Balaji Raghavan Vs. Union of India, 1995

• Balaji Raghavan, the petitioner, in the High Court of Kerala, filed a petition under Article 226 of the Constitution sought by way of a writ of mandamus with an aim to prevent the respondent from conferring any of the National Awards. Between September 30, 1992, and April 7, 1994, the contesting parties of the case filed written submissions and counters. Although, the Kerala High Court did not hear any oral arguments or pass any interim order.
• The respondent sought to transfer this case to the Supreme Court of India. On October 29, 1993, a Division Bench of the Supreme Court of India directed the matter to be posted before a bench presided over by the Chief Justice of India.
• National Awards and Honours had been instituted even before the Constitution had been formally drafted. The National Awards were formally instituted in January 1954 by a number of Presidential Notifications.
• A press note issued by the Government of India on April 17, 1978, made clear that the practice of using Civilian Awards such as Padma Vibhushan, Padma Shri etc. as titles on letterheads, invitation cards, books, posters etc. is against the scheme of the Government as the awards are not titles and their use along with the names of individuals is contrary to the spirit of the constitution which has abolished titles. The press note also emphasised that civilian awards should not be attached as suffixes or prefixes to the names of the awardees.
• On August 8, 1977, the institution of the National Awards was cancelled. But, later, on January 25, 1980, the Government of India revived these awards which were cancelled earlier. From then on, National Awards have been conferred annually on Republic Day.
• Article 18 of the Constitution of India refers to the Abolition of Titles and Article 18(1) reads – “No title, not being a military or academic distinction, shall be conferred by the State.”

"Whether the Awards, Bharat Ratna, Padma Vibhushan, Padma Bhushan and Padma Shri (hereinafter called "The National Awards") are "Titles" within the meaning of Article 18(1) of the Constitution of India?"

In this case, Article 18 abolishes all titles. Military and academic distinctions are however exempted from the prohibition. Balaji Raghavan v. Union of India is a landmark judgement in which the Supreme Court of India upheld the validity of civilian honours. Bharat Ratna, Padma Vibhushan, Padma Shri etc. denote State recognition of good work in various fields of activity by the citizens of India. Therefore, National awards are not violative of the equality of status guaranteed by the Constitution of India and come under the scope of Article 18(1) of the Constitution.