[Cites 19, Cited by 0]
Kerala High Court
Dr. Sonu Mohan M.S vs Union Of India on 22 January, 2026
Author: V.G.Arun
Bench: V.G.Arun
1
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
THURSDAY, THE 22ND DAY OF JANUARY 2026 / 2ND MAGHA, 1947
WP(C) NO. 43518 OF 2025
PETITIONERS:
1 INDIAN MEDICAL ASSOCIATION
KERALA STATE BRANCH, ANAYARA P.O.,
THIRUVANANTHAPURAM REPRESENTED BY ITS HON.
SECRETARY - DR. ROY R. CHANDRAN, PIN - 695029
2 DR. ROY R. CHANDRAN
AGED 50 YEARS
S/O MR. RAMACHANDRAN N(LATE) HON' SECRETARY,
PROFESSOR IN DEPARTMENT OF PHYSICAL MEDICINE
AND REHABILITATION, GOVERNMENT MEDICAL
COLLEGE, KOZHIKODE RESIDING IN DYU,
MAKKANAMCHERRY THAZHAM, CHEVAYUR P.O,
KOZHIKODE, PIN - 673017
3 DR. JAYAKRISHNAN A.V
AGED 56 YEARS
S/O. VIKRAMAN MENON, DOCTOR, NEURO SURGEON, MS
ORTHO MCH NEUROSURGERY, SENIOR CONSULTANT
NEUROSURGEON, EMS MEMORIAL CO-OPERATIVE
HOSPITAL, PERINTHALMANNA, RESIDING IN
SURYAGAYATHRI, AMBALAPPUZHA, PATTAMBI ROAD,
PERINTHALMANNA, PIN - 679322
2
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4 DR. PRADEEP KUMAR KALATHIL
AGED 54 YEARS
S/O NARAYANAN P.K, CONSULTANT, PMR GENERAL
HOSPITAL, KOZHIKODE RESIDING IN ASWATHY,
VANHERI NAGAR, ILLATHUPARAMBA, THEKKUMMURI
P.O, TIRUR, MALAPPURAM, PIN - 676105
5 DR. SURESH KUMAR M
AGED 59 YEARS
S/O. MADASWAMY ACHARY, ENT SENIOR CONSULTANT,
KIMS HEALTH, THIRUVANANTHAPURAM, RESIDING IN
GANGOTRI, TC 17/2143/3, KPRA A22, KOONAMKULAM
LANE, OPP. GG HOSPITAL, MURINJAPALAM, MEDICAL
COLLEGE P.O, THIRUVANANTHAPURAM, PIN - 695011
6 DR. SREENI EDAKHLON
AGED 54 YEARS
OPHTHALMOLOGIST, DR.SREENI EDAKHLON'S MALHAARI
EYE CARE, OPPOSITE CHANDUMENON SMARAKA
VALIYAMADAVIL GOVT U P SCHOOL,
KEEZHANTHIMUKKU, THIRUVANGAD, THALASSERY,
KANNUR, RESIDING IN MALHAARI, NEAR RUBCO
AUDITORIUM, SOUTH BAZAAR, KANNUR, PIN - 670002
7 DR. C.K. HAREENDRANATH,
AGED 77 YEARS
S/O. K.C. ACHUTHAN, CONSULTANT ORTHO SURGEON,
GREENS EAST HILL, WEST HILL. P.O KOZHIKODE,
PIN - 673005
8 DR. P. RAGHAVAN
AGED 80 YEARS
S/O. P. KUNDAN, ENT CONSULTANT AND RTD. DY.
DIRECTOR OF HEALTH SERVICE, CONSULT ENT
SURGEON, CALICUT HOSPITAL AND NURSING HOME,
PALAYAM, KOZHIKODE RESIDING IN RAJI,
ASOKAPURAM HOUSING COLONY,
KOZHIKODE, PIN - 673001.
3
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9 DR.K.V.RAJU
AGED 69 YEARS
S/O. K.M.VALLON, PROFESSOR AND HOD IN
OPHTHALMOLOGY, MALABAR MEDICAL COLLEGE
HOSPITAL AND RESEARCH CENTRE, ATHOLI,
KOZHIKODE. RESIDING AT AMRUTHARESHMI,
CHEVAYUR.P.O., KOZHIKODE, PIN - 673017
BY ADVS.
SMT.T.K.SREEKALA
SMT.S.PARVATHI
SMT.NIKITHA SUSAN PAULSON
SMT.UTHARA ASOKAN
SRI.V.V.ASOKAN (SR.)
SHRI.K.G.ANIL
RESPONDENTS:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, MINISTRY OF
HEALTH AND FAMILY WELFARE, NIRMAN BHAVAN, NEW
DELHI, PIN - 110001
2 NATIONAL COMMISSION FOR ALLIED AND HEALTHCARE
PROFESSIONS (NCAHP),
2ND FLOOR, ACADEMIC BLOCK, NIHFW CAMPUS, BABA
GANG NATH MARG, MUNIRKA, NEW DELHI,
REPRESENTED BY ITS CHAIRPERSON,
PIN - 110067
3 STATE ALLIED AND HEALTH CARE COUNCIL
NEAR DIRECTORATE OF MEDICAL EDUCATION, MEDICAL
COLLEGE, THIRUVANANTHAPURAM,
THIRUVANANTHAPURAM MEDICAL COLLEGE S.O,
THIRUVANANTHAPURAM,
REPRESENTED BY ITS CHAIRPERSON.,
PIN - 695011
4
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4 NATIONAL MEDICAL COMMISSION
POCKET-14, SECTOR-8, DWARKA PHASE-1, NEW
DELHI, REPRESENTED BY ITS CHAIRPERSON, PIN -
110077
BY ADVS.
