While adopting the provision, H V Kamath had moved an amendment underlining the use of Bharat. Indeed, he called for the use of a “much happier expression” that “Bharat, or, in the English language, India, shall, be and such.” However, the amendment was not passed.

Apart from Article 1, the Constitution, originally drafted in English does not refer to “Bharat” in any other provision. The Preamble also refers to “We the People of India.”

In 2020, Chief Justice of India S A Bobde dismissed a PIL seeking a name change. “Bharat and India are both names given in the Constitution. India is already called ‘Bharat’ in the Constitution,” Justice Bobde had said refusing to hear the plea.

In 2015, the BJP-led Centre had told the Supreme Court, in response to a PIL calling for a name change, that there was “no change in circumstances since the Constituent Assembly debated the issue to warrant a review.”

It said that the issues regarding the country’s name were deliberated upon extensively by the Constituent Assembly when the Constitution was drafted and clauses in Article 1 were adopted unanimously. It also pointed out that Bharat did not figure in the original draft of the Constitution and it was during debates that the Constituent Assembly considered names and formulations such as Bharat, Bharatbhumi, Bharatvarsh, India that is Bharat, and Bharat that is India.

The affidavit by the Ministry of Home Affairs was filed after a petitioner made a representation to the Centre.

The SC then dismissed the plea.

In 2004, the Uttar Pradesh Assembly passed a resolution that the Constitution must be amended to say “Bharat, that is India,” instead of “India, that is Bharat.” While then Chief Minister Mulayam Singh Yadav moved the resolution, it was adopted unanimously when the Bharatiya Janata Party, which was in then in the opposition, walked out before the resolution was passed.

The names of villages, towns, railway stations etc are changed under revenue laws of the state since “land” falls in the state list of the Seventh Schedule.

However, the name change requires the approval of the Union Home Ministry after which the state government issues a notification in the official gazette. For renaming states, a change in the Constitution is required.

Articles 2 & 3 of the Constitution which list out the names of the states in the Union can be changed with a simple majority.

In 2011, Orissa was renamed Odisha; in 2007, Uttaranchal was renamed Uttarakhand; in 1973, Mysore was renamed Karnataka and in 1969, Madras state was renamed Tamil Nadu.

However, in Tamil Nadu and Odisha, the High Courts have continued to retain the old names of the state.