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Misuse of “Doctor” Prefix by Physiotherapists: A Growing Concern in India
The Federation of Resident Doctors’ Association (FORDA) has recently raised a serious concern to the Union Health Minister regarding the widespread and increasing misuse of the “Doctor” prefix by physiotherapists in India.
Legal and Regulatory Position
Lok Sabha Clarification (2018): The Ministry of Health confirmed that the “Doctor” prefix is reserved only for practitioners of recognized systems of medicine (MBBS, BDS, BAMS, BHMS, BUMS, BSMS, BYNS).
Delhi High Court (2014) reaffirmed that only registered medical practitioners can use the title “Doctor” in a clinical context.
Madras High Court (2010) in Tamil Nadu Dr. M.G.R. Medical University vs. S. Vinod Kumar ruled that physiotherapists cannot use the prefix “Dr.,” as it amounts to misrepresentation.
Madras High Court (2010) Case –
Respondent: S. Vinod Kumar, a physiotherapy graduate (Bachelor of Physiotherapy, BPT) from Tamil Nadu Dr. M.G.R. Medical University.After completing his course, he began to use the prefix “Dr.” before his name, presenting himself as “Dr. S. Vinod Kumar.”
The University authorities objected, stating that a BPT graduate is not recognized as a medical practitioner under the Indian Medical Council Act or any other medical law.
The University filed a case, arguing that physiotherapists are allied health professionals and not entitled to use “Dr.” in a clinical setting, as this could mislead patients into believing they were consulting a physician.
Vinod Kumar defended his usage, arguing that since “Doctor” is also an academic title (for example, PhD holders use it), physiotherapists should be allowed to use it.
The University countered that in the healthcare context, the term “Doctor” carries a specific public meaning — it refers to a registered medical practitioner (MBBS, BDS, or AYUSH systems like BAMS, BHMS, etc.).
The Madras High Court ruled against S. Vinod Kumar. It held that physiotherapists cannot use the prefix “Dr.” before their names in a clinical/medical context.
The Court emphasized that such usage amounts to misrepresentation and misleading the public.
Supreme Court (1996) Case-
Dr. Ashwin Patel was a homeopathic practitioner. He treated a patient (husband of Poonam Verma) with allopathic (modern medicine) drugs. The patient developed complications and died.
Supreme Court Ruling: A person qualified in one system of medicine cannot practice another system. Dr. Patel was not qualified in allopathy, so his act amounted to negligence per se (negligence by itself, without needing further proof). Practising without qualification is considered illegal and unsafe for patients.
The Supreme Court of India has repeatedly upheld that only practitioners qualified in a recognized system of medicine can represent themselves as doctors.
Issue in Physiotherapy Curriculum
The National Physiotherapy Curriculum Handbook describes physiotherapists as “healthcare professionals” and, in some sections, even as “primary healthcare professionals.” This is problematic because:
It contradicts International Standard Classification of Occupations (ISCO-08), which lists physiotherapists under “Other health professionals.”
The National Commission for Allied and Healthcare Professions (NCAHP) Act, 2021 and Indian Public Health Standards (IPHS) Guidelines, 2022 categorize physiotherapists as allied and healthcare professionals, not primary health providers.
Such wording may confuse the public into equating physiotherapists with physicians or medical doctors, potentially leading to misrepresentation.
Implications for Healthcare and Patient Safety
- Allowing physiotherapists—or any of the 57 categories of allied healthcare professionals under the NCAHP Act—to use the “Doctor” prefix could:
- Mislead patients regarding the qualifications of the provider.
- Blur the line between medical practitioners and allied health professionals.
- Risk patient safety by creating confusion in healthcare delivery.
- Open the door for other allied health professionals (e.g., optometrists, nutritionists, occupational therapists, medical lab technologists, audiologists) to demand similar recognition.
FORDA’s Appeal
FORDA has urged the Health Ministry to:
- Amend the Physiotherapy Curriculum to remove references that designate physiotherapists as “primary healthcare professionals.”
- Enforce strict compliance with court orders and NMC guidelines through state medical councils and health departments.
- Issue a clear directive to prevent the misuse of the “Doctor” prefix by non-medical professionals.
The Medical Bulletin

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