Balaji Raghavan/S.P.

Anand vs Union Of India on 15 December,

1995
Since their inception in 1948, National Awards such as the Bharat Ratna, Padma Bhushan,
Padma Vibhushan, and Padma Shri have been given to individuals in recognition of their
achievements and contributions in various fields. These prestigious honours serve as a means
of acknowledging their excellence and merits, reflecting the nation's appreciation for the
exceptional accomplishments of its citizens. Through the conferral of these awards, the
government recognizes and celebrates the remarkable talents of individuals who have made
significant and enduring contributions to the advancement and enrichment of society.

In the aforementioned case Balaji Raghavan filed a petition in the High court under article
226 through writ of Mandamus to abstain respondent from conferring any National Awards,
The question came up after the same question was raised in two high courts simultaneously.

The National Awards have been questioned many a times since their inception in 1948. They
are said to be violative of the right to equality and Article 18 wherein titles are prohibited.
The petitioner in the present case also had same contentions. According to Petitioners, word
‘Titles’ have not been clearly defined in the constitution but the inculcation of Article 18 itself
indicated the thought of constitutional makers to do away with any kind of title conferment
on individuals but these national awards violate Article 18. Further contentions were that,
these awards also rank individuals which is violative of Article 14 i.e Right to equality as it
throws distinction among people on the basis of these awards. They contended that the
distinction of military and civil awards in Article 18 did not mean awarding people on
humanitarian or meritorious grounds.

The respondents contended that the constitutional makers clearly distinguished and exempted
national awards by mentioning civil and military awards being exempted from definition of
title. According to them the awards do not inculcate any permanent prefixes or suffixes and
on that ground they can be distinguished from the word ‘Title’. Moreover, similar national
awards have been given in many nations all over the world.

Court purported that these National Awards are not violative of the right to equality or Article
18 and these awards are not included in ‘titles’ under article 18 and these are in conferment of
the national democratic principles.
Article 51A of the Constitution of India delineates the fundamental duties that every citizen
of the nation is expected to uphold. These duties serve as guiding principles for making
responsible citizens. In particular, clause (j) of Article 51A presents and urges every citizen to
"strive towards excellence in all spheres of individual and collective activity, so that the
nation constantly rises to higher levels achievement." This clause highlights the importance
of fostering a culture of excellence and continuous improvement in both personal and
communal actions. These national awards infuse in citizens thought to aspire to greatness and
contribute to the overall progress and advancement of the nation. In light of this
constitutional mandate, it becomes evident that system of national awards in place to
recognize and celebrate individuals is an outstanding and motivating endeavour of
government.