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[Cites 43, Cited by 0]

Kerala High Court

K.V.Mohammed Jamsheer vs S.H.O.Kannur Town Police Station on 13 February, 2025

WP(C) NO.190/2013                    1



                                             2025:KER:11812

         IN THE HIGH COURT OF KERALA AT ERNAKULAM

                           PRESENT

        THE HONOURABLE MR. JUSTICE SYAM KUMAR V.M.
THURSDAY, THE 13TH DAY OF FEBRUARY 2025 / 24TH MAGHA, 1946
                    WP(C) NO. 190 OF 2013
        CC NO.838 OF 2012 OF JUDICIAL MAGISTRATE OF FIRST
                      CLASS -I, KANNUR
PETITIONER:

         K.V.MOHAMMED JAMSHEER
         S/O.C.V MOHAMMED SHERIF
         AGED 29 YEARS, 'SUDHEEPAM'
         NEAR CHOVVA BRIDGE, KANNUR 6

         BY ADVS.
         SRI.K.C.SANTHOSHKUMAR
         SMT.K.K.CHANDRALEKHA


RESPONDENTS:

    1    STATION HOUSE OFFICER
         KANNUR TOWN POLICE STATION
         KANNUR DISTRICT

         ADDL.R2:
    2    M.C.SHEREEF
         S/O.P.K.C.KUNHABDULLA HAJI. B.M.C. VILLA,
         BEECHARAKADAVU, PADNNA KADAPPURAM.P.O.,
         HOSDURG, KASARGODE.

         IMPLEADED AS PER ORDER DATED 01.11.2023 IN
         I.A.NO.13569/2013

         BY ADV.BINOY DAVIS, GOVERNMENT PLEADER

     THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD
ON 13.02.2025, THE COURT ON THE SAME DAY DELIVERED THE
FOLLOWING:
 WP(C) NO.190/2013                         2



                                                             2025:KER:11812




                              JUDGMENT

Dated this the 13th day of February, 2025 Whether a criminal prosecution would lie against a physiotherapist for putting forth to the public at large to be a 'Doctor' by using the prefix 'Dr.' to his name in the office stationary and in his name boards is the short, but pertinent question that arises for consideration in this Writ Petition.

2. The petitioner is a Physiotherapist by profession. He is the accused in C.C.No.867 of 2012 on the file of the Judicial First Class Magistrate Court-I, Kannur. Ext.P1 charge sheet has been laid against him alleging commission of offences under Section 419 of the IPC, Sections 38 and 39 of the Travancore Cochin Medical Practitioner's Act, 1953 and Section 17 (4) of the Indian Medical Council Act, 1956. Petitioner claims to be totally innocent of the offences charged. He seeks to quash Ext.P1 charge sheet inter alia contending that it is a falsely foisted case wherein not even a prima facie case has been made out against him. He contends that WP(C) NO.190/2013 3 2025:KER:11812 subjecting him to face the trial will be an exercise in futility and enduring a trial will be trauma and punishment in itself. He has hence filed this Writ Petition seeking the following reliefs:

1. (i) Issue a writ of certiorari or other appropriate writ, order or direction call for the records leading to Ext. P1 charge sheet and quash the same.
2. (ii) Such other and further reliefs this Honourable Court may deem fit and proper in the interest of justice.
3. A statement has been filed by the 1 st respondent producing Annexure R1 (a) copy of an enquiry report submitted by the District Medical Officer (Health), Kannur, inter alia stating that an enquiry had been conducted against the petitioner/accused on the basis of the complaints received from the general public and it has been revealed in the said inquiry that the petitioner is not a qualified medical practitioner and his practice as a 'doctor' is illegal.
4. The de facto complainant got impleaded in this W.P.(C) as the additional 2nd respondent pursuant to the order in I.A.No.13569 of 2013.
5. Heard Sri.K.C.Santhosh Kumar, Advocate, appearing on behalf of the petitioner and Sri.Binoy Davis, learned WP(C) NO.190/2013 4 2025:KER:11812 Government Pleader, appearing on behalf of respondent No.1.

There was no appearance on behalf of the additional 2 nd respondent.

