Kerala High Court Dismisses Pleas on ‘Dr’ Prefix for Physiotherapists

Court’s Ruling on Medical Title

The Kerala High Court has recently dismissed petitions that sought to prohibit physiotherapists and occupational therapy professionals from using the title “Doctor” and claiming to be primary healthcare providers. The bench noted that the National Medical Commission (NMC) Act does not include any provisions that grant the title “Doctor” to qualified medical professionals.

In a previous interim order, the court had already stated that these professionals could not use the prefix “Dr” without a recognized medical qualification. However, Justice VG Arun emphasized that the notion that the title “Doctor” is exclusive to medical practitioners is a misunderstanding. He pointed out that individuals with advanced degrees, such as a PhD, are also entitled to use this title.

Legal Context of the Court’s Decision

The court supported the argument made by the respondent authorities regarding the NMC Act’s lack of provisions for conferring the “Doctor” title. It stated, “The expression title used in Section 40 of the Kerala State Medical Practitioners Act cannot therefore be understood as statutorily entitling the qualified medical professionals to prefix ‘Dr’ to their names.” Consequently, the court concluded that the petitioners do not possess an exclusive right to use the prefix “Dr.” It also clarified that previous decisions cited by the petitioners were not applicable due to a lack of reference to the National Commission for Allied and Healthcare Professions (NCAHP) Act.

Background of the Issue

The controversy began when the NCAHP recommended that physiotherapists be allowed to use the “Dr” prefix in their title. A report published on April 23, 2025, within the Competency-Based Curriculum for Physiotherapy suggested the title “Physiotherapist” accompanied by the prefix “Dr” and suffix “PT.”

However, on September 9, the Directorate General of Health Services (DGHS) informed the IMA National President, Dr. Dilip Bhanushali, that using the prefix “Dr” could violate the Indian Medical Degrees Act of 1916. This directive came after substantial objections from various organizations, including the Indian Association of Physical Medicine and Rehabilitation (IAPMR). Notably, the DGHS retracted its earlier letter a day later for further examination.

Petitions Filed in Kerala HC

Multiple petitions were presented to the Kerala High Court, aiming to narrow the interpretation of “Physiotherapy Professional” and “Occupational Therapy Professional” under the NCAHP Act. The petitioners sought to limit the scope of these professions to roles supporting qualified medical professionals as defined by the National Medical Commission Act.

They also requested the court to invalidate certain provisions of the Competency-Based Curriculum that elevated physiotherapists and occupational therapists to the status of primary healthcare providers and permitted them to use the “Dr” prefix. The petitions were submitted by the Kerala State Branch of the Indian Medical Association and other medical professionals.

Previous Interim Order

In November of the previous year, the High Court temporarily prohibited physiotherapists and occupational therapists from using the “Dr” prefix without recognized medical qualifications. The court directed relevant authorities to ensure compliance with this order.

Final Judgment by Kerala HC

In its conclusive ruling, the Kerala High Court upheld the rights of physiotherapists and occupational therapists to use the “Doctor” title. The court examined the factors that led to the establishment of the NCAHP Act and the formulation of the Competency-Based Curriculum.

The court noted that historically, the Indian healthcare system had focused on a limited number of professionals, while allied healthcare workers were often categorized as para-medical personnel. It highlighted the need for a patient-centered approach and a multidisciplinary team-based care model.

The court further analyzed the definitions of “allied health professional” and “healthcare professional” under the NCAHP Act, concluding that these professionals are authorized to deliver a range of health services, albeit without the authority to prescribe medication.

Implications of the Court’s Decision

The court clarified that the challenge against the use of the “Dr” prefix by physiotherapists lacked grounding, as the NMC and related statutes do not restrict its use. The bench referenced the historical context of the title “Doctor” and affirmed that it has evolved over time to include various fields beyond medicine.

Ultimately, the High Court dismissed the petitions, reinforcing the legitimacy of physiotherapists and occupational therapists to adopt the “Dr” prefix.

For the full order, click [here](https://medicaldialogues.in/pdf_upload/kerala-hc-physiotherapist-323440.pdf).

Related Reading

Also read: NO ‘Dr’ prefix for Physiotherapists, Occupational Therapists, Rules Kerala HC.