‘Doctor’ Title Not Exclusive to Allopaths: Kerala HC Allows Physios, Occupational Therapists to Use The Title ‘Dr’

Holding that the title “Doctor” is not a statutorily protected prefix reserved exclusively for allopathic practitioners, the Kerala High Court has ruled that physiotherapists and occupational therapists governed by the National Commission for Allied and Healthcare Professions Act, 2021, cannot be restrained from using the prefix “Dr” in the absence of an express legal prohibition.

A single judge bench of Justice V. G. Arun dismissed a batch of writ petitions filed by the Indian Association of Physical Medicine and Rehabilitation, the Indian Medical Association (Kerala State Branch), and several medical practitioners, which had challenged the statutory recognition, professional autonomy, and curriculum framework applicable to physiotherapists and occupational therapists.

The petitioners, all qualified medical professionals trained in modern scientific medicine, had contended that the National Commission for Allied and Healthcare Professions Act, 2021, along with the competency-based curricula framed under it, unlawfully elevated physiotherapists and occupational therapists to the status of “first contact healthcare providers". According to them, such recognition encroached upon the exclusive domain of registered medical practitioners under the National Medical Commission Act, 2019.

A central plank of the challenge was the provision permitting physiotherapists and occupational therapists to use the prefix “Dr". The petitioners argued that, in common parlance, the title “Doctor” is associated with allopathic medical practitioners and that its use by allied healthcare professionals would mislead patients into believing that they were consulting qualified medical doctors.

Rejecting this contention, court observed that the National Medical Commission Act does not confer the title “Doctor” on medical practitioners, nor does it contain any provision reserving the prefix exclusively for those registered under it. Court further held that Section 40 of the Kerala State Medical Practitioners Act, which penalises unauthorised use of medical titles, cannot be interpreted as statutorily entitling medical practitioners alone to use the prefix “Dr".

Court traced the historical origin of the term “Doctor,” noting that it was originally an academic title meaning teacher or learned person and later came to be commonly associated with physicians as medical education formalised. Even today, the court observed, individuals holding higher academic qualifications such as PhDs are entitled to use the title “Doctor,” undermining the claim that the prefix belongs exclusively to the medical profession.

Beyond the issue of nomenclature, the petitioners had sought a declaration that physiotherapists and occupational therapists could function only as supporting professionals under the supervision of registered medical practitioners. They also sought to read down provisions of the NCAHP Act and quash portions of the competency-based curricula that recognised allied healthcare professionals as first-contact providers within their domain.

The respondents, including the Union of India and the National Commission for Allied and Healthcare Professions, opposed the plea, arguing that the NCAHP Act was enacted after extensive parliamentary deliberation and was intended to strengthen a multidisciplinary, patient-centric healthcare system. They pointed out that the Act expressly authorises healthcare professionals to provide preventive, curative, rehabilitative, and therapeutic services, while clearly distinguishing such services from the practice of allopathic medicine.

Court accepted these submissions, holding that there was no compelling reason to interfere with a parliamentary enactment or to read down its provisions at the instance of a section of medical professionals. It noted that allied healthcare professionals undergo extensive statutory training and that their services, though distinct from those of medical practitioners, are integral to modern healthcare delivery.

Significantly, court also relied on the overriding effect clause under Section 64 of the NCAHP Act and took note of the fact that the National Medical Commission was consulted during the legislative process and is represented in the Allied and Healthcare Professions Commission.

Holding that the petitions sought judicial interference in matters of legislative policy, court dismissed all the writ petitions, thereby upholding the statutory framework governing physiotherapists and occupational therapists, including their entitlement to use the prefix “Dr".

Case Title: Indian Medical Association, Kerala State Branch and Others vs. UOI and Others with connected matters

Order Date: January 22, 2026

Bench: Justice VG Arun