Introduction:
The Kerala High Court has recently addressed an important and long-debated issue concerning the professional identity of physiotherapists and occupational therapists in India, sparking a significant discussion in the medical and paramedical community. The case, Indian Association Of Physical Medicine And Rehabilitation (IAPMR) v. Union of India and Others, W.P.(C) No. 41064 of 2025, came before the Bench of Justice V.G. Arun. The petitioner, represented by Senior Advocate V.V. Asokan and Advocates S. Parvathi, T.K. Sreekala, Nikitha Susan Paulson, Uthara Asokan, and K.G. Anil, raised a critical grievance regarding the use of the prefix “Dr.” by physiotherapists and occupational therapists who do not possess recognised medical qualifications under the law. The dispute primarily revolved around the conflict between the provisions of the Indian Medical Degrees Act, 1916, which restricts the use of the title “Doctor” to those holding recognised medical qualifications, and the Competency Based Curriculum for Physiotherapy and Occupational Therapy, which allegedly permitted or implied such use.
Arguments:
The petitioners contended that the usage of the “Dr.” prefix by physiotherapists and occupational therapists misleads the public and infringes upon the statutory provisions of the Indian Medical Degrees Act, 1916. They argued that only individuals who possess recognised medical degrees such as MBBS, MD, MS, or equivalent qualifications approved by the National Medical Commission (NMC) can lawfully use the title “Doctor.” They drew the Court’s attention to the clear language of Section 2 of the Indian Medical Degrees Act, which prohibits the conferment or assumption of the title “Doctor” unless the degree is recognised under that Act. The petitioners further stated that the Competency Based Curriculum for Physiotherapy and Occupational Therapy contained clauses that indirectly encouraged physiotherapists to use “Dr.” before their names, creating confusion among patients and the public. According to the petitioners, physiotherapists and occupational therapists, though skilled healthcare professionals, are part of the allied health sciences and do not qualify as doctors of medicine. The petitioners also relied upon directions previously issued by the Ministry of Health & Family Welfare (MoHFW), which clarified that physiotherapists and occupational therapists are not permitted to use the prefix “Dr.” unless they hold a recognised medical qualification. They further emphasized that the usage of “Dr.” without such qualification not only contravenes the Indian Medical Degrees Act but also amounts to misrepresentation, misleading the public into believing that physiotherapists are qualified medical doctors capable of diagnosing and prescribing medicine, which is not the case under existing legal and regulatory frameworks.
On the other hand, the respondents, representing the Union of India and other concerned authorities, submitted that the Competency Based Curriculum had been formulated to align with modern educational standards and international practices. They argued that in several countries, physiotherapists holding a Doctor of Physiotherapy (DPT) degree are legitimately called “Doctors,” and the same academic recognition should extend to Indian practitioners holding advanced qualifications in physiotherapy. The respondents contended that the use of “Dr.” by physiotherapists was academic and honorary in nature, not intended to mislead the public or to imply that they were medical practitioners. They asserted that physiotherapists and occupational therapists play a vital role in healthcare delivery, working collaboratively with medical professionals to rehabilitate patients, and the restriction of the “Dr.” prefix undermines their professional dignity and international parity. The respondents further submitted that the confusion stemmed from the absence of a clear statutory framework distinguishing medical and paramedical qualifications, and that the curriculum in question did not confer medical degrees but merely reflected professional competency standards. They urged the Court to interpret the issue in a manner that preserves the autonomy and identity of physiotherapy as an independent healthcare profession rather than a subordinate branch of medicine.
Judgement:
Justice V.G. Arun, after hearing both sides, carefully examined the conflict between the statutory provisions and the curriculum. The Court noted that the Indian Medical Degrees Act, 1916, is a central legislation that unequivocally restricts the conferment or assumption of medical titles without recognised medical qualifications. The Bench observed that any person who, not possessing a recognised medical degree, assumes the title of “Doctor” in connection with the practice of medicine, contravenes the spirit and intent of the Act. The Court referred to the Ministry of Health & Family Welfare’s explicit direction for the removal of the “Dr.” prefix from the Competency Based Curriculum for Physiotherapy – Approved Syllabus, 2025, as the Ministry itself recognised that physiotherapists using the prefix “Dr.” without medical qualification would be acting contrary to the law. Justice Arun held that since a prima facie case had been made out, the authorities must act to prevent the misuse of the prefix in official or educational documents. The Court stated that until the legal and professional ambiguities surrounding physiotherapy and occupational therapy titles are clarified through proper legislation or regulatory reform, physiotherapists and occupational therapists who do not hold recognised medical qualifications must refrain from using the title “Doctor.”
The Court thus issued an interim direction to the competent authorities to ensure that the prefix “Dr.” mentioned in the Exhibits P1 and P1(a)—which included the Indian Medical Degrees Act and the Competency Based Curriculum—is not used by physiotherapists and occupational therapists unless they possess recognised medical qualifications. The Bench emphasised that this restriction was not intended to demean the professional standing of physiotherapists or occupational therapists but was a necessary safeguard to uphold the integrity of medical titles and to prevent public confusion. The matter has been posted for further hearing on December 1, allowing the respondents to file their detailed responses.
In its observation, the Court noted that professional titles carry legal implications and that allowing their misuse could create misleading impressions about one’s scope of practice and qualification. Justice Arun also observed that while physiotherapy and occupational therapy are indispensable components of the healthcare system, their professional recognition must be distinguished from that of medical practitioners. The Court hinted that the ultimate resolution of the issue may require a coordinated effort between the Ministry of Health, the National Medical Commission, and the National Commission for Allied and Healthcare Professions to establish clear and uniform standards for the usage of professional titles across the healthcare sector.
The Kerala High Court’s ruling comes amid long-standing debates within India’s healthcare education system about the use of the title “Doctor” by non-medical professionals. Several previous instances have seen physiotherapists, dentists, and even PhD holders using the title “Dr.,” leading to public confusion and disputes within professional circles. However, the Court clarified that the title “Doctor” can be lawfully used by those with doctoral degrees (PhD) in an academic context but not by those who claim to be medical practitioners without recognised medical qualifications. The judgment reiterates the importance of regulatory clarity in healthcare education and professional nomenclature, especially when the title in question carries implications for patient trust and public safety.
This order, though interim in nature, has already generated considerable discussion in both the medical and allied health communities. While physiotherapists argue that their years of rigorous study and contribution to patient care justify the use of “Dr.” as a mark of respect and recognition, medical practitioners maintain that the legal definition of “Doctor” under the Indian Medical Degrees Act must prevail to prevent the erosion of professional boundaries. The issue also raises broader questions about the recognition of allied health professionals and the need for a more inclusive yet legally consistent framework governing professional titles. The Kerala High Court’s intervention, therefore, serves as a crucial reminder that the sanctity of statutory provisions must be maintained until Parliament or the relevant regulatory authority brings clarity to such overlapping professional domains.
The case, Indian Association Of Physical Medicine And Rehabilitation (IAPMR) v. Union of India and Ors., thus stands as a landmark in defining the scope of professional identity within India’s healthcare sector. The order ensures that while physiotherapists and occupational therapists continue to serve a critical rehabilitative role, the use of professional titles remains consistent with the law to prevent deception or confusion among patients. The matter will now proceed to further hearings, where the Court may issue a final verdict harmonising statutory interpretation with evolving professional realities.