SHRI.PRAVEEN K.S., CGC
GOVERNMENT PLEADER
OTHER PRESENT:
SRI. MAHADEV. M.J, FOR R2. SMT. O.M. SHALIN
AFOR DSGI. SRI. K.S. PRENJITH KUMAR FOR SC.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY
HEARD ON 06.12.2025, ALONG WITH WP(C).41064/2025,
43237/2025, THE COURT ON 22.01.2026 DELIVERED THE
FOLLOWING:
5
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
THURSDAY, THE 22ND DAY OF JANUARY 2026 / 2ND MAGHA, 1947
WP(C) NO. 41064 OF 2025
PETITIONER:
INDIAN ASSOCIATION OF PHYSICAL MEDICINE AND
REHABILITATION (IAPMR)
REG. NO. S 18608, HAVING ITS OFFICE AT
SAFDARJUNG HOSPITAL, NEW DELHI, REPRESENTED BY
ITS HONORARY SECRETARY - DR. HARSHANAND PO
PALWAR THROUGH HIS POWER OF ATTORNEY HOLDER -
DR. RAJESH B. NAIR, NELENDA NEAR KALLIL
TEMPLE, ASAMANNOOR, ERNAKULAM, PIN - 683545
BY ADVS.
SMT.S.PARVATHI
SMT.T.K.SREEKALA
SMT.NIKITHA SUSAN PAULSON
SMT.UTHARA ASOKAN
SRI.V.V.ASOKAN (SR.)
SHRI.K.G.ANIL
RESPONDENTS:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, MINISTRY OF
HEALTH AND FAMILY WELFARE, NIRMAN BHAVAN, NEW
DELHI, PIN - 110001
6
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2 NATIONAL COMMISSION FOR ALLIED AND HEALTHCARE
PROFESSIONS (NCAHP),
2ND FLOOR, ACADEMIC BLOCK, NIHFW CAMPUS, BABA
GANGNATH MARG, MUNIRKA, NEW DELHI,REPRESENTED
BY ITS CHAIRPERSON, PIN - 110067
3 STATE ALLIED AND HEALTH CARE COUNCIL,
COMBINED COUNCIL BUILDING, RED CROSS ROAD,
THIRUVANANTHAPURAM,REPRESENTED BY ITS
CHAIRPERSON, PIN-695 035. (*THE ADDRESS OF
THE 3RD RESPONDENT IS CORRECTED AS 'STATE
ALLIED AND HEALTH CARE COUNCIL, NEAR
DIRECTORATE OF MEDICAL EDUCATION, MEDICAL
COLLEGE, THIRUVANANTHAPURAM,
THIRUVANANTHAPURAM MEDICAL COLLEGE S.O.,
THIRUVANANTHAPURAM - 695 011, REPRESENTED BY
ITS CHAIRPERSON' AS PER THE ORDER DATED
03.12.2025 IN IA NO.9/2025 IN WP(C)
NO.41064/2025)., PIN - 10
4 NATIONAL MEDICAL COMMISSION
POCKET-14, SECTOR-8, DWARKA PHASE-1, NEW
DELHI, REPRESENTED BY ITS CHAIRPERSON, PIN -
110077
5 ADDL.R5: THE INDIAN ASSOCIATION OF
PHYSIOTHERAPISTS,
1094,RUSTOMJEE EASE ZONE MALL, GOREGOAN-MULUND
LINK ROAD,GOREGAON, OPP.OZONE TOWER, MALAD
(WEST), MUMBAI, PIN-400 064, REPRESENTED BY
ITS SECRETARY (KERALA BRANCH),DR.JIM
GOPALAKRISHNAN(PT). (ADDL.R5 IS IMPLEADED AS
PER ORDER DATED 13.11.2025 IN IA NO.2/2025 IN
WP(C) NO.41064/2025).
6 ADDL.R6: KERALA ASSOCIATION FOR
PHYSIOTHERAPISTS' COORDINATION (KAPC), REG.NO.
680/10,
REPRESENTED BY ITS GENERAL SECRETARY, UPASANA,
7
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VH 102, UPPER MERIDIAN ROAD, KURAVANKONAM,
KOWDIAR P.O., THIRUVANANTHAPURAM, PIN 695 003.
(ADDL.R6 IS IMPLEADED AS PER ORDER DATED
13.11.2025 IN IA NO.3/2025 IN WP(C)
NO.41064/2025)
7 ADDL.R7: THE ALL INDIA OCCUPATIONAL
THERAPISTS' ASSOCIATION (AIOTA),
PLOT NO. 51, KAMDHENU BUSINESS BAY, 8TH FLOOR,
DOOR NO 801, SECTOR 1, JUINAGAR EAST, NERUL,
NAVI MUMBAI, MAHARASHTRA 400 706, REPRESENTED
BY HONORARY SECRETARY.
