‘Doctor’ Title Not Exclusive to Medical Practitioners: Kerala HC Rules in Favor of Physiotherapists and Occupational Therapists
In a landmark judgment, the Kerala High Court has clarified that the prefix “Dr.” is not the exclusive preserve of medical doctors. The ruling vindicates the right of physiotherapists and occupational therapy professionals to use the title, significantly impacting the way allied healthcare professionals are perceived in India.
📍 Background of the Controversy
The dispute began when several petitions were filed before the Kerala High Court by the Kerala State Branch of the Indian Medical Association (IMA), the Indian Association of Physical Medicine and Rehabilitation (IAPMR), and other medical professionals. These petitions sought to:
Ban physiotherapists and occupational therapists from calling themselves “first health care providers”.
Prevent them from using the “Dr.” prefix unless they possess a recognized medical qualification.
Confine their roles strictly as supporting cadre to medical doctors registered under the National Medical Commission (NMC) Act.
These pleas directly challenged certain provisions of the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021, and the competency-based curricula for physiotherapy and occupational therapy.
⚖️ Interim Order vs. Final Judgment
Last year, the High Court had passed an interim order restricting physiotherapists and occupational therapists without recognized medical degrees from using “Dr.” However, in its final judgment, the bench — led by Justice V.G. Arun — overturned that position.
The Court’s reasoning was multi-layered and rooted in legal interpretation rather than medical hierarchy.
🔍 Key Takeaways from the High Court Decision
🧑🎓 1. Legal Recognition of the Title “Doctor”
The High Court emphatically noted that:
The title “Doctor” does not exclusively belong to medical professionals.
Historically, the term “Doctor” originates from the Latin word for “teacher” or “instructor” and was traditionally used to denote someone who had achieved the highest academic level. Even today, individuals with doctoral-level qualifications — including PhDs — are entitled to use the title.
📜 2. Statutory Interpretation of Health Laws
The Court observed that:
The NMC Act does not contain any provision granting an exclusive right to medical practitioners to use the prefix “Dr.”
Likewise, Section 40 of the Kerala State Medical Practitioners Act does not statutorily entitle only medical professionals to use the title.
In other words, there is no legal bar preventing non-medical healthcare professionals from using “Dr.” if they are academically entitled to it.
🧠 3. The Role of Allied Healthcare Professionals
The NCAHP Act, 2021 was enacted to regulate and standardize education and practice across allied healthcare professions, acknowledging the increasing complexity of modern healthcare delivery.
The High Court recognized that:
Allied healthcare professionals undergo extensive training — spanning 3,600+ hours over 3–6 years.
They are trained to provide preventive, curative, rehabilitative, therapeutic, and promotional health services, though they are not authorized to prescribe medications or provide allopathic treatment.
This establishes that their scope of practice is distinct from, yet complementary to, medical practitioners.
📊 4. Policy Considerations
The Court also highlighted that:
The NCAHP Act was developed through extensive parliamentary deliberation, including inputs from the National Medical Commission itself.
Given this comprehensive legislative process, it is not the role of the judiciary to “tinker” with policy or narrow the scope of the Act at the behest of a few petitioners.
📌 Implications of the Judgment
This ruling carries major implications for healthcare professionals and patients alike:
Physiotherapists and occupational therapists can use the title “Dr.” if they hold the academic qualification to justify it.
These professionals are legally recognized as healthcare providers in their own right, not merely as adjuncts to medical doctors.
The decision reinforces a multi-disciplinary and patient-centric approach to healthcare delivery in India.
📚 In Summary
The Kerala High Court’s judgment is a progressive affirmation of the evolving healthcare landscape in India. It underscores that:
✅ The title “Doctor” is not legally exclusive to medical doctors.
✅ Allied healthcare professionals, such as physiotherapists and occupational therapists, have the right to use the title when academically qualified.
✅ The judiciary will not narrow statutory provisions that govern healthcare professions unless compelling reasons exist.
