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Why Kerala High Court has allowed physiotherapists to use the title ‘Dr’

Medical doctors argued that the prefix 'Dr', in 'common parlance', is associated with a medical practitioner. The court, however, ruled that medical doctors do not hold an exclusive right to the title

The court observed that while physiotherapists “cannot prescribe medicines or provide allopathic treatment”, they are recognised as distinct professionals. Unsplash

Written by: Vineet Bhalla

5 min readNew DelhiJan 28, 2026 02:33 PM IST First published on: Jan 28, 2026 at 01:38 PM IST

The Kerala High Court on Thursday dismissed a petition by the Indian Medical Association (IMA), the Indian Association of Physical Medicine and Rehabilitation (IAPMR) and some physicians seeking to prevent physiotherapists and occupational therapists from using the title “Dr” before their names.

In doing so, it overruled its interim order dated November 4, 2025 that had prohibited physiotherapists and occupational therapists from using the prefix “without recognised medical qualification”.

The judgment by Justice V G Arun held that medical doctors do not hold an exclusive right to the title “Doctor”. The court declined to interfere with the central legislation — the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021 — that governs physiotherapists and occupational therapists and recognises them as “healthcare professionals”.

The NCAHP Act was introduced to regulate and standardise the education and services of allied healthcare professionals. The “competency based curriculum” framed under it permits physiotherapists and occupational therapists to use the prefix “Dr” with the suffix “PT” (Physiotherapy) or “OT” (Occupational Therapy).

The legal arguments

The IMA, along with the IAPMR and individual doctors, moved the High Court last year, seeking to “nullify or read down” these provisions on the basis that these professionals should be confined to a “supporting group” for qualified medical professionals governed by the National Medical Commission Act, 2019 (NMC Act).

The medical doctors contended that under the NMC Act, only those registered in the State or National Medical Registers are entitled to practice modern scientific medicine. They argued that the new curriculum, by allowing therapists to be “first contact” providers, effectively allowed them to practice modern medicine, which is prohibited for anyone without an MBBS or MD degree.

A central point of contention for them was the title “Dr”. They argued that in “common parlance”, the prefix is associated with a medical practitioner. “[I]f a Physiotherapist prefixes his name with ‘Dr’, the general public would naturally assume him to be a qualified allopathic doctor,” they posited.

On the other hand, the respondents — the Union government and representative bodies for allied and healthcare professionals — argued that the NCAHP Act was a legislative policy decision to move towards “a multi-disciplinary team based care”.

They pointed out that the Act distinguishes between an “allied health professional” — a technician supporting the implementation of healthcare treatment — and a “healthcare professional”, which includes therapists. The latter undergoes 3,000 to 6,000 hours of training and is statutorily entitled to provide “preventive, curative, rehabilitative, therapeutic or promotional health services”.

Court’s reasoning

The High Court had, in November, found the petitioners “to have made out a prima facie case” and stayed the use of the title “Dr” by physiotherapists and occupational therapists.

However, in its judgment on January 22, in a volte-face, it dismissed the petitions, relying on three primary observations regarding the law and the history of the title “Doctor”.

The court first examined the NMC Act and found that it does not explicitly grant the title “Dr” to medical practitioners.

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While the petitioners cited Section 40 of the Kerala State Medical Practitioners Act, 2021 which penalises the unauthorised use of titles implying a medical degree, the court held that this “cannot therefore be understood as statutorily entitling the qualified medical professionals to prefix ‘Dr’ to their names”.

“In the absence of such provision, the petitioners cannot claim exclusive right to use the prefix ‘Dr’,” the court concluded.

The court also rejected the argument that the title belongs exclusively to the medical fraternity by tracing the word’s origins.

“[T]he term ‘Doctor’ originated from the latin word ‘Doctor’, which means teacher or instructor,” the judgment noted. It explained 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.

The court’s refusal to “read down” the NCAHP Act was grounded in the reasoning that the legislation was passed by Parliament after hearing all stakeholders, including the National Medical Commission. The National Commission for Allied and Healthcare Professions, it noted, includes a representative of the National Medical Commission.

The court observed that while physiotherapists “cannot prescribe medicines or provide allopathic treatment”, they are recognised as distinct professionals. “It will be inappropriate for this Court 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,” the judgment reasoned.