Justice C.V. Karthikeyan, Justice R. Sakthivel, Madras HC (Madurai Bench)

The Madras High Court has upheld a Tamil Nadu Government Order directing the identification and renaming of residential areas, streets, roads, water bodies and public establishments bearing caste-based or objectionable names.

The Court dismissed a writ petition challenging the measure and vacated the interim stay on its implementation.

The Court was hearing a writ petition alleging that the Government Order was politically motivated, provided an inadequate period for objections and would create confusion by altering established place names.

A Bench of Justice C.V. Karthikeyan and Justice R. Sakthivel observed: “It had been stated that there would be confusion caused by removal of the caste names. There would be confusion only in the minds of those who retain the names of the caste in their minds, but there would not be any confusion in the minds of the persons who remove caste from their minds. They can identify names without the caste and there would not be any difficulty after a period of time, as caste names will disappear into oblivion.”

Senior Advocate G. Karthikeyan appeared for the petitioner. Advocate General Vijay Narayan appeared for the State.

Background

The Tamil Nadu Government issued guidelines to identify residential areas, streets, roads, water bodies, and public establishments bearing caste-based or objectionable names. The identified places were to be renamed either by retaining a neutral part of the existing name or by adopting the names of persons recognised for their service to society and social justice.

The prescribed procedure provided 21 days for members of the public to submit objections after publication of the proposed changes. The objections were to be considered within a further period of 21 days before the District Collector issued a subsequent Gazette notification.

The petitioner alleged that the measure had been introduced for political advantage, that the objection procedure was inadequate and that the Government proposed to substitute the existing names with those of persons favoured by the ruling party. It was also contended that removing familiar caste-based names would create confusion.

The State submitted that the measure sought to promote equality, remove derogatory caste identities and ensure that public spaces reflected inclusiveness and neutrality. It further stated that local bodies across Tamil Nadu had passed resolutions identifying thousands of habitations, streets, roads, water bodies and public institutions for renaming.

Court’s Observations

The Court observed that the examples placed before it demonstrated that caste-based names were being replaced with neutral names or those of poets, social leaders and other respected personalities. The Bench found no basis for the allegation that the exercise was designed solely to promote political figures.

The Court noted that names associated with Thiruvalluvar, Kabilar, Kambar, Avvaiyar and Bharathidasan had been adopted in different places. Other locations had been given neutral names associated with flowers.

The Bench found that some of the existing names were so derogatory that their continued use could not be justified.

The Bench remarked: “In fact, the existing names can never be uttered in open Court. They are so derogatory, and it is only appropriate that they are renamed. This step should have been taken many years ago. The Government should not have waited all these years to introduce these changes.”

The Court further observed that the petitioner’s suggestion that names of eminent literary and religious personalities could be used as alternatives itself accepted the fundamental premise that caste-based names should be removed. The remaining disagreement concerned only the selection of appropriate replacement names.

The Court rejected the challenge to the 21 days prescribed for filing objections. The Bench observed that an administrative process necessarily required a definite time limit and could not remain indefinitely open.

The Bench held: “We do not find any objection in the said Government Order in the implementation. It is contended that just 21 days' notice is given for any objections to be raised. We hold that there cannot be an indefinite number of days, which could be given. It could be 40, it could be 50, but there must be some limit. And in the Government Order, 21 days had been stated.”

The Court also took note of the State’s submission that the procedure required objections and representations to be examined before a subsequent Gazette notification was issued.

The Court observed that the impugned Government Order supplemented an earlier State measure concerning the removal of caste-based names from roads and streets. It held that the process should not be confined to the places already identified.

The Bench called upon the State to identify other places bearing caste-based or derogatory names and issue a further Government Order.

The Bench added: “It is only to supplement the earlier Government Order, a new Government Order has been passed. We would now call upon the Government to pass a fresh Government Order to identify further places and rename them. This is a continuous process and it has to be continued by the Government.”

The Court stated that residents should ideally have sought the change voluntarily. It found no legal basis for interfering with the Government’s decision to remove caste identities from the names of public places.

Conclusion

The Madras High Court dismissed the writ petition and upheld the Tamil Nadu Government Order directing the removal of caste-based and objectionable names from residential areas, streets, roads, water bodies and public establishments.

The Court vacated the interim stay on the implementation of the measure and called upon the State Government to identify additional places requiring renaming and continue the exercise through a fresh Government Order.

The connected applications were disposed of accordingly, with no order as to costs.

Cause Title: S. Paramasivam v. State of Tamil Nadu & Anr. (Neutral Citation: 2026:MHC:4029)

Appearances

Petitioner: Senior Advocate G. Karthikeyan; Advocate M. Karthikeya Venkitachalapathy

Respondents: Advocate General Vijay Narayan; Government Pleader M.P. Senthil

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