Physiotherapists And Occupational Therapists Cannot Use ‘Dr’ Prefix Without Medical Qualification: Kerala HC [Read Order]

Kerala: The Kerala High Court has issued an interim direction restraining physiotherapists and occupational therapists from using the prefix ‘Dr.’ in their names without holding recognized medical qualifications, citing conflict with the Indian Medical Degrees Act, 1916.

Justice V.G. Arun, in an order dated November 4, 2025, addressed a writ petition filed by the Indian Association of Physical Medicine and Rehabilitation (IAPMR) against the Union of India and other regulatory authorities.

The petition challenged provisions in the Competency-Based Curriculum for Physiotherapy and Occupational Therapy that appeared to permit these professionals to use the ‘Dr.’ prefix, seeking directions to ensure that physiotherapy and occupational therapy professionals do not represent themselves as primary healthcare providers and refrain from using the prefix without appropriate qualifications.

Addressing the central legal issue, Justice Arun observed, “There is an apparent conflict between the provisions of the Indian Medical Degrees Act, 1916, and the clauses in the Competency-Based Curriculum for Physiotherapy and Occupational Therapy.”

The Court drew attention to a significant administrative action taken by the Ministry of Health and Family Welfare, noting, “The Ministry of Health & Family Welfare had directed to forthwith remove the usage of the prefix ‘Dr.’ for physiotherapists in the Competency-Based Curriculum for Physiotherapy (Approved Syllabus, 2025) on the premise that any physiotherapist using the title ‘Doctor’ without holding a recognized medical qualification would be violating the provisions of the Indian Medical Degrees Act, 1916.”

The Bench acknowledged that while this directive was subsequently withdrawn through a later notification, the underlying legal question remained unresolved, stating, “Although Ext.P4 was later withdrawn as per Ext.P5, I find the petitioner to have made out a prima facie case.”

In its interim order, the Court directed, “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 recognized medical qualification.”

The matter has been listed for further hearing on December 1, 2025.

Case Title: Indian Association of Physical Medicine and Rehabilitation (IAPMR) v. Union of India & Ors.

[Read Order]