8 ADDL.R8: DR.JOSEPH SUNNY,
AGE 46, S/O.SUNNY T.J., THOOMPANAYIL HOUSE,
THIRUVAMPADY P.O., PAZHTHURUTH, KOTTAYAM-686
612. (ADDL.R7 & R8 ARE IMPLEADED AS PER ORDER
DATED 13.11.2025 IN IA NO.4/2025 IN WP(C)
NO.41064/2025).
9 ADDL.R9: T.ARUN KUMAR,
S/O.S.THANKAPPAN NAIR, AGED 51 YEARS,
PHYSIOTHERAPIST,RESIDING AT
"ARUNALAYAM',KODUMTHARA, PATHANAMTHITTA
DISTRICT- 689 645. (ADDL.R9 IS IMPLEADED AS
PER ORDER DATED 13.11.2025 IN IA NO.6/2025 IN
WP(C) NO.41064/2025)
10 ADDL.R10: DR.NAVIN SAGAR,
S/O. SURESH PRASAD MANDAL, SENIOR RESIDENT
DOCTOR, PMR DEPARTMENT, ABVIMS AND DR. RML
HOSPITAL, NEW DELHI, RESIDING IN BASAHA, BLOCK
PIPRA, SUPAUL, BIHAR-852 131.
11 ADDL.R11: DR.ASHA E.K.,
CONSULTANT, PHYSICAL MEDICINE AND
REHABILITATION, DISTRICT HOSPITAL, KANJANHAD,
KASARGODE-671 531.
8
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12 ADDL.R12: DR.ARUN A. JOHN,
CONSULTANT IN PHYSICAL MEDICINE AND
REHABILITATION, LEPROSY SANATORIUM, NOORANAD,
ALAPPUZHA-690 571.
13 ADDL.R13: DR. PRAMOD KUMAR P.P.,
ASSISTANT DIRECTOR, KERALA HEALTH SERVICE,
KERALA WOMEN AND CHILDREN HOSPITAL, KOZHIKODE-
673 001. (ADDL.R10 TO R13 ARE IMPLEADED AS PER
ORDER DATED 13.11.2025 IN IA NO.7/2025 IN
WP(C) NO.41064/2025).
14 ADDL.R4: KERALA ORTHOPAEDIC ASSOCIATION,
REG NO. E.R.275/1992, REPRESENTED BY ITS
SECRETARY, 4C IMA HOUSE, PALARIVATTO P.O,
KOCHI-682 028. (ADDL.R14 IS IMPLEADED AS PER
ORDER DATED 03.12.2025 IN IA NO.10/2025 IN
WP(C) NO.41064/2025).
BY ADVS.
SHRI.MAHADEV M.J., CGC
GOVERNMENT PLEADER
SHRI.K.S.PRENJITH KUMAR, SC, NATIONAL MEDICAL
COMMISSION
SRI.V.SREEJITH (K/1398/2000)
SMT.NISHA GEORGE
SRI.SABU GEORGE
SHRI.V.RAMKUMAR NAMBIAR
SRI.VINEETH KOMALACHANDRAN
SRI.G.P.SHINOD
SRI.S.SREEKUMAR (SR.)
SRI.NAVANEETH D.PAI
SRI.GEORGE POONTHOTTAM (SR.)
SMT.SILPA SREEKUMAR
SRI.P.B.SUBRAMANYAN
SRI.MANU VYASAN PETER
SHRI.P.B.KRISHNAN (SR.)
O.M.SHALINA, DEPUTY SOLICITOR GENERAL OF INDIA
SRI.GOVIND PADMANAABHAN
9
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SHRI.AJIT G ANJARLEKAR
SHRI.ATUL MATHEWS
SMT.GAYATHRI S.B.
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY
HEARD ON 06.12.2025, ALONG WITH WP(C).43518/2025 AND
CONNECTED CASE, THE COURT ON 22.01.2026 DELIVERED THE
FOLLOWING:
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE V.G.ARUN
THURSDAY, THE 22ND DAY OF JANUARY 2026 / 2ND MAGHA, 1947
WP(C) NO. 43237 OF 2025
PETITIONERS:
1 DR. SONU MOHAN M.S
AGED 40 YEARS
S/O. M. MOHANAN JUNIOR CONSULTANT PMR,
DISTRICT HOSPITAL, PALAKKAD. NOW RESIDING IN
POURNAMI, D10-SRKPRA, ASHRAMOM ROAD, NETTAYAM
P.O., THIRUVANANTHAPURAM, PIN - 695013
2 DR. RAMESH C
AGED 60 YEARS
S/O KARUNAKARAN C., CONSULTANT IN PHYSICAL
MEDICINE & REHABILITATION RESIDING AT
AISHWARYA, MINI BYEPASS, PUTHIYARA, KOZHIKODE,
PIN - 673004
3 DR. ARUN OOMMEN
AGED 48 YEARS
S/O. K.G. OOMMEN, SENIOR CONSULTANT NEURO
SURGEON, VPS LAKESHORE HOSPITAL, NETTOOR P.O,
KOCHI, PIN - 682040
BY ADVS.
SMT.S.PARVATHI
SHRI.K.G.ANIL
SMT.T.K.SREEKALA
SMT.NIKITHA SUSAN PAULSON
11
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SMT.UTHARA ASOKAN
SHRI.K.I.MAYANKUTTY MATHER (SR.)
