Article 18 – Abolition of Titles

Article 18 – Abolition of Titles 

Clause (1)

• State shall not confer any title
• Exception:
  • Military distinctions
  • Academic distinctions

Clause (2)

• No citizen of India shall accept any title from a foreign State

Clause (3)

• A non-citizen holding any office of profit or trust under the State shall not accept any title from a foreign State without the consent of the President

Clause (4)

• Any person holding an office of profit or trust under the State shall not accept, without the consent of the President:
  • Any present
  • Any emolument
  • Any office
• From or under any foreign State

Balaji Raghavan v. Union of India (1996) – Case Notes

Issue

• Constitutional validity of national awards (Bharat Ratna, Padma Vibhushan, Padma Bhushan, Padma Shri) under Article 18(1) (Abolition of Titles).

Petitioner’s Argument

• National awards create artificial distinctions.
• Violate Article 18(1) which prohibits conferment of titles (except military and academic).

Supreme Court Ruling

• National awards are NOT “titles” within the meaning of Article 18.
• They are recognitions of merit and excellence, not hereditary or honorific titles.
• Equality does not mean absence of recognition for exceptional service.
• Awards align with Article 51A(j) (duty to strive for excellence).

Restrictions Imposed by the Court

• Award recipients cannot use the awards as prefixes or suffixesto their names.
  • Example: ❌ Bharat Ratna X / X, Padma Shri
• Awards must not be used for personal, professional, or political gain.

Court’s Recommendations

• Constitution of a high-level committee.
• Ensure:
  • Strict and transparent selection criteria
  • Limited number of awards
  • Maintenance of dignity and prestige
  • Prevention of misuse

Significance of the Judgment

• Preserved the constitutional validity of national honours.
• Clearly distinguished:
  • ❌ Prohibited colonial-style titles
  • ✅ Permissible merit-based national awards
• Reinforced the balance between equality and recognition of excellence.

One-line Conclusion 

The Balaji Raghavan case upheld national awards as constitutional recognitions of merit, not titles, while safeguarding Article 18 by prohibiting their misuse as honorific designations.