“Doctor” Title Not Exclusive to MBBS: Kerala High Court Backs Use of ‘Dr’ Prefix by Physiotherapists and Occupational Therapists

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What the Kerala HC Has Decided

The Kerala High Court has ruled that physiotherapists and occupational therapists regulated under the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021 are entitled to use the prefix “Dr” with their names, rejecting a demand from sections of the medical fraternity to reserve the title exclusively for allopathic doctors. Delivering judgment on 22 January 2026 in a batch of writ petitions filed by the Indian Medical Association (IMA) Kerala branch and other medical professionals, Justice V.G. Arun held that neither the National Medical Commission (NMC) Act, 2019 nor the Kerala State Medical Practitioners Act confers a statutory monopoly over the title “Doctor” on medical practitioners.

Why the Dispute Reached Court

The litigation stemmed from growing friction between physician groups and physiotherapy and occupational therapy professionals over status, scope of practice and the use of the “Dr” prefix in India’s increasingly complex healthcare ecosystem. In 2025, the NCAHP released a Competency-Based Curriculum for Physiotherapy that described physiotherapists as “first contact” health providers within their domain and allowed the prefix “Dr” with the suffix “PT”, triggering opposition from organizations such as the IMA and the Indian Association of Physical Medicine and Rehabilitation (IAPMR).

Petitioners before the Kerala High Court argued that physiotherapists and occupational therapists are support staff who should work only under the supervision of registered medical practitioners, and that permitting them to present themselves as “Doctor” would mislead patients and blur the line between allied health and modern medicine. They cited the NMC Act and Section 40 of the Kerala State Medical Practitioners Act, which penalizes unauthorized use of degrees or titles implying the right to practice modern medicine, to argue that only those on State or National Medical Registers should be allowed the “Dr” prefix.

Key Findings and Reasoning of the Court

1. “Doctor” is an academic, not an exclusive medical title

Justice Arun traced the origin of the word “Doctor” to the Latin “doctor,” meaning teacher, and noted that historically it denoted a highly learned person, especially in theology, law and philosophy. The court recorded that university-trained physicians adopted the title later, and public association of “Doctor” with healers became more prominent only by the nineteenth century. On this basis, the bench concluded that claiming exclusivity over “Doctor” for medical practitioners is a “misconception,” as individuals with higher academic qualifications such as PhDs have long used the title across disciplines.

Crucially, the court underscored that the NMC Act does not contain any provision granting qualified medical practitioners a statutory right to use “Dr” or conferring that title on them. It held that the word “title” in Section 40 of the Kerala State Medical Practitioners Act cannot be read as a legislative grant of exclusive entitlement to prefix “Dr”; that section targets fraudulent or misleading claims to degrees, diplomas or qualifications, not legitimate academic or professional usage by other regulated health professionals.

2. Allied health professionals’ status under the NCAHP Act

The NCAHP Act defines a “healthcare professional” as a scientist or therapist who provides preventive, curative, rehabilitative, therapeutic or promotional health services and who has completed at least 3,600 hours of study over three to six years. The court noted that physiotherapists and occupational therapists who qualify under this framework are degree-holding professionals with a defined scope of practice, subject to central and state registers and oversight by the National Commission for Allied and Healthcare Professions.

However, the judgment clearly differentiates their role from that of medical practitioners: while allied health professionals can assess, plan and deliver therapeutic and rehabilitative services, they cannot prescribe medicines or provide allopathic treatment. The court emphasized that their services are distinct, though often complementary, and that policy decisions to promote multidisciplinary, team-based, patient-centric care under the NCAHP Act should not be curtailed at the instance of a few dissenting doctors.

3. No basis to “read down” the NCAHP Act

Petitioners had urged the court to “read down” provisions of the NCAHP Act and associated curricula to confine physiotherapists and occupational therapists to supportive roles and strip them of “first-contact” status or the right to use “Dr”. The bench refused, observing that Parliament enacted the NCAHP Act after detailed scrutiny by a Department-related Parliamentary Standing Committee on Health and Family Welfare, which heard stakeholders including the National Medical Commission.

The court also pointed to Section 64 of the NCAHP Act, which gives the statute overriding effect over inconsistent laws, and found no compelling constitutional reason to interfere with legislative policy. It held that prior case law cited by petitioners, including earlier decisions on unauthorized medical practice and title misuse under the old Indian Medical Degrees Act, predated or did not consider the NCAHP framework and therefore did not govern the present situation.

From Interim Restriction to Final Green Signal

In November 2025, the same bench had issued an interim order directing authorities to ensure that physiotherapists and occupational therapists without recognized medical qualifications did not use the prefix “Dr” as mentioned in the new curricula. That interim direction was aligned with a contemporaneous communication from the Directorate General of Health Services (DGHS), which had briefly stated that physiotherapists using the title “Doctor” without a recognized medical qualification could be violating the (now historic) Indian Medical Degrees Act, 1916.

