The proper way to use `t()` with a non-literal is to pass in the string as a replacement like so:

    <?php print t('@title', array('@title' => check_plain($title))); ?>

The function comments on [`t()`][1] contain a very descriptive explanation of why this is necessary so I won't re-hash it here.

[1]: http://api.drupal.org/api/drupal/includes%21bootstrap.inc/function/t/7