COURTKUTHEHRY SPECIAL ON PADMA AWARDS USAGE RULES
Bombay High Court Rules: Padma Awards Cannot Be Used in Names
Court reiterates government notifications and Supreme Court directions on civilian honours
Padma Shri, Padma Bhushan, Padma Vibhushan and Bharat Ratna are not “titles” under Article 18
By Our Legal Reporter
New Delhi: December 29, 2025:
In a significant ruling, the Bombay High Court has clarified that Padma Awards cannot be used as prefixes or suffixes to names, reinforcing long-standing government notifications and Supreme Court directions. The Court stressed that civilian honours such as Padma Shri, Padma Bhushan, Padma Vibhushan, and Bharat Ratna are not “titles” under the Constitution and must not be misused as part of an individual’s identity.
The ruling came after the Court noticed that a party in a case was described as “Padmashree Dr. Sharad M. Hardikar,” which violated official guidelines.
Background of the Case
- Incident: A doctor awarded the Padma Shri in 2004 was referred to in case documents as “Padmashree Dr. Sharad M. Hardikar.”
- Court’s objection: The Bombay High Court objected to the use of “Padmashree” as a prefix, citing constitutional and government rules.
- Legal basis: The Court relied on a 1995 Supreme Court Constitution Bench ruling that clarified civilian awards are not “titles” under Article 18 of the Constitution.
- Outcome: The Court directed strict compliance with the law and government notifications, warning against misuse of awards in names.
Padma Rules Based on Government Notifications
The rules governing Padma Awards are based on Ministry of Home Affairs (MHA) notifications and Supreme Court directions:
- No prefixes or suffixes: Padma Awards cannot be used before or after names in any manner.
- Not “titles”: Awards are not considered titles under Article 18 of the Constitution, which prohibits titles except military and academic distinctions.
- Withdrawal clause: Misuse of awards, including using them as titles, can lead to withdrawal of the honour.
- Representation in documents: Awardees must not use Padma Awards in official documents, case titles, or public identity.
- Purpose of awards: Padma Awards are meant to recognize exceptional service, not to confer social or legal status.
Court’s Observations
Justice Somasekhar Sundaresan emphasized:
- Compliance with Article 141: All courts must follow Supreme Court directions strictly.
- Civilian honours vs titles: Awards are recognitions, not titles, and cannot be equated with prefixes like “Dr.” or “Mr.”
- Public misuse: Using awards as titles creates confusion and undermines constitutional principles.
- Legal consequences: Continued misuse can lead to cancellation of awards.
Legal Context
- Article 18, Constitution of India: Prohibits conferment of titles except military and academic distinctions.
- Supreme Court ruling (1995): Clarified that Bharat Ratna and Padma Awards are not titles.
- MHA guidelines: Explicitly prohibit use of awards as prefixes or suffixes.
- Padma Awards scheme: Recognizes distinguished service in various fields but does not grant legal or social privileges.
Case Title and Bench
- Case Title: Bombay High Court suo motu observations in Padma Award misuse case
- Court: Bombay High Court
- Date: December 24, 2025
- Bench: Justice Somasekhar Sundaresan
Impact of the Ruling
The ruling has significant implications:
- For awardees: Reinforces that awards cannot be used as part of names.
- For judiciary: Ensures strict compliance with constitutional and government rules.
- For governance: Strengthens transparency and prevents misuse of national honours.
- For society: Clarifies that awards are recognitions, not titles conferring status.
Expert Opinions
- Legal scholars argue that the ruling protects constitutional principles and prevents elitism.
- Policy analysts note that misuse of awards as titles undermines their purpose.
- Civil society representatives welcome the ruling, saying it ensures equality and fairness.
Comparison with Other Cases
|
Case Title |
Court |
Key Ruling |
|
Bombay HC Padma Award misuse case |
Bombay HC |
Padma Awards cannot be used in names |
|
Supreme Court Constitution Bench (1995) |
Supreme Court |
Civilian awards are not titles under Article 18 |
|
Delhi HC Award Misuse Case (2024) |
Delhi HC |
Misuse of awards can lead to withdrawal |
Broader Implications
The ruling also has implications for:
- Award ceremonies: Reinforces that awards are recognitions, not status symbols.
- Public documents: Prevents misuse of awards in legal and official records.
- Equality principle: Ensures that awards do not create social hierarchies.
- National honours: Strengthens credibility and sanctity of Padma Awards.
Conclusion
The Bombay High Court’s ruling marks a critical clarification in the use of national honours. By holding that Padma Awards cannot be used as prefixes or suffixes to names, the Court has reinforced constitutional principles, government notifications, and Supreme Court directions.
This judgment ensures that Padma Awards remain recognitions of service, not titles of privilege, preserving their dignity and preventing misuse.
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