Kerala High Court Upholds Physiotherapists' Right to Use 'Doctor' Title
In a landmark judgment that has significant implications for India's healthcare sector, the Kerala High Court has dismissed petitions seeking to prevent physiotherapists and occupational therapists from using the title "Dr" before their names. The court ruled that medical doctors do not hold an exclusive right to the prestigious prefix, marking a decisive victory for allied healthcare professionals across the country.
Court Overturns Interim Order, Upholds Legislative Framework
The judgment delivered by Justice V G Arun on January 22, 2026, represents a complete reversal from the court's interim order dated November 4, 2025, which had temporarily prohibited physiotherapists and occupational therapists from using the "Dr" prefix without recognized medical qualifications. The court declined to interfere with the central legislation governing these professionals, specifically the National Commission for Allied and Healthcare Professions (NCAHP) Act of 2021.
This legislation explicitly recognizes physiotherapists and occupational therapists as "healthcare professionals" rather than mere support staff. The competency-based curriculum framed under the NCAHP Act permits these professionals to use the prefix "Dr" with the suffix "PT" (Physiotherapy) or "OT" (Occupational Therapy), creating a clear distinction from medical doctors while acknowledging their professional status.
Medical Community's Arguments Rejected
The Indian Medical Association (IMA), along with the Indian Association of Physical Medicine and Rehabilitation (IAPMR) and several individual physicians, had moved the High Court seeking to "nullify or read down" these provisions. Their primary contention centered on the argument that in "common parlance," the prefix "Dr" is exclusively associated with medical practitioners.
"If a Physiotherapist prefixes his name with 'Dr', the general public would naturally assume him to be a qualified allopathic doctor," the petitioners argued. They maintained that allowing therapists to be "first contact" providers effectively permitted them to practice modern medicine, which should be restricted to those with MBBS or MD degrees registered under the National Medical Commission Act of 2019.
Court's Three-Pronged Reasoning
The High Court's judgment rested on three fundamental observations that systematically dismantled the medical community's claims:
- Statutory Analysis: The court examined the National Medical Commission Act and found it does not explicitly grant the title "Dr" to medical practitioners. While petitioners cited Section 40 of the Kerala State Medical Practitioners Act, 2021, which penalizes unauthorized use of titles implying a medical degree, the court held this "cannot therefore be understood as statutorily entitling the qualified medical professionals to prefix 'Dr' to their names."
- Historical Context: The judgment traced the word's origins to the Latin "Doctor," meaning teacher or instructor. The court noted that in the 13th century, the term evolved into an academic title in European universities for those licensed to teach theology, law, and philosophy. "Therefore 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,'" the court held.
- Legislative Intent: The court emphasized that the NCAHP Act represents a deliberate legislative policy decision to move toward "a multi-disciplinary team based care" approach. The legislation was passed by Parliament after extensive consultation with all stakeholders, including the National Medical Commission, which has representation in the National Commission for Allied and Healthcare Professions.
Distinct Professional Roles Acknowledged
Importantly, the court acknowledged the distinct professional boundaries between medical doctors and allied healthcare professionals. The judgment explicitly noted that while physiotherapists "cannot prescribe medicines or provide allopathic treatment," they undergo substantial training—between 3,000 to 6,000 hours—and are statutorily entitled to provide "preventive, curative, rehabilitative, therapeutic or promotional health services."
The NCAHP Act carefully distinguishes between an "allied health professional" (a technician supporting healthcare treatment implementation) and a "healthcare professional" (which includes therapists with advanced training and responsibilities). This distinction formed a crucial part of the court's reasoning in upholding the legislative framework.
Broader Implications for Healthcare Delivery
This judgment represents more than just a semantic victory for physiotherapists and occupational therapists. It signals a formal recognition of their professional standing within India's evolving healthcare ecosystem. The court's refusal to "tinker with the policy of the Government or read down the provisions of the Act or the Curriculum at the instance of a few medical professionals" underscores the judiciary's deference to legislative decisions made after comprehensive stakeholder consultation.
The ruling aligns with global trends toward multidisciplinary healthcare teams and acknowledges the specialized expertise that different healthcare professionals bring to patient care. By allowing physiotherapists to use the "Dr" title with appropriate suffixes, the court has created a system that both honors their professional qualifications and maintains clear distinctions for public understanding.
As India continues to reform its healthcare system to meet growing demands, this judgment establishes important precedents regarding professional recognition, inter-professional relationships, and the evolving nature of healthcare delivery in the 21st century.
