<P> On 4 December 2013, the Election Commission rejected the petition stating that conferring the award on people from non-polling states did not amount to a violation of the code . Other High Courts as well rejected the petitions raised against Rao and Tendulkar . </P> <P> In 1988, then Prime Minister Rajiv Gandhi (1984--89) conferred the Bharat Ratna posthumously on film actor and former Chief Minister of Tamil Nadu, M.G. Ramachandran, in a bid to influence voters prior to the Tamil Nadu assembly elections in 1989 . The decision was criticised for awarding Ramachandran before independence activist B.R. Ambedkar and Vallabhbhai Patel, who were bestowed the honour in 1990 and 1991 respectively . While Ravi Shankar was accused of lobbying for the award, the decision by Indira Gandhi to posthumously honour K. Kamaraj was considered to have been aimed at placating Tamil voters for the Tamil Nadu assembly elections in 1977 . The seventh Prime Minister V.P. Singh was criticised for posthumously honouring B.R. Ambedkar to please Dalits . </P> <P> The posthumous conferments of the award on the recipients who died before the Indian independence in 1947 or the award was instituted in 1954 have been criticised by historians . It was noted that such conferments could lead to more demands to honour people like Maurya Emperor Ashoka, Mughal Emperor Akbar, Maratha Emperor Shivaji, Nobel Laureate Rabindranath Tagore, Hindu spiritualist Swami Vivekananda, and independence activist Bal Gangadhar Tilak . The then Prime Minister P.V. Narasimha Rao (1991--96) was criticised for bestowing the award upon Vallabhbhai Patel in 1991, 41 years after his death in 1950; and upon Subhas Chandra Bose in 1992, who went missing since 18 August 1945 . Similarly in 2015, the incumbent Prime Minister Narendra Modi's decision to award Madan Mohan Malaviya, who died in 1946, met with criticism . Janardan Dwivedi, politician of the Indian National Congress, said that Malaviya, who worked predominantly in Varanasi, was "deliberately chosen" by the Prime Minister Modi, who is the incumbent Member of Parliament from Varanasi . </P> <P> A few of the conferments have been criticised for honouring personalities only after they received global recognition . The award for Mother Teresa was announced in 1980, a year after she was awarded the Nobel Peace Prize . Satyajit Ray received an Academy Honorary Award in 1992 followed by the Bharat Ratna the same year . In 1999, Amartya Sen was awarded the Bharat Ratna, a year after his 1998 Nobel Memorial Prize in Economic Sciences . The award was proposed by President K.R. Narayanan to Prime Minister Atal Bihari Vajpayee who agreed to the proposal . </P>

Who dedicated bharath ratna award to his mother