Doctors weigh legal, policy options after Kerala HC allows physiotherapists to use 'Dr' prefix

Their main concern is that while many people can tell the difference between a PhD holder and a medical doctor, some may not be able to distinguish between a qualified medical doctor and allied healthcare professionals using the same title. This confusion, they fear, could compromise patient safety.

Also read- 'Doctor' title not exclusive to medical professionals! Kerala HC allows physiotherapists to use Dr prefix

Medical Dialogues previously reported that the Kerala High Court recently dismissed the pleas filed by the Indian Medical Association (IMA) and the Indian Association of Physical Medicine and Rehabilitation (IAPMR) seeking a ban on Physiotherapists and Occupational Therapy Professionals to proclaim themselves as the first health care provider and use the 'Dr' prefix.

"As rightly contended by the respondents, the NMC Act does not contain any provision for conferring the title Doctor on qualified medical professionals," the bench noted.

Even though in an earlier interim order, the HC bench had clarified that such professionals cannot use the concerned prefix 'Doctor' without a recognised medical qualification, in a recent judgment, the High Court bench comprising Justice VG Arun has observed that the contention that the title 'Doctor' exclusively belongs to medical professionals is a misconception since even now, like in the olden times, persons with higher educational qualifications like PhD are entitled to use the title 'Doctor'.

Further, the Court agreed with the contention by the respondent authorities that the NMC Act does not contain any provision for conferring the title Doctor on qualified medical professionals.

Highlighting that medical treatment is not limited to therapy or rehabilitation but involves diagnosis and detailed clinical evaluation, the former IMA state president A.V. Jayakrishnan told The Hindu, "Medical treatment is prescribed to a patient after diagnosis and detailed clinical evaluation. It is a medically directed job. If allied healthcare professionals such as physiotherapists start independent practice and use the title ‘Dr’, this aspect will be overlooked."

He added, "Conventionally, practising medical doctors have been using it. People may be able to differentiate between someone with a PhD in a particular subject and a medical doctor. But there could be others who may get confused between an actual medical doctor and those who practise in allied healthcare branches."

Dr Jayakrishnan said that the IMA had sought legal opinion on the High Court order, and it would also seek policy changes to address its concerns.

Meanwhile, the Indian Association of Physical Medicine and Rehabilitation (IAPMR) has also expressed concerns over the impact of the judgment. According to the association, the court order might help unscientific practices and quackery

They said that allied healthcare professionals would never get the exposure to clinical practice like medical doctors and wondered who would be held responsible if there were lapses. However, the association said physiotherapists and occupational therapists had a vital role in rehabilitation, adding that ethical interdisciplinary collaboration was the need of the hour.

Background:

The issue arose when, earlier last year, the National Commission for Allied and Healthcare Professions (NCAHP) had recommended the use of 'Dr' prefix for physiotherapists.

In the Competency-Based Curriculum for Physiotherapy 2025, which was released on 23.04.2025, NCAHP suggested the title "Physiotherapist" with the prefix "Dr" and suffix "PT."

On September 9, the Directorate General of Health Services (DGHS), under the Health Ministry, mentioned in a letter addressed to the IMA National President, Dr Dilip Bhanushali, that by using the 'Dr' prefix, physiotherapists will be in legal violation of the Indian Medical Degrees Act, 1916.

DGHS had issued the directive after receiving several representations and strong objections from various organisations, including the IAPMR, regarding the use of the prefix "Dr." and suffix "PT" by Physiotherapists in India.

However, only a day later, the DGHS announced its earlier letter as withdrawn. DGHS changed its decision after receiving representations in this regard requiring further examination.

Pleas before Kerala HC:

Several pleas were filed before the Kerala High Court seeking an order to nullify, rather read down, the wide scope of the connotation "Physiotherapy Professional" as enlisted vide Sl. No. 3 as well as Serial No. 6- Occupational Therapy Professional of the Schedule appended to the National Commission for Allied and Health Care Professions Act, 2021 so as to make and confine the scope of discharge of such professional services of Physiotherapists and Occupational Therapy Professionals only as a supporting group for the qualified Medical Professionals under the provisions of the National Medical Commission Act, 2019 and Indian Medical Degrees Act, 1916.

Further, the petitions prayed for quashing certain provisions in the Competency Based Curriculum for Occupational Therapy, to the extent to which they purported to place Physiotherapists and Occupational Therapy Professionals on a high pedestal as a First Health Care provider and in allowing them to use prefix 'Dr' in their names.

Another prayer was for a writ of mandamus or other appropriate order directing the authorities and their officers to issue necessary orders interdicting Physiotherapists and Occupational Therapy Professionals in proclaiming themselves as the First Health Care provider and in using the prefix 'Dr' in their names and to ensure that their professional services should be confined only as a supporting group for the medical profession.

These pleas were filed by the Kerala State Branch of the Indian Medical Association, the Indian Association of Physical Medicine and Rehabilitation (IAPMR), and several other medical professionals.

Interim Order:

Last year in November, the HC bench, in an interim order, barred Physiotherapists and Occupational Therapists without recognised medical qualifications from using the prefix 'Dr'.

"Hence, there shall be a direction to the competent authorities to ensure that the prefix “Dr.” mentioned in Exts.P1 and P1(a) is not used by Physiotherapists and Occupational Therapists without recognised medical qualification," the Court had ordered.

Judgment by Kerala HC:

However, in its final judgment, the Kerala HC bench has upheld the right of Physiotherapists and Occupational Therapists to use the prefix 'Doctor'.

While deciding the matter, the HC bench endeavoured to understand the circumstances leading to the enactment of the NCAHP Act and the formulation of the Competence-Based Curriculum for Physiotherapists and Occupational Therapists.

It noted that till recently, the health force in the Indian scenario focused mainly on a few cadres such as qualified modern medicine practitioners, nurses, and front-line workers, while the professionals belonging to the healthcare sector were generally termed as para-medical professionals.

Also read- NO 'Dr' prefix for Physiotherapists, occupational therapists, Rules Kerala HC