RESPONDENTS:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, MINISTRY OF
HEALTH AND FAMILY WELFARE, NIRMAN BHAVAN, NEW
DELHI, PIN - 110001
2 NATIONAL COMMISSION FOR ALLIED AND HEALTHCARE
PROFESSIONS (NCAHP)
2ND FLOOR, ACADEMIC BLOCK, NIHFW CAMPUS, BABA
GANGNATH MARG, MUNIRKA, NEW DELHI, REPRESENTED
BY ITS CHAIRPERSON, PIN - 110067
3 STATE ALLIED AND HEALTH CARE COUNCIL
NEAR DIRECTORATE OF MEDICAL EDUCATION, MEDICAL
COLLEGE, THIRUVANANTHAPURAM,
THIRUVANANTHAPURAM MEDICAL COLLEGE S.O,
THIRUVANANTHAPURAM, REPRESENTED BY ITS
CHAIRPERSON, PIN - 695011
4 NATIONAL MEDICAL COMMISSION
POCKET-14, SECTOR-8, DWARKA PHASE-1, NEW
DELHI, REPRESENTED BY ITS CHAIRPERSON, PIN -
110077
BY ADVS.
O.M.SHALINA, DEPUTY SOLICITOR GENERAL OF INDIA
GOVERNMENT PLEADER
SHRI.MAHADEV M.J., CGC
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY
HEARD ON 06.12.2025, ALONG WITH WP(C).43518/2025 AND
CONNECTED CASE, THE COURT ON 22.01.2026 DELIVERED THE
FOLLOWING:
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V.G.ARUN, J
= = = = = = = = = = = = = = = = =
W.P.(C).Nos.41064, 43237
and 43518 of 2025
= = = = = = = = = = = = = = = = =
Dated this the 22nd day of January, 2026
JUDGMENT
The petitioners are qualified medical professionals in
the field of modern scientific medicine and are aggrieved by
the powers and status given to Physiotherapists and
Occupational Therapists under the National Commission for
Allied and Healthcare Profession Act, 2021 ('the NCAHP Act'
for short) as well as the Competency Based Curriculum for
Physiotherapy and Occupational Therapy. According to the
petitioners, the objectionable provisions in the NCAHP Act
and the Curriculum run counter to the provisions of the
National Medical Commission Act, 2019 ('the NMC Act' for
short). They contend that, while the specialist medical
professionals in the specialty of Physical Medicine and
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Rehabilitation are qualified doctors, Physiotherapists and
Occupational Therapists only extend supporting service, and
do not have the qualification or entitlement to extend their
services as first hand healthcare professionals. The
qualifications of Physiotherapists can at best enable them to
undertake administration of physiotherapy under the
instructions of a qualified Medical Practitioner. Even though
the curriculum of physiotherapy and occupational therapy
contains many subjects like Anatomy, Physiology, etc., that,
by itself, will not confer them with the right to engage in
independent clinical practice, since such subjects are taught
solely to provide a basic idea regarding the human body and
as to how it functions. There are no statutory provisions
under the NCAHP Act conferring legal right to diagnose,
decide treatment plan, or prescribe treatment by
Physiotherapists and Occupational Therapists or such other
healthcare professionals. The petitioners are also aggrieved
by the fact that the Competency Based Curriculum for
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Physiotherapy and Occupational Therapy permits the use of
the prefix "Dr" with suffix "PT" by Physiotherapists and "OT"
by Occupational Therapists, thereby equating them with
modern medical practitioners.
The writ petitions are hence filed seeking the following
reliefs;
"(i) Declare by means of an appropriate writ or order to nullify
rather read down the wide scope of the connotation "Physiotherapy
Professional" as enlisted vide Sl. No. 3 as well as Serial No. 6-
Occupational Therapy Professional of the Schedule appended to the
National Commission for Allied and Health Care Professions Act, 2021 so
as to make and confine the scope of discharge of such professional
services of Physiotherapists and Occupational Therapy Professionals
only as a supporting group for the qualified Medical Professionals under
the provisions of the National Medical Commission Act, 2019 and Indian
Medical Degrees Act, 1916;
(ii) Call for the records of the case leading to the promulgation of
competency based curriculum for physiotherapy and Occupational
Therapy by the National Commission for Allied and Health Care
Professions by means of a writ of certiorari or such other appropriate
writ or order and quash/read down certain provisions therein viz. (1)
Chapter 1 Clause 1.2, (ii) Chapter 3 Clause 3.0 and 3.2.3 and (iii)
Chapter 8 of Competency Based Curriculum for Physiotherapy (Ext.P1)
and Chapter 1-1.3.1, 1.3.3, 1.6.2, Chapter 3 3.3 and 3.7 (Ext. P1(a))
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Competency Based Curriculum for Occupational Therapy, to the extent
to which they purport to place Physiotherapists and Occupational
Therapy Professionals in a high pedestal as a First Health Care provider
and in allowing them to use prefix 'Dr' in their names.
(iii) Issue a writ of mandamus or other appropriate writ or order
directing the respondents, particularly the respondents 2 and 3 and their
Officers to issue necessary orders interdicting Physiotherapists and
Occupational Therapy Professionals in proclaiming themselves as First
Health Care provider and in using the prefix 'Dr' in their names and to
ensure that their professional services should be confined only as a
supporting group for the medical profession;"
2. Heard Senior Advocates Mayankutty Mather for the
petitioners, S.Sreekumar, George Poonthottam and
P.B.Krishnan, along with Advs.V.Ramkumar Nambiar and
Vineeth Komalachandran for the party respondents,
Adv.O.M.Shalina, the learned DSGI for the Union of India,
Adv.K.S.Premjith Kumar, the learned Standing Counsel for
the National Medical Commission, and Advocate Mahadev
M.J, the learned Central Government Counsel for the National
Commission for Allied and Healthcare Professions.
