Kerala High Court: A Singh Judge Bench of V.G. Arun, J., barred physiotherapists and occupational therapists, who do not possess a formal medical qualification, from using ‘Dr.’ as a prefix to their names. In the present writ petition, the Indian Association of Physical Medicine and Rehabilitation (‘IAPMR’), prayed for an interim order directing National Commission for Allied and Healthcare Professions (‘NCAHP’) and State Allied and Health Care Council (‘SAHCC’) to ensure that Physiotherapists and Occupational Therapy Professionals do not use the prefix ‘Dr’ in their names. The Court, while admitting the petition, found that IAPMR had made out a prima facie case, and directed the competent authorities to ensure that the prefix ‘Dr.’ mentioned is not used by Physiotherapists and Occupational Therapists without required medical qualification.
IAPMR filed the present writ petition praying for an interim order directing NCAHP, SAHCC and their officers to ensure that Physiotherapists and Occupational Therapy Professionals should not proclaim themselves as first health care provider and should not use the prefix ‘Dr’ in their names, and that their professional services should be confined only as a supporting group for and under the qualified medical professionals. The Senior Counsel for National Medical Commission pointed out the apparent conflict between the Indian Medical Degrees Act, 1916 (‘Act of 1916’) and the clauses in the Competency Based Curriculum.
The Court noted that the Ministry of Health & Family Welfare had ordered the removal of the prefix ‘Dr.’ for Physiotherapists in the Competency Based Curriculum for Physiotherapy, stating that using the title ‘Doctor’ without a recognized medical qualification would violate the Act of 1916, although the order was later withdrawn. The Court concluded that notwithstanding the withdrawal of the abovementioned order, IAPMR had made out a prima facie case.
Accordingly, the Court directed the competent authorities to ensure that the prefix ‘Dr.’ is not used by Physiotherapists and Occupational Therapists without recognised medical qualification and posted the matter for further hearing on 01-12-2025.
[Indian Association of Physical Medicine and Rehabilitation v. Union of India, WP(C) No. 41064 of 2025 (G), decided on 04-11-2025]
Advocates who appeared in this case:
For the Petitioner: V.V. Asokan (SR.), S. Parvathi, T.K. Sreekala, Nikitha Susan Paulson, Uthara Asokan & K.G. Anil, Advocates
For the Respondents: Mahadev M.J., Central Government Counsel, K.S. Prenjith Kumar, Standing Counsel.