The DGHS withdrew its directive within 24 hours, citing the need for further examination and jurisdictional concerns after objections from the NCAHP authorities. In its final judgment, the High Court took note of the evolved statutory landscape, the role of the NCAHP, and the absence of an exclusive legal claim by medical practitioners over “Dr,” and therefore upheld the right of physiotherapists and occupational therapists to use the prefix as healthcare professionals.

What This Means for Patients and the Public

For patients in Kerala—and potentially, by influence, in other parts of India—the ruling clarifies that the presence of “Dr” before a name does not automatically mean the person is a physician qualified to prescribe medicines or perform surgeries. A physiotherapist or occupational therapist may legitimately use “Dr” while still being limited to non-allopathic, rehabilitative and therapeutic services within their professional scope.

From a practical standpoint, this places greater responsibility on institutions and practitioners to communicate their full professional designation clearly—for example, “Dr X, Physiotherapist (PT)” or “Dr Y, Occupational Therapist (OT)”—and on patients to read and ask about credentials, registration and roles. For everyday health decisions, experts advise that patients should continue to consult registered medical practitioners (MBBS/MD/MS or equivalent) for diagnosis, medication prescriptions and management of acute or complex illnesses, while seeing physiotherapists or occupational therapists for rehabilitation, functional recovery and long-term physical or occupational therapy needs as advised.

Voices From the Profession and Concerns Raised

Medical associations have argued that allowing multiple cadres to use “Dr” risks confusing vulnerable patients, especially in rural and low-literacy settings, and could open the door to misrepresentation or overstepping of practice boundaries. Some medico-legal experts also point out that past ethics and regulatory bodies interpreted earlier law to mean that only practitioners of modern medicine and recognized traditional systems like Ayurveda, Homoeopathy and Unani should use the title in a clinical context.

On the other side, physiotherapy and occupational therapy groups maintain that the title reflects their intensive academic training—often four or more years—and their role as independent professionals in rehabilitation, pain management and disability care, not mere assistants. They note that international practice in many countries recognizes doctoral degrees in physical therapy (DPT) and allows physiotherapists to use “Dr” while requiring clear disclosure of their discipline, a model they argue promotes respect and clarity rather than confusion.

Legal scholars and health-policy experts who are not parties to the litigation stress that the real public health priority is transparent credentialing, strong regulation of scope of practice, and patient education, rather than a narrow contest over a title. As one academic specialist in health law from a national university (not involved in the case) commented in recent commentary, when regulators define and enforce who can diagnose, prescribe and perform invasive procedures, and when providers consistently state their profession alongside any prefix, title disputes lose much of their potential to mislead.

Implications for Health Policy and Future Regulation

The Kerala High Court’s decision sits at the intersection of professional identity, patient safety and the urgent need to expand India’s health workforce. The judgment explicitly acknowledges that the traditional focus on doctors, nurses and frontline workers is no longer sufficient and that allied and healthcare professionals must be integrated into a multidisciplinary, team-based model of care.

Going forward, policymakers may need to:

Strengthen public-facing registers where patients can verify whether a practitioner is a medical doctor, physiotherapist, occupational therapist or other allied professional, and see their qualifications and regulatory status.
Standardize how titles and designations are displayed in clinics, hospitals and digital platforms (for example, requiring the profession to be written immediately after “Dr”).
Update ethical guidelines and advertising norms to prohibit ambiguous or misleading representations of expertise, while respecting the autonomy and professional status of allied health cadres.

For the broader health system, the ruling reinforces that the solution to workforce gaps and rising chronic disease burdens lies in coordinated, clearly regulated teams rather than in siloed hierarchies based on titles alone.

Practical Takeaways for Readers

When you encounter the prefix “Dr” in Kerala after this ruling, consider three quick checks:

Look for the full designation
Is the person identified as MBBS/MD (physician), BPT/MPT/DPT (physiotherapist), BOT/MOT (occupational therapist), or another qualification? This will tell you what kind of care they are trained to provide.
Match the professional to your need
- For diagnosis, prescriptions, surgery or complex medical management, see a registered medical practitioner under the NMC framework.
- For physical rehabilitation after stroke, injury, surgery or chronic musculoskeletal problems, or for support in daily living activities after disability, a licensed physiotherapist or occupational therapist may be appropriate, often in coordination with your doctor.
Do not hesitate to ask
It is reasonable to ask any “Dr” about their degree, registration council and what they are authorized to do, especially before starting long-term treatment or paying for services.

Being informed about titles and roles can help you navigate the health system more safely and confidently.

Medical Disclaimer: This article is for informational purposes only and should not be considered medical advice. Always consult with qualified healthcare professionals before making any health-related decisions or changes to your treatment plan. The information presented here is based on current research and expert opinions, which may evolve as new evidence emerges.