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3. Learned Senior Counsel appearing for the petitioners
put forth the following contentions in support of the reliefs
sought;
The NMC Act provides for a medical educational system
that improves access to quality and affordable medical
education, ensuring availability of adequate and high quality
medical professionals in all parts of the country. Persons
having the qualification prescribed under the NMC Act alone
are entitled to practice modern medicine in the country.
Section 2(j) of the NMC Act defines 'medicine' as modern
scientific medicine in all its branches, including surgery and
obstetrics and as per Section 2(r), 'recognised medical
qualification' means a medical qualification recognised under
Sections 35, 36, 37 or 40. While Section 2(m) of the NMC Act
defines 'National Register', Section 2(v) defines 'State
Register'. Further Section 33 mandates that only persons
who qualify the National Exit Test shall be granted licence to
practice medicine and have their names enrolled in the
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National Register or the State Register, as the case may be.
Moreover, Section 34 prohibits the practice of medicine by
persons other than those enrolled in the 'State Register' or
the 'National Register'. As against this, the impugned
provisions of the NCAHP Act as well as the Curriculum
issued under Section 11 of that Act confer powers upon the
Physiotherapists and Occupational Therapists to directly
receive patients, conduct first-contact examinations,
diagnose diseases, undertake treatment and use the prefix
'Dr', which in essence, amounts to the practice of modern
medicine. Thus, the said provisions run contrary to the
provisions of the NMC Act, which is the final word as far as
the practice of modern medicine in the country is concerned.
Unlike Ayurvedic or Unani practitioners belonging to
different systems of medicine, the common public perception
is that Physiotherapists and Occupational Therapists are part
of the modern medical system, and therefore, use of the
prefix 'Dr' by such persons will lead to disastrous results as
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patients may approach them for treatment, which can only be
provided by qualified medical practitioners. Moreover,
Section 40 of the Kerala State Medical Practitioners Act,
2021 provides for penalty for unauthorised use of titles,
letters or abbreviations implying that a person holds a
degree, diploma, licence or certificate to practice modern
medicine unless he actually holds such degree, diploma,
licence or certificate. A conjoint reading of the provisions of
the NMC Act along with Section 40 of the Kerala State
Medical Practitioners Act will unequivocally show that
Physiotherapists and Occupational Therapists cannot
practice modern medicine or use the prefix 'Dr'.
4. Learned Senior Counsel placed reliance on the
following decisions to contend that, MBBS qualification is a
pre-requisite for practicising modern medicine; Poonam
Verma v. Aswin Patel [1996 KHC 450 (SC)], Medical
Council of India and Another v. State of Rajasthan and
Another [(1996) 7 SCC 731], Dr.A.K.Sabhapathy v. State
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of Kerala and Others [1992 (1) KLT 784 (SC)],
Dr.Mukhtiar Chand and Others v. State of Punjab and
Others [(1998) 7 SCC 579]. Attention is drawn to the
decision in Bharru Islam v. Indian Medical Association
[AIR 2023 SC 721] to point out that the Supreme Court had
held an Act permitting persons without recognised medical
qualifications, to practice allopathic medicines, as null and
void. The decision in Sri Sarjoo Prasad and Ors v The
State of Bihar & Ors [(2003) SCC OnLine Pat 188] is
pressed into service in support of the argument that even
though Occupational Therapy and Physiotherapy are
recognised medical disciplines, individuals not enrolled in
the State Medical Register cannot practice modern medicine
or use titles implying such authority. Referring to the
decision of this Court in Mohammed Jamsheer K.V. v.
Station House Officer [2025 KHC OnLine 10808], it is
contended that use of the prefix 'Dr' by a Physiotherapist is
misleading and constitutes an offence under the IPC and
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relevant medical statutes. According to the Senior Counsel,
in common parlance, the prefix 'Dr' is associated with a
medical practitioner, and if a Physiotherapist prefixes his
name with 'Dr', the general public would naturally assume
him to be a qualified allopathic doctor. Support for this
argument is sought to be drawn from the explanation of the
expression "common parlance" in Commissioner of Central
Excise v. Madhan Agro Industries India Private Limited
[(2018) 15 SCC 733].
5. Senior Counsel S. Sreekumar appearing for some
of the respondents, raised a preliminary objection against the
maintainability of the writ petitions at the instance of an
association of a few doctors, when the regulatory body that
governs medical practitioners, viz.; the National Medical
Commission had not raised any objection against the
Curriculum or use of the prefix 'Dr' by Physiotherapists and
Occupational Therapists. Even otherwise, the prefix 'Dr' is
not statutorily recognized under the NMC Act and that
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statute merely entitles qualified medical practitioners to have
their names entered in the State Register. The NCAHP Act
was enacted by the Parliament after due deliberation and
based on the recommendations of the Parliamentary
Committee, after hearing all stakeholders. Section 2(j) of the
NCAHP Act entitles the healthcare professionals to provide
preventive, curative, rehabilitative, therapeutic services, etc.
The Act also provides for the constitution of a National
Commission for ensuring co-ordinated and integrated
development of education and maintenance of the standards
of delivery of services. The members of the Commission are
eminent personalities and institutions, and includes even a
representative of the National Medical Commission.
