Kerala HC admits doctors' appeals against order allowing 'Dr' prefix for physiotherapists

Earlier, the Court had refused to step into the matter, saying that the decision on using the “Dr.” prefix should be taken by the government, not the Court. However, after hearing submissions that the matter can be argued on merits, the Court has now decided that the issue requires detailed examination.

Challenging that order, the Indian Medical Association (IMA) and the Indian Association of Physical Medicine and Rehabilitation (IAPMR) approached a Division Bench of the High Court. In their appeal, they sought directions that the professional services of physiotherapists and occupational therapy professionals should be confined to a supportive role within the medical profession.

When the matter came up on Monday (February 23), the Division Bench of Justice Sushrut Arvind Dharmadhikari and Justice P.V. Balakrishnan orally remarked that it is not up to the Court to make a decision as to whether medical professionals or physiotherapists can use the prefix 'Dr.' and that the same has to be decided by the government or the legislature.

The matter was adjourned at that stage to enable senior counsel appearing for the appellants to obtain instructions on whether to press the appeals in light of the court’s observations.

On February 2, the counsel informed the Bench that the appellants wished to proceed on the merits, raising all legal and regulatory grounds available to them.

Following this, the Division Bench comprising Justice Sushrut Arvind Dharmadhikari and Justice P.V. Balakrishnan issued notice to the respondents after hearing preliminary submissions and decided that the matter warrants detailed consideration.

The case has been posted for further hearing on March 19.

As per IANS report, the March 19 hearing is expected to see detailed arguments on the scope of professional titles, regulatory authority, and the potential public interest implications arising from the use of the “Dr.” prefix across different streams of healthcare practice.

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:

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 to 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.

Also read- Courts can't legislate, let govt decide on Dr prefix for physiotherapists: Kerala HC