Expanded Recognition of Additional Languages in Municipal Signage: A New Paradigm

1. Introduction

The case VARSHATAI v. THE STATE OF MAHARASHTRA (2025 INSC 486) came before the Supreme Court of India, questioning the permissibility of using Urdu on the signboard of the Municipal Council, Patur, in the State of Maharashtra. The appellant, a former Municipal Council member, objected to using Urdu in addition to Marathi—the latter being the official language in Maharashtra—contending that conducting official business and displaying official signage should be solely in Marathi.

The appellant initially failed in her challenge at the Municipal Council, which insisted on using Urdu given the local needs and historical practice. Several legal remedies were sought by the appellant, eventually leading to the Supreme Court’s final pronouncement. This Judgment not only addresses the specific question of adding Urdu to official signboards but also elaborates on the larger constitutional and legislative framework that governs official languages in India, notably discussing the Maharashtra Local Authorities (Official Languages) Act, 2022.

2. Summary of the Judgment

The Supreme Court reaffirmed that while Marathi is the official language in Maharashtra for municipal affairs under the governing statute and the 2022 Act, the use of an additional language—especially one recognized in the Eighth Schedule to the Constitution of India—does not violate any legal requirement.

The Court highlighted that multiple Indian States permit the usage of multiple languages for various official or public-facing purposes, recognizing linguistic diversity as a hallmark of India’s constitutional identity. The Court dismissed the appeal, confirming that there is no prohibition against installing signboards in an additional language (in this case, Urdu), so long as the primary obligation to use the official language—in signage, official records, and proceedings—is duly fulfilled.

3. Analysis

3.1 Precedents Cited

The Judgment examines several constitutional and statutory provisions. In particular, the Court extensively relied on:

• Article 345 of the Constitution, which empowers States to adopt one or more languages for all or any of its official purposes.
• Uttar Pradesh Hindi Sahitya Sammelan v. State of Uttar Pradesh (2014) 9 SCC 716 – A five-judge Bench decision where recognizing a “second official language” (Urdu in that instance) was validated.
• Provisions from Part XVII of the Constitution, which deal with the official language at the Union and State levels.

These references demonstrate that the Constitution is deliberately “accommodative” of multiple languages, and that the mere adoption of a primary official language does not bar parallel or supplemental usage of other languages in the public domain.

3.2 Legal Reasoning

The Court’s legal reasoning proceeded as follows:

1. Statutory and Constitutional Framework: The Court examined how Section 308 of the Maharashtra Municipal Council Act changed over time, restricting certain challenges to municipal resolutions. It also assessed whether the Maharashtra Local Authorities (Official Languages) Act, 2022 barred the usage of Urdu. The Court found that, while Marathi is mandated for official work, there is no explicit prohibition on displaying additional languages.
2. Interpretation of the 2022 Act: Section 3 of the 2022 Act was central. It designates Marathi as the official language but does not exclude or block the use of other languages. The Court interpreted the phrase “in addition to Marathi” to mean that signboards may indeed contain other languages, as long as Marathi remains prominently used.
3. Linguistic Diversity and Constitutional Intent: Referring to historical debates from the Constituent Assembly and decisions of the Supreme Court on language rights, the Justices underscored that India’s constitutional ethos promotes tolerance and the peaceful coexistence of many languages.
4. No Injury to Public Interest: Since the signboard continued to prioritize Marathi, placing Urdu underneath it did not impede any official function or public interest. Rather, it facilitated broader communication in a region where a significant segment of the population comprehends Urdu.

3.3 Impact

The ruling has significant implications:

• Affirmation of Linguistic Pluralism: Local and State authorities can continue—and perhaps even expand—their practice of using multiple languages for signage and communication, so long as the official language is not replaced or compromised.
• Guidance on Municipal Governance: Municipal Councils and local bodies now have authoritative guidance that accommodating minority or additional languages does not violate statutory or constitutional provisions if the official language remains in primary use.
• Future Litigation: Challenges to multilingual signage in other parts of India will likely be guided by this reasoning. Courts are now better positioned to uphold the use of languages recognized under the Constitution’s Eighth Schedule.

4. Complex Concepts Simplified

This Judgment delves into a number of legal and constitutional terms that may be unfamiliar to laypersons. Some key points clarified:

• Official Language: A language adopted by government entities for official communications, record-keeping, and administration.
• Second Official Language: A language recognized by a governmental unit—from municipal councils up to State legislatures—that can be used for certain official or public-facing tasks alongside the principal official language.
• Eighth Schedule to the Constitution: A schedule listing 22 languages that enjoy special recognition and status, though not necessarily used as official languages in all States.
• Municipal Council Resolution: A formal decision by a local governing body. In this case, the Council had resolved to include Urdu for signboards, a step that the appellant tried to challenge under Section 308 of the Municipal Council Act.

The judgment’s broader lesson is that the Constitution and relevant statutes do not aim to exclude languages but rather ensure that the recognized (or official) language remains in place, while additional languages may also be used for inclusivity or convenience.

5. Conclusion

In VARSHATAI v. THE STATE OF MAHARASHTRA, the Supreme Court of India solidified the principle that designating an official language does not categorically prevent the use of other languages — especially those included in the Eighth Schedule — for signage and communication. The Court championed India’s vast linguistic heritage and reaffirmed the constitutional principle of accommodating diversity, rejecting the notion that one official language must automatically exclude all others in public-facing contexts.

Crucially, this decision carries a strong message of inclusivity. By upholding multilingual signage, the Court has acknowledged that governments and local bodies must meet the needs of the people they serve, including linguistic minorities. This ruling thus stands as an important precedent for any future disputes on the interplay between a designated official language and additional languages in public administration and official signage.

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