Kerala High Court Rules ‘Dr’ Title Not Exclusive to Medical Professionals

The Kerala High Court has dismissed petitions filed by medical professionals challenging the use of the prefix ‘Dr’ by physiotherapists and occupational therapists, observing that the National Medical Commission (NMC) Act does not expressly confer the title on MBBS graduates.

Justice V G Arun noted that the term ‘doctor’ was originally used to describe individuals who had attained the highest level of learning and were licensed to teach in disciplines such as theology, law and philosophy. Over time, with the evolution of medical science, university-trained physicians holding medical degrees also came to be referred to as doctors.

The court clarified that the belief that the title ‘doctor’ exclusively belongs to medical practitioners is a misconception, pointing out that even today, individuals with higher academic qualifications such as PhDs are entitled to use the title. It further observed that the NMC Act does not contain any provision that statutorily grants the title ‘doctor’ to qualified medical professionals.

The High Court also held that the expression “title” used in Section 40 of the Kerala State Medical Practitioners Act cannot be interpreted as conferring a statutory right on medical professionals to prefix ‘Dr’ to their names.

Additionally, the court refused to read down the provisions of the National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021, to restrict the professional scope of physiotherapists and occupational therapists to merely a supporting role for medical professionals registered under the NMC Act. It said it would be inappropriate to interfere with central government policy or dilute the provisions of the NCAHP Act or the competency-based curriculum for physiotherapy and occupational therapy at the instance of a few medical professionals.

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