Therefore, it is not for a set of doctors, motivated by their
personal interest, to require the High Court to read down the
provisions of the NCAHP Act or seek a declaration that
Physiotherapists and Occupational Therapists cannot use the
prefix 'Dr'.
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
6. Senior Counsel George Poonthottam, appearing
for the Physiotherapists, submitted that the physiotherapy
profession constitutes an independent and distinct branch of
health science, forming part of the Allied Health and
Rehabilitation Services. The Competency Based Curriculum
for Physiotherapy and Occupational Therapy framed by the
Allied Health Commission expressly recognises these
professionals as first contact health providers within their
domain, having autonomy to assess, plan and implement
rehabilitative and therapeutic interventions. The Allied
Health Commission is performing a role analogous to that of
the National Medical Commission in relation to medical
practitioners. According to the Senior Counsel, the reliefs
sought cannot be granted as the petitioners are seeking
directions to nullify or read down various statutory
provisions of the NCAHP Act and to confine the professional
scope of Physiotherapists and Occupational Therapists to
supporting medical professionals governed by the NMC Act.
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
The High Court, in exercise of its writ jurisdiction under
Article 226, does not possess the power to read down or re-
write the provisions of a parliamentary enactment, so as to
alter the legislative intent or policy. Further, the
presumption being that a parliamentary enactment is
constitutional, judicial interference is justified only on limited
grounds. The Senior Counsel submits that, the attempt of the
petitioners is to curtail and diminish the professional status,
competency and scope of practice of an entire class of
recognized health professionals.
7. Senior Advocate P.B.Krishnan appearing for the
Occupational Therapists drew attention to Section 64 of
NCAHP Act to point out the overriding effect of the Act. It is
contended that the NCAHP Act being the subsequent
enactment, its provisions will prevail over the NMC Act.
Serial No.6 of the Schedule to the NCAHP Act dealing with
occupational therapy professionals makes it abundantly clear
that an occupational therapist can either practice
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
independently or as part of a multi-disciplinary team.
Further, the Curriculum for Occupational Therapists,
prepared in exercise of the power conferred under Section
66(2)(a) of the NCAHP Act also has statutory force. The
Senior Counsel submits that, while the Indian Medical
Degrees Act, 1916 provided penalty for falsely assuming or
using medical titles, the said provision was subsequently
repealed and the prevailing statute, i.e., the NMC Act does
not contain either any provision conferring the title 'Dr' on
qualified medical practitioners or penalty for use of the title
by other qualified professionals.
8 Before proceeding to decide upon the legality of the
provisions, it is essential to understand the circumstances leading
to the enactment of the NCAHP Act and the formulation of the
Competency Based Curriculum for Physiotherapists and
Occupational Therapists. Till recently, the health force in the
Indian scenario had focused mainly on a few cadres such as
qualified modern medicine practitioners, nurses and front-line
workers, while the professionals belonging to the healthcare
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
sector were generally termed as para-medical professionals. The
advancement in the health sector and the changing preferences
of consumers and service providers warranted a fresh vision of
healthcare delivery with a patient-centric approach and focus on
moving to a multi-disciplinary team based care. Accordingly, the
Allied and Healthcare Professions Bill, 2018 was introduced in the
Rajya Sabha and referred to the Department Related
Parliamentary Standing Committee of the Ministry of Health and
Family Welfare for its examination and report. Based on the
recommendations of the Committee, the earlier Bill was
withdrawn and a new Bill, namely, the National Commission for
Allied and Healthcare Professions Bill, 2020 introduced. Later,
after due deliberations, the National Commission for Allied and
Healthcare Professions Act, 2021 was brought into force. The Act
is intended to provide for regulation and maintenance of
standards of education and services by allied and healthcare
professionals, assessment of institutions, maintenance of a Central
Register and State Register, creation of a system to improve
access, research and development, adoption of latest scientific
advancement and for matters connected therewith or incidental
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
thereto.
9. Section 2(d) of the Act defines 'allied and health
professional' as under;
"2(d) "allied health professional" includes an associate, technician or
technologist who is trained to perform any technical and practical task
to support diagnosis and treatment of illness, disease, injury or
impairment, and to support implementation of any healthcare
treatment and referral plan recommended by a medical, nursing or
any other healthcare professional, and who has obtained any
qualification of diploma or degree under this Act, the duration of which
shall not be less than two thousand hours spread over a period of two
years to four years divided into specific semesters"
The definition of 'healthcare professional' in Section 2(j)
reads as under;
"2(j) "healthcare professional" includes a scientist, therapist or other
professional who studies, advises, researches, supervises or provides
preventive, curative, rehabilitative, therapeutic or promotional health
services and who has obtained any qualification of degree under this
Act, the duration of which shall not be less than three thousand six
hundred hours spread over a period of three years to six years divided
into specific semesters;"
10. Thus, going by the definition itself, a healthcare
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
professional is entitled to provide preventive, curative,
rehabilitative, therapeutic and promotional health services.
