitioner: Senior counsel for Dr Sharad Hardikar and assisting advocates, as per court record.

[Read Order]