Allahabad High Court Clarifies: "Hon'ble" is Reserved for Constitutional Functionaries Exercising Sovereign State Powers
Background and Context
A noteworthy constitutional observation has emerged from the High Court of Judicature at Allahabad while adjudicating Criminal Misc. Writ Petition No. 4982 of 2026 in the matter of Harshit Sharma And 2 Others Vs State of U.P. And 2 Others. The Division Bench comprising Justice J.J. Munir and Justice Tarun Saxena took up a fundamental question of constitutional protocol — specifically, who is legitimately entitled to be addressed with the honorific "Hon'ble" in official communications and public discourse.
The matter arose out of a complaint and a corresponding FIR in which the name of Mr. Anurag Thakur, a sitting Member of Parliament and former Union Minister, was allegedly recorded without the appropriate honorific prefix. The Court examined an affidavit of compliance submitted by the Additional Chief Secretary (Home), Government of Uttar Pradesh, which formed the basis for the Court's clarificatory observations on the scope and proper usage of the term "Hon'ble."
Key Observation: The honorific "Hon'ble" is constitutionally and protocolarily reserved for those who exercise sovereign governmental functions — it is not a matter of personal prestige or administrative rank.
The Court's Core Finding
At the heart of this ruling lies a precise constitutional distinction. The Bench articulated its position in unambiguous terms:
"The honorific 'Hon'ble' is to be appended to the names of constitutional functionaries who exercise sovereign functions of any of the three organs of the Government."
Simultaneously, the Court drew a firm boundary by clarifying:
"'Hon'ble' is an honorific which no functionary, howsoever high, who is a civil servant and not the holder of a sovereign constitutional office, is entitled to use."
These two observations together establish a clear constitutional hierarchy in the matter of official forms of address. No matter how elevated a civil servant's rank may be — whether it is a Cabinet Secretary, a Director General, or the Chief Secretary of a State — the honorific "Hon'ble" cannot be attached to their name because their authority derives from statutes and service rules, not directly from the Constitution as a sovereign grant of power.
What Triggered the Issue: Factual Matrix
The Additional Chief Secretary (Home), Government of Uttar Pradesh, filed an affidavit of compliance before the Court. In paragraph no. 9 of the said affidavit, it was averred that a Hindi typed complaint — the basis on which the check FIR was registered — had been submitted by one Khajan Singh, the first informant, and its contents were reproduced verbatim in column 12 of the check FIR.
The affidavit further stated that upon receipt of this Court's order communicated through the Registrar (Compliance), directions were issued to the Senior Superintendent of Police, Mathura, on 02.04.2026, to initiate a preliminary inquiry into the use of the name and honorific for the former Union Minister.
In paragraph no. 10 of the affidavit, Khajan Singh stated that he was unaware of the protocol governing the use of honorifics for Members of Parliament or former Union Ministers. The Court noted that Mr. Anurag Thakur, being an Hon'ble Member of Parliament, is unquestionably entitled to the use of this honorific, and ignorance of protocol cannot serve as a justification for its omission.
Understanding "Sovereign Functions" in Indian Constitutional Law
Meaning and Constitutional Basis
While the Constitution of India does not provide an explicit definition of "sovereign functions," a well-established body of constitutional jurisprudence has consistently interpreted them as those functions that are intrinsic to the governance architecture of the State and are exercised through its constitutionally mandated organs.
The three organs of the State — the Legislature, the Executive, and the Judiciary — each exercise sovereign functions in their respective constitutional domains. Any individual who is a constitutionally recognised part of these organs, and who exercises power by virtue of that constitutional position, qualifies as a sovereign constitutional functionary.