There is no direct challenge to the said provision and the
prayer is only to read down certain provisions, that too, of
the Schedule to the Act and the Competency Based
Curriculum. As rightly contended by the respondents, the
prayer seeking the reading down of the provisions of an
enactment passed by the Parliament will normally not be
entertained, though, in appropriate cases the writ courts can
resort to such procedure. In the cases under consideration,
this Court is unable to find any compelling reason to read
down the provisions of the NCAHP Act, so as to confine the
scope of discharge of professional services by
Physiotherapists and Occupational Therapists as a
supporting group for the qualified medical professionals
registered under the NMC Act. Pertinent to note that the
healthcare professionals are conferred the qualification of
degree under the NCAHP Act after undergoing extensive
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
study of not less than three thousand six hundred hours
spread over a period of three years to six years, divided into
specific semesters. Even though healthcare professionals
can provide preventive, curative, rehabilitative, therapeutic
and promotional health services, they cannot prescribe
medicines or provide allopathic treatment. Therefore, the
services provided by a healthcare professional and a medical
professional are distinct, though, at times, a healthcare
professional will also be playing a supporting role during
allopathic treatment of patients. While considering whether
the prayers in the writ petition can be granted, the
overriding effect provided by Section 64 of the NCAHP Act
cannot be overlooked. Yet another aspect of importance is
that the Parliamentary Committee had made its
recommendations, after hearing the National Medical
Commission also. The fact that the representative of the
National Medical Commission is a member of the National
Commission for Allied and Healthcare Professions, also
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
assumes relevance. In such circumstances, it will be
inappropriate for this Court to tinker with the policy of the
Government or read down the provisions of the Act or the
Curriculum at the instance of a few medical professionals.
10. The challenge against the use of prefix 'Dr' by
Physiotherapists will not also hold good since the NMC or the
allied statutes does not provide for the use of the prefix 'Dr'
by qualified medical professionals. Here it will be interesting
to note that the term 'Doctor' originated from the latin word
'Doctor', which means teacher or instructor. Research
reveals that, around the thirteenth century, the term Doctor
has evolved into an academic title in European Universities
and was used for referring to someone who had achieved the
highest level of learning and had received licence to teach in
fields like theology, law and philosophy. Thus, the term
Doctor originally meant a learned person qualified to teach.
Gradually, with the advancement of medical science,
University trained Physicians (holders of degrees in
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
medicine) began to be called Doctors. The usage became
much more common for physicians by the nineteenth
century, as medical education formalised and the public
increasingly associated the title with healers. Therefore the
contention that the title 'Doctor' exclusively belongs to
medical professionals is a misconception since even now, like
in the olden times, persons with higher educational
qualifications like PhD are entitled to use the title 'Doctor'.
As rightly contended by the respondents, the NMC Act
does not contain any provision for conferring the title Doctor
on qualified medical professionals. The expression title used
in Section 40 of the Kerala State Medical Practitioners Act
cannot therefore be understood as statutorily entitling the
qualified medical professionals to prefix 'Dr' to their names.
In the absence of such provision, the petitioners cannot claim
exclusive right to use the prefix 'Dr'. The decisions relied on
by the Senior Counsel for the petitioners are all rendered
prior to or without reference to the NCAHP Act and are
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
therefore not applicable to the cases under consideration.
For the aforementioned reasons, the writ petitions are
dismissed.
sd/-
V.G.ARUN, JUDGE
sj
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 43518 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P1(b) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OPTOMETRY -
APPROVED SYLLABUS
2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
DATED 22.02.2003 OF
THE HON'BLE PATNA
HIGH COURT
Exhibit P3(a) TRUE COPY OF THE
ORDER IN S.L.P. NO.
19889/2003 OF THE
HON'BLE SUPREME
COURT DATED
09.05.2008.
Exhibit P4 TRUE COPY OF THE
NOTIFICATION D.O
NO. Z28017/91/2025-
SAS III
(FTS8356966) DATED
09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION D.O
NO. Z28017/91/2025-
SAS III
(FTS8356966) DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018 OF
HEALTH & FAMILY
WELFARE (K)
DEPARTMENT,
THIRUVANANTHAPURAM
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 41064 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
DATED 21.02.2003 OF
THE PATNA HIGH
COURT
Exhibit P3(a) TRUE COPY OF THE
SPECIAL LEAVE
PETITION (S.L.P.
NO. 19889/2003)
FILED BEFORE THE
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
HON'BLE SUPREME
COURT.
Exhibit P4 TRUE COPY OF THE
NOTIFICATION DATED
09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018
AFFIDAVIT AFFIDAVIT
RESPONDENT EXHIBITS
Exhibit R5(a) A TRUE COPY OF THE
REGISTRATION
CERTIFICATE DATED
29-06-1955 OF
APPLICANT NO.1
Exhibit R5(b) A TRUE COPY OF THE
CONSTITUTION OF
APPLICANT NO.1
UPDATED AS ON 31-
03-2013
RESPONDENT EXHIBITS
Exhibit-R7(a) A true copy of the
report dated 17-01-
2020 by the
Department-related
Parliamentary
Standing Committee
on Health and
Family Welfare
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
Exhibit-R6(a) True copy of the
relevant pages of
the 117th report of
the Parliamentary
standing committee
of Health and
family Welfare
during the
presentation of the
Bill on 31.01.2018
Exhibit-R6(b) True copy of the
certificate No. 09-
6840 dated
05.03.2009 issued
by the Medical
Council of India.
Exhibit-R6(c) True copy of the
certificate issued
by the Maharashtra
State Council for
Occupational
Therapy and
Physiotherapy
Mumbai dated
28.07.2014.
