Consider the following statements under Article 18 of the Indian Constitution: 1. Any Citizen of India can take any title from any foreign state. 2. In Balaji Raghavan v/s Indian Federation, 1996, the Supreme Court has announced that 'Padma-Vibhushan', 'Padma- Bhushan' and 'Padamshree' is a title but these awards violate "right to equality". Which of the following statements given above is/are correct?

• Article 18 of the Indian Constitution falls under Part III, which deals with the Fundamental Rights. Specifically, Article 18 is part of the Right to Equality, which is covered under Articles 14 to 18.

Key Provisions of Article 18 : Abolition of Titles

• Article 18(1): Prohibits the State from conferring any titles except military and academic distinctions.
• This means that the government cannot grant any hereditary titles or titles of nobility (e.g., "Raja," "Maharaja," "Nawab") that could create a privileged class in society.
• Article 18(2): Prohibits any citizen of India from accepting any title from a foreign state.
• Indian citizens cannot accept titles or honors from other countries, ensuring that no Indian citizen holds allegiance to a foreign state. Hence, Statement 1 is incorrect.
• Article 18(3): Provides that any foreigner holding any office of profit or trust under the State cannot accept any title from any foreign state without the consent of the President of India.
• Article 18(4): Prohibits any person holding any office of profit or trust under the State from accepting any present, emolument, or office of any kind from or under any foreign state without the consent of the President.

Important Judgments Related to Article 18

• Balaji Raghavan vs. Union of India (1996): This case dealt with the constitutionality of national awards like the Bharat Ratna, Padma Vibhushan, Padma Bhushan, and Padma Shri. The Supreme Court held that the national awards do not violate Article 18 because they are not titles in the traditional sense. The Court clarified that these awards are given in recognition of exceptional service to the nation and are not hereditary or carry any special privileges or benefits. The Court also emphasized that the awards cannot be used as a prefix or suffix to the recipient’s name, as it would be considered a violation of Article 18(1). Hence, statement 2 is incorrect.
• Madhavrao Scindia vs. Union of India (1971): This case was related to the abolition of the privy purses and titles of former princely states. The Supreme Court upheld the abolition of privy purses and titles, stating that the privileges associated with these titles were incompatible with the principles of equality and democracy enshrined in the Constitution. The Court supported the view that titles granted under the British regime created a privileged class, which Article 18 aimed to abolish.
• P.S. Venkatasubramanian vs. Union of India (1996): The petitioner challenged the conferment of honorary degrees and academic distinctions, claiming it violated Article 18. The Court ruled that honorary degrees are not titles within the meaning of Article 18 and are, therefore, permissible. The judgment clarified that honorary degrees and distinctions related to academics, which do not confer any special status or privileges, are not prohibited by the Constitution.