The Kerala High Court has held that doctors cannot claim a monopoly over the title, reinforcing the autonomy of allied healthcare professionals while maintaining functional boundaries.

The Court held that the applicable Indian laws do not confer exclusive entitlement over the “Dr.” title. The Court observed that developments in the healthcare sector warranted a patient-centric, multidisciplinary approach, leading to the enactment of the National Commission for Allied and Healthcare Professions Act, 2021 (“NCAHP Act”) and the Competency-Based Curriculum. It noted that allied healthcare professionals undergo extensive statutory training and are authorised to provide specified services, though they cannot prescribe medicines or provide allopathic treatment.

The above observations came while the Kerala High Court dismissed a batch of writ petitions filed by medical professionals and associations challenging the regulatory framework governing physiotherapists and occupational therapists under the NCAHP Act. The petitions sought restrictions on the use of the prefix “Dr.”, alleging that it was misleading and encroached upon the exclusive domain of qualified medical practitioners.

The respondents, however, submitted that the prefix “Dr” is not statutorily recognised either under the National Medical Commission Act, 2019 (“NMC Act”) (which merely provides for registration of medical practitioners) or Kerala State Medical Practitioners Act. They relied on the NCAHP Act, which authorises healthcare professionals to provide preventive, curative, rehabilitative and therapeutic services, and highlighted that the NCAHP Act establishes a National Commission that includes a representative of the National Medical Commission. As a subsequent enactment, the NCAHP Act was stated to prevail over the NMC Act.