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Kerala High Court Bars Physiotherapists, Occupational Therapists from Using ‘Dr’ Prefix

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The Kerala High Court has ruled that physiotherapists and occupational therapists cannot use the prefix “Dr.” unless they possess a recognized medical qualification.

Delivering the order, a bench led by Justice V.G. Arun directed the concerned authorities to ensure that the prefix “Dr.”, as mentioned in certain official documents (Exts. P1 and P1(A)), is not used by such professionals without proper medical credentials.

The court was hearing a petition filed by the Indian Association of Physical Medicine and Rehabilitation (IAPMR), which sought to prohibit physiotherapists and occupational therapists from identifying themselves as primary healthcare providers or using the title “Doctor.” The association argued that their professional role is limited to offering support under the supervision of qualified medical practitioners.

The issue gained prominence earlier this year after the National Commission for Allied and Healthcare Professions (NCAHP) recommended allowing physiotherapists to use the “Dr.” prefix. Following this, the Directorate General of Health Services (DGHS), under the Union Health Ministry, issued a clarification on September 9, 2025, stating that such usage would contravene the Indian Medical Degrees Act, 1916.

However, the DGHS withdrew its letter a day later, citing the need for further review after receiving representations from various quarters.

During the hearing, the IAPMR’s counsel pointed out the contradiction between the Indian Medical Degrees Act and provisions in the Competency-Based Curriculum for Physiotherapy and Occupational Therapy. The court also took note of a recent directive from the Health Ministry, which had ordered the removal of the “Dr.” prefix from the Competency-Based Curriculum for Physiotherapy – Approved Syllabus, 2025, deeming its use unlawful for those without recognized medical qualifications.

Although this directive was later withdrawn, the court observed that the petitioner had presented a prima facie case.

Consequently, the bench instructed the competent authorities to ensure that physiotherapists and occupational therapists refrain from using the “Dr.” prefix unless they hold an officially recognized medical degree. The matter has been scheduled for further hearing on December 1, 2025.

The IAPMR had earlier contended before the DGHS that allowing physiotherapists to use the “Dr.” title could mislead patients and the public, potentially encouraging quackery. The association also stressed that physiotherapists are not trained to diagnose medical conditions and should treat only referred patients.

It further cited previous judicial rulings, including a Patna High Court order, which held that physiotherapists not registered under a State Medical Register cannot practice modern medicine or use the “Dr.” prefix.

The Kerala High Court’s directive now reinforces this position, bringing clarity to a long-debated issue within India’s healthcare community.

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