The Kerala High Court has directed authorities to restrain physiotherapists and occupational therapists from using the prefix ‘Dr.’ without possessing recognised medical qualifications, observing that such use prima facie violates the Indian Medical Degrees Act, 1916.

The interim order was passed by Justice V.G. Arun while considering a plea filed by the Indian Association of Physical Medicine and Rehabilitation (IAPMR) in the matter Indian Association of Physical Medicine and Rehabilitation v. Union of India & Ors.

The Court noted a prima facie conflict between the Indian Medical Degrees Act, 1916 and the recently introduced Competency-Based Curriculums for Physiotherapy and Occupational Therapy (2025), which permitted the use of the title ‘Dr.’ for these professionals.

Justice Arun remarked that the Ministry of Health and Family Welfare, by an earlier order dated September 9, 2025, had directed removal of the ‘Dr.’ prefix from the approved curriculum, holding that physiotherapists using the title without recognised medical qualifications would be in violation of the 1916 Act. However, that order was subsequently withdrawn the next day.

Despite this withdrawal, the Court held that the petitioner had made out a prima facie case warranting interim restraint. The Bench directed the competent authorities to ensure that the prefix ‘Dr.’ is not used by physiotherapists and occupational therapists unless they hold recognised medical degrees as defined under the Act.

The matter is now listed for further hearing on December 1, 2025.

Bench and Representation

• Bench: Justice V.G. Arun
• Petitioner: Indian Association of Physical Medicine and Rehabilitation (IAPMR)
• Petitioner Counsel: Senior Advocate V.V. Asokan, with Advocates S. Parvathi, T.K. Sreekala, Nikitha Susan Paulson, Uthara Asokan, and K.G. Anil
• Respondents: Union of India, National Commission for Allied and Healthcare Professions (NCAHP), State Allied and Healthcare Council
• For Respondents: Central Government Counsel Mahadev M.J.; Standing Counsel K.S. Prenjith Kumar (for NMC)

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