Kerala High Court restrains physiotherapists, occupational therapists from using 'Dr.' prefix

The Kerala High Court recently passed an interim order directing competent authorities to restrain physiotherapists and occupational therapists from using the prefix 'Dr.' without recognised medical qualifications [Indian Association of Physical Medicine and Rehabilitation v Union of India & ors]

Justice VG Arun observed that there appeared a prima facie conflict between the the Indian Medical Degrees Act, 1916 and the provisions in the Competency-Based Curriculums for Physiotherapy and Occupational Therapy (2025) which allowed physiotherapists and occupational therapists to use the prefix 'Dr'.

"Interesting also to note that by Ext.P4 order, the Ministry of Health & Family Welfare had directed to forthwith remove the usage of the prefix “Dr.” for Physiotherapists in the Competency Based Curriculum for Physiotherapy – Approved Syllabus, 2025 on the premise that any Physiotherapist using the title 'Doctor' without holding a recognised medical qualification would be violating the provisions of the Indian Medical Degrees Act, 1916. Although Ext.P4 was later withdrawn as per Ext.P5, I find the petitioner to have made out a prima facie case," the Court said.

The plea was filed by the Indian Association of Physical Medicine and Rehabilitation (IAPMR) alleging unauthorised use of the prefix 'Dr.' by physiotherapists and occupational therapists.

They sought directions against the National Commission for Allied and Healthcare Professions (NCAHP) and the State Allied and Healthcare Council to restrain these professionals from proclaiming themselves as first healthcare providers and using the prefix 'Dr.' in their names.

The petitioner submitted that an order of the Ministry of Health and Family Welfare dated September 9, 2025 had directed the removal of the 'Dr.' prefix from the approved syllabus for Physiotherapy on the ground that using the title without recognised medical qualification would amount to a violation of the 1916 Act.

However, that order was later withdrawn the following day, it was pointed out.

Based on the submissions and facts of the case, the Court held that the petitioner had made out a prima facie case and ordered the competent authorities to restrain the use of the prefix 'Dr.' by such professionals.

"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 andOccupational Therapists without recognised medical qualification," the Court said in its interim order.

The case will be heard next on December 1.

Senior counsel VV Asokan along with advocates S Parvathi, TK Sreekala, Nikitha Susan Paulson, Uthara Asokan and KG Anil appeared for the petitioner.

Central government counsel Mahadev MJ represented the Union.

Standing counsel KS Prenjith Kumar appeared for the National Medical Commission.

[Read Order]