Battle over ‘Dr.’ title: modern medicine doctors in Kerala mull legal options

Organisations representing modern medicine doctors are exploring legal and policy options to address their concerns over a recent Kerala High Court order allowing physiotherapists and occupational therapists to use the title ‘Dr.’

In the order issued last month, Justice V.G. Arun dismissed the petitions filed by the Indian Medical Association (IMA) and the Indian Association of Physical Medicine and Rehabilitation (IAPMR) challenging its use by the allied healthcare professionals, while observing that the title was not the “exclusive preserve” of medical practitioners.

A.V. Jayakrishnan, IMA former State president, told The Hindu on Tuesday that modern medicine doctors were concerned about the implications of the order in terms of patients’ safety. “Medical treatment is prescribed to a patient after diagnosis and detailed clinical evaluation. It is a medically directed job. If allied healthcare professionals such as physiotherapists start independent practice and use the title ‘Dr’, this aspect will be overlooked,” he said.

Also, at least some people may get confused and misled by those who use the title, Dr. Jayakrishnan said. “Conventionally, practising medical doctors have been using it. People may be able to differentiate between someone with a PhD in a particular subject and a medical doctor. But there could be others who may get confused between an actual medical doctor and those who practise in allied healthcare branches,” he pointed out. Dr. Jayakrishnan said that the IMA had sought legal opinion on the High Court order, and it would also seek policy changes to address its concerns.

The High Court had said that the National Medical Commission (NMC) Act did not contain provisions conferring the ‘Dr.’ title exclusively on medical professionals. The belief that only doctors can use it was a misconception. Earlier, people with high academic qualifications such as PhDs had been using the title ‘Doctor’, the court said.

Meanwhile, IAPMR leaders expressed apprehension that the order might help unscientific practices and quackery. They said that allied healthcare professionals would never get the exposure to clinical practice like medical doctors and wondered who would be held responsible if there were lapses. However, the association said physiotherapists and occupational therapists had a vital role in rehabilitation, adding that “ethical interdisciplinary collaboration” was the need of the hour.

The IMA and the IAPMR had moved the High Court last year, seeking to nullify or read down provisions in the National Commission for Allied Healthcare Professions Act (NCAHP), 2021, which govern physiotherapists and occupational therapists and recognise them as “healthcare professionals”. The competency-based curriculum framed under the Act permits them to use the prefix ‘Dr.’ with the suffix ‘PT’ (physiotherapy) or ‘OT’ (occupational therapy). The respondents – Union government and representatives of allied healthcare professionals- claimed that the NCAHP Act was a step towards multi-disciplinary team based care, and the legislation distinguished between a healthcare professional and an allied health professional.

The petitioners had cited Section 40 of the Kerala State Medical Practitioners Act which penalises the unauthorised use of titles implying medical degrees. They also contended that under the NMC Act, only those registered under the National or State Medical Registers were allowed to practice modern scientific medicine. The court refused to read down the NCAHP Act while pointing out that the legislation was passed by Parliament after hearing all stakeholders, including the NMC. Though the court in an interim order in November 2025 stayed their use of the ‘Dr’ title, in the subsequent order issued on January 22, it dismissed the petitions filed by the IMA, IAPMR, and others.