Kerala High Court admits appeals over use of the prefix “Dr” by physiotherapists

Overview of the case and immediate developments

The Kerala High Court has admitted appeals filed by medical professionals challenging a Single Bench order that allowed physiotherapists, alongside medical practitioners, to use the prefix “Dr.” A Division Bench heard the appeals after counsel for the appellants indicated they wished to proceed on the merits. The Bench concluded that the question requires detailed examination and issued notices to the respondents. The matter is listed for further hearing on March 19.

The appeal arises from earlier proceedings in which a Single Bench declined to prohibit physiotherapists and occupational therapy professionals from identifying themselves as “first health care providers” or from using the prefix “Dr.” Initially, the Single Bench had observed that decisions about professional titles were matters for the government and legislature rather than the courtroom. On reconsideration, the Division Bench determined the legal and regulatory issues warrant fuller adjudication.

Who has filed the appeals and what they seek

The appeals were filed by the Kerala State Branch of the Indian Medical Association (IMA), the Indian Association of Physical Medicine and Rehabilitation (IAPMR), and several individual medical professionals. They challenge the Single Bench order and seek directions to restrict the professional scope of physiotherapists and occupational therapy professionals to roles supportive of qualified medical practitioners.

Specifically, the petitions ask the High Court to nullify—or read down—the broad definitions of “Physiotherapy Professional” and “Occupational Therapy Professional” as set out in the Schedule to the National Commission for Allied and Health Care Professions Act, 2021. The pleadings further move to quash parts of the Competency Based Curriculum for Occupational Therapy to the extent these provisions purportedly place physiotherapists and occupational therapy professionals on an equivalently primary platform as medical practitioners and permit the use of the prefix “Dr.”

An additional prayer requests a writ of mandamus or similar direction requiring competent authorities to prohibit physiotherapists and occupational therapists from proclaiming themselves as “First Health Care providers” or using the prefix “Dr,” thereby confining their practice to a supporting role within the framework of the National Medical Commission Act, 2019 and the Indian Medical Degrees Act, 1916.

Courtroom timeline and key judicial observations

When the Division Bench comprising Justice Sushrut Arvind Dharmadhikari and Justice P.V. Balakrishnan first took up the matter, it observed orally that regulation of professional titles falls within the province of the legislature or the executive, and suggested the court need not make that policy determination. The hearing was initially adjourned to allow solicitors for the appellants to obtain instructions in light of those remarks.

On February 2, counsel for the appellants informed the Bench that they intended to press the appeals on their merits and pursue all available legal and regulatory grounds. After preliminary submissions, the Division Bench issued notices to the respondents and decided that the subject merits detailed judicial consideration. The case has been scheduled for an extended hearing on March 19 to allow fuller argument.

Regulatory background and prior administrative action

The controversy traces to recommendations made by the National Commission for Allied and Healthcare Professions (NCAHP). In its Competency-Based Curriculum for Physiotherapy 2025, released on April 23, 2025, the NCAHP recommended the professional title “Physiotherapist” accompanied by the prefix “Dr” and the suffix “PT.”

Following representations and objections from several organisations, including the IAPMR, the Directorate General of Health Services (DGHS) in the Health Ministry initially issued a letter to the IMA National President stating that physiotherapists using the prefix “Dr” would be in legal violation of the Indian Medical Degrees Act, 1916. The DGHS subsequently withdrew that letter the very next day and indicated the matter required further examination after receiving additional representations.

medichelpline had reported earlier coverage of the Single Bench dismissal and the ensuing legal challenge that led to the present appeals.

What to expect at the March 19 hearing

The forthcoming hearing is expected to focus on several core legal themes identified by the Division Bench. These include the permissible scope and legal significance of professional titles in healthcare, the extent of regulatory authority under the National Commission for Allied and Healthcare Professions Act and related statutes, and potential public interest considerations arising from multiple healthcare streams adopting the “Dr” prefix.

Counsel for the appellants have indicated they will press all legal and regulatory grounds available to them. The court’s decision to admit the appeals and issue notices signals that the Bench views the legal questions as more than matters of policy comment and that judicial determination may be required to resolve conflicts between professional regulatory instruments and existing medical statutes.

Significance and broader implications

The case presents a clear point of legal and regulatory intersection between allied healthcare governance and statutory protections historically governing medical degrees and titles. How the High Court navigates the boundary between executive or legislative policymaking and judicial review on this subject will be closely watched by professional bodies across health streams.

The outcome may clarify whether regulatory bodies can authorize certain professional titles and prefixes for allied health practitioners, or whether such authorizations must conform to statutory constraints embedded in older laws governing medical degrees and the practice of medicine. The March 19 hearing is likely to provide an authoritative assessment on those issues and set a framework that stakeholders will need to follow going forward.