The Kerala High Court has rejected petitions filed by medical practitioners challenging the use of the prefix “Dr” by physiotherapists and occupational therapists, holding that the title is not reserved exclusively for MBBS-qualified doctors under existing law.
Justice V. G. Arun observed that the National Medical Commission (NMC) Act does not grant statutory rights to medical graduates to use the prefix “Dr.” The court explained that historically, the term “doctor” was used to describe individuals who attained the highest level of learning and were authorised to teach disciplines such as theology, law and philosophy.
Over time, as medical science evolved, university-trained physicians holding medical degrees also came to be known as doctors. However, the court noted that this evolution does not make the title exclusive to the medical profession. Even today, individuals with advanced academic qualifications such as PhDs are entitled to use the title “doctor.”
The court further clarified that neither the NMC Act nor Section 40 of the Kerala State Medical Practitioners Act confers a statutory entitlement on medical professionals to prefix “Dr” to their names. In the absence of such a provision, medical practitioners cannot claim an exclusive right over the title.
Additionally, the High Court declined to read down the provisions of the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021, to limit the professional roles of physiotherapists and occupational therapists to a merely supportive function under NMC-registered doctors.
The court held that it would be inappropriate to interfere with the central government’s policy framework or dilute the provisions of the NCAHP Act and the competency-based curriculum for physiotherapy and occupational therapy at the behest of a section of medical professionals.