Exhibit-R6(d) True copy of the
RTI application
dated 29.03.2017
along with the
reply furnished by
the Medical Council
of India.
EXHIBIT-R5(c) True copy of RTI
report dated
03/01/2025
EXHIBIT-R5(d) True copy of RTI
report received
dated 30/08/2025
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 43237 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
DATED 22.02.2003 OF
THE HON'BLE PATNA
HIGH COURT
Exhibit P3(a) TRUE COPY OF THE
ORDER IN S.L.P. NO.
19889/2003 OF THE
HON'BLE SUPREME
COURT DATED
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
09.05.2008
Exhibit P4 TRUE COPY OF THE
NOTIFICATION
D.O.NO.
Z28017/91/2025-SAS-
III(FTS.8356966)
DATED 09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION
NO.Z28017/91/2025-
SAS-III
(FTS.8356966) DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018 OF
HEALTH AND FAMILY
WELFARE (K)
DEPARTMENT,
THIRUVANANTHAPURAM
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 43518 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P1(b) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OPTOMETRY -
APPROVED SYLLABUS
2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
DATED 22.02.2003 OF
THE HON'BLE PATNA
HIGH COURT
Exhibit P3(a) TRUE COPY OF THE
ORDER IN S.L.P. NO.
19889/2003 OF THE
HON'BLE SUPREME
COURT DATED
09.05.2008.
Exhibit P4 TRUE COPY OF THE
NOTIFICATION D.O
NO. Z28017/91/2025-
SAS III
(FTS8356966) DATED
09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION D.O
NO. Z28017/91/2025-
SAS III
(FTS8356966) DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018 OF
HEALTH & FAMILY
WELFARE (K)
DEPARTMENT,
THIRUVANANTHAPURAM
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 41064 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
DATED 21.02.2003 OF
THE PATNA HIGH
COURT
Exhibit P3(a) TRUE COPY OF THE
SPECIAL LEAVE
PETITION (S.L.P.
NO. 19889/2003)
FILED BEFORE THE
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
HON'BLE SUPREME
COURT.
Exhibit P4 TRUE COPY OF THE
NOTIFICATION DATED
09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018
AFFIDAVIT AFFIDAVIT
RESPONDENT EXHIBITS
Exhibit R5(a) A TRUE COPY OF THE
REGISTRATION
CERTIFICATE DATED
29-06-1955 OF
APPLICANT NO.1
Exhibit R5(b) A TRUE COPY OF THE
CONSTITUTION OF
APPLICANT NO.1
UPDATED AS ON 31-
03-2013
RESPONDENT EXHIBITS
Exhibit-R7(a) A true copy of the
report dated 17-01-
2020 by the
Department-related
Parliamentary
Standing Committee
on Health and
Family Welfare
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
Exhibit-R6(a) True copy of the
relevant pages of
the 117th report of
the Parliamentary
standing committee
of Health and
family Welfare
during the
presentation of the
Bill on 31.01.2018
Exhibit-R6(b) True copy of the
certificate No. 09-
6840 dated
05.03.2009 issued
by the Medical
Council of India.
Exhibit-R6(c) True copy of the
certificate issued
by the Maharashtra
State Council for
Occupational
Therapy and
Physiotherapy
Mumbai dated
28.07.2014.
Exhibit-R6(d) True copy of the
RTI application
dated 29.03.2017
along with the
reply furnished by
the Medical Council
of India.
EXHIBIT-R5(c) True copy of RTI
report dated
03/01/2025
EXHIBIT-R5(d) True copy of RTI
report received
dated 30/08/2025
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
APPENDIX OF WP(C) NO. 43237 OF 2025
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR PHYSIOTHERAPY -
APPROVED SYLLABUS
2025'.
Exhibit P1(a) TRUE COPY OF THE
RELEVANT PROVISIONS
UNDER CHALLENGE IN
THE
‘COMPETENCY
BASED CURRICULUM
FOR OCCUPATIONAL
THERAPY - APPROVED
SYLLABUS 2025'.
Exhibit P2 TRUE COPY OF THE
JUDGMENT DATED
27.06.2025 OF THIS
HON'BLE COURT IN
WRIT PETITION
(CIVIL) NO. 7867 OF
Exhibit P3 TRUE COPY OF THE
JUDGMENT IN CIVIL
DATED 22.02.2003 OF
THE HON'BLE PATNA
HIGH COURT
Exhibit P3(a) TRUE COPY OF THE
ORDER IN S.L.P. NO.
19889/2003 OF THE
HON'BLE SUPREME
COURT DATED
W.P.(C).No.41064/25 & con.cases
2026:KER:6168
09.05.2008
Exhibit P4 TRUE COPY OF THE
NOTIFICATION
D.O.NO.
Z28017/91/2025-SAS-
III(FTS.8356966)
DATED 09.09.2025
Exhibit P5 TRUE COPY OF THE
NOTIFICATION
NO.Z28017/91/2025-
SAS-III
(FTS.8356966) DATED
10.09.2025 ISSUED
BY THE MINISTRY
HEALTH & FAMILY
WELFARE THROUGH
DIRECTORATE GENERAL
OF HEALTH SERVICES
Exhibit P6 TRUE COPY OF G.O.
H&FWD DATED
14.02.2018 OF
HEALTH AND FAMILY
WELFARE (K)
DEPARTMENT,
THIRUVANANTHAPURAM
