The Kerala High Court has issued a crucial directive regarding the professional designation used by physiotherapists and occupational therapists, ruling that they cannot use the prefix “Dr.” unless they hold recognised medical qualifications under applicable law. The Court observed that using the title ‘Dr.’ without statutory authorization would amount to a violation of the Indian Medical Degrees Act, 1916.
This judgment carries profound implications for healthcare practice, professional identity, and public perception, especially in the context of increasing confusion among patients regarding medical credentials.
Background of the Case
The matter came before the Kerala High Court through a writ petition filed by the Indian Association of Physical Medicine and Rehabilitation (IAPMR). The petition highlighted a conflict between:
- The Indian Medical Degrees Act, 1916, which regulates the conferment and usage of medical degrees and titles.
- The Competency-Based Curriculum for Physiotherapy and Occupational Therapy (CBCPT/OT), which allegedly permitted physiotherapists and occupational therapists to use the prefix “Dr.” in certain contexts.
The petitioner argued that physiotherapists and occupational therapists who do not hold medical degrees (such as MBBS or equivalent recognized medical qualifications under the National Medical Commission Act) should not be allowed to prefix their names with “Dr.”, as it misleads patients into believing that they are doctors in the conventional medical sense.
Arguments Presented
Petitioner’s Arguments
- Physiotherapy and occupational therapy are paramedical and rehabilitative fields, not medical doctor qualifications.
- The Indian Medical Degrees Act, 1916 prohibits anyone who does not hold a recognized medical degree from using titles that imply medical doctor status.
- Allowing physiotherapists to use “Dr.” could confuse patients, leading them to believe they are being treated by medical doctors, which could have serious health implications.
Government Position
The Court was informed that the Ministry of Health & Family Welfare had already issued directions to remove the use of “Dr.” from the Competency Based Curriculum for Physiotherapy as part of the Approved Syllabus 2025. The Ministry acknowledged that any physiotherapist using the ‘Dr.’ title without possessing a legally recognized medical degree would be in violation of the law.
Court’s Observations
Justice V.G. Arun noted that:
- There exists a prima facie conflict between the legal prohibition under the Indian Medical Degrees Act and the curriculum that previously allowed physiotherapists to use “Dr.”
- The matter required immediate interim protection to prevent misleading representation in the healthcare system.
The Court held:
“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 and Occupational Therapists without recognised medical qualification.”
The Court further scheduled the case for next hearing on December 1, 2025.
Legal Foundation of the Decision
Indian Medical Degrees Act, 1916
The Act prohibits the use of medical titles such as “Doctor”, “Dr.”, “Surgeon”, etc., by individuals who do not possess degrees recognized by statutory medical councils.
Issue of Public Confusion
The judgment takes into account the protection of public interest, noting that patients often rely on professional titles while seeking healthcare. Misuse of the prefix could:
- Mislead patients into believing they are consulting a medical doctor.
- Disrupt informed decision-making regarding treatment options.
- Create a false sense of professional equivalence between medical doctors and rehabilitative therapists.
Impact of the Ruling
For Physiotherapists and Occupational Therapists
- They may continue their professional practice but cannot use the prefix “Dr.” unless holding degrees such as MBBS, BDS, MD, MS, or other recognized medical qualifications.
- Those holding PhD degrees can still use “Dr.”, but must clarify that their doctorate is academic, not medical (e.g., Dr. (PhD), Physiotherapist).
For Healthcare Ecosystem
- The judgment strengthens transparency in healthcare labeling and credentials.
- Ensures that patients understand who is administering treatment.
- Reinforces legal boundaries among medical and paramedical professions.
For Educational Institutions
- Physiotherapy and occupational therapy colleges must ensure removal of “Dr.” prefixes from academic material, ID cards, and promotional literature unless legally justified.
Why This Decision Matters
This ruling comes at a time when healthcare specializations are expanding, and professional identity claims are becoming more competitive. The Court’s clear direction:
- Prevents misrepresentation of professional expertise.
- Safeguards patient rights to informed medical decisions.
- Promotes clarity and trust in the healthcare system.
It also reaffirms that titles carry legal accountability and cannot be used loosely.
Conclusion
The Kerala High Court’s order marks a critical reaffirmation of legal and ethical boundaries in healthcare. By ensuring that physiotherapists and occupational therapists do not use the “Dr.” prefix without recognized medical degrees, the Court has prioritized patient awareness, legal compliance, and professional clarity.
The case now remains pending for further hearing on December 1, 2025.