6. The learned counsel appearing for the petitioner submitted that Ext.P1 charge sheet had been filed and was being pursued under the misconception that a physiotherapist cannot be addressed as a 'doctor' and that a physiotherapist is prohibited from using the prefix 'Doctor' or 'Dr' to his name. Petitioner has been conferred with a Bachelor of Physiotherapy degree after successfully completing a full-fledged medical course spanning more than 4½ years. He has been admitted to the Indian Association of Physiotherapists as 'Dr.K.V. Mohammed Jamsheer'. The prefix 'Dr.' is based on tradition and convention and there is no prohibition against using the said terms or designations under law. It has a meaning apart from the dictionary meaning of addressing a qualified practitioner of medicine, a person holding a doctorate etc. Exhibiting a name board describing his name as 'Dr.Muhammed Jamsheer' and attending to patients does not attract any offence punishable under any of the provisions under which he is seen WP(C) NO.190/2013 5 2025:KER:11812 charged. Further, Ext.P1 charge sheet does not disclose any offence punishable under law. The Travancore Cochin Medical Practitioners' Act 1953, does not apply to Physiotherapists. No offence can lie against the petitioner under the said statute. The FIR states that the complaint was filed by an individual by name M.C.Shereef upon seeing a news item on a TV channel. The same cannot lead to an implication of the petitioner under the provisions of the statutes under which he is now seen charged. The role played by CW7, who is the husband of an allopathic doctor and an active worker of All India Association of Allopathic Doctors, is clearly manifest in the matter. The prosecution initiated is the result of a collusion between the de facto complainant and the office bearers of All India Association of Allopathic Doctors. Petitioner has been made a scapegoat in the tussle between the physiotherapists and allopathic doctors. Even the averments in the F.I.Statement do not reveal any reason to implicate the petitioner. FIS only states that Smt.Megha Raghavan along with one Nabeel Kamal, Physiotherapist attached to the hospital had attended to the de facto complainant and he was referred to Dr.Anil Sundareshan of Holistic WP(C) NO.190/2013 6 2025:KER:11812 Medicine in the Apollo Clinic, City Centre, Kannur. The right of physiotherapists to practice independently without registration for such practice has been recognised by many Indian universities including Mahatma Gandhi University, Kottayam. Ext.P1 charge sheet does not reveal all the ingredients of Section 415 IPC. Reliance is placed on the dictum laid down in Vipin Sahni v. Central Bureau of Investigation ( 2024 KHC 6195); Ram Jas v. State of U.P. (1970 KHC 531). Regarding the question of maintainability of the Writ Petition to challenge a charge sheet, the learned counsel submitted that a Writ Petition filed under Article 226 of the Constitution challenging Ext.P1 charge sheet is maintainable as the inherent jurisdiction of Article 226 of the Constitution is designed to achieve the salutary purpose that criminal proceedings ought not to be permitted to degenerate into weapons of harassment. When the court is satisfied that the criminal proceeding amounts to an abuse of the process of law or that it amounts to bringing pressure upon the accused, in the exercise of inherent powers, such proceedings can be quashed. Reliance is placed on the dictum laid down by the Supreme Court in Kapil Agarwal and WP(C) NO.190/2013 7 2025:KER:11812 others v. Sanjay Sharma and others (2021 KHC 6119). The extraordinary power under Article 226 of the Constitution, it is contended can be exercised to prevent abuse of process of any court or to otherwise secure the ends of Justice when the allegations in the First Information Report and other materials, if any, accompanying the FIR do not disclose a cognizable offence, justifying an investigation by police officers under Section 156(1) of the Code of Criminal Procedure (Cr.P.C.) except under an order of a Magistrate within the purview of Section 155(2) of the Cr.P.C. Reliance is placed on the dictum laid down by the Hon'ble Supreme Court in a catena of decisions commencing from State of Haryana and others v. Ch. Bhajan Lal and others (1992 KHC 600) to Neeharika Infrastructure Pvt. Ltd. (M/s.) v. State of Maharashtra and others (2021 (3) KHC 25) to contend that the High Court under Article 226 has the power to entertain a Writ Petition seeking to quash an FIR or a charge sheet.

7. Per contra, the learned Government Pleader, challenges the very maintainability of the Writ Petition under Article 226 seeking to quash Ext.P1 charge sheet. He submits that the WP(C) NO.190/2013 8 2025:KER:11812 petitioner has sought to quash the charge sheet by invoking Article 226 of the Constitution rather than seek the same relief under Section 482 of the Cr.P.C. Reliance is placed on the dictum in Thansingh Nathmal and others v. Superintendent of Taxes, Dhubri and others [1964 KHC 576]. It was also open to the petitioner to seek a discharge under Section 239 of the Code of Criminal Procedure, 1973 (Reliance is placed on the dictum in Vijukumar R. v. State of Kerala [2024 KHC 1140]; Silvester @ Silver v. State of Kerala [2023 KHC 458]; Rajesh Kumar J. v. Central Bureau of Investigation, Ekm and another [2021 KHC 692]). Without invoking or availing any of the said alternate options available, the petitioner had rushed to this Court by filing this writ which is an extraordinary remedy. On the said count of maintainability itself, the learned Government Pleader seeks to dismiss the Writ Petition. Coming to the merits of the matter, it is submitted by the learned Government Pleader that the petitioner has been using the prefix 'Dr.' to his name in the advertisement hoardings and boards claiming to be a specialist medical practitioner. In India as per the extant laws, a person who possesses WP(C) NO.190/2013 9 2025:KER:11812 a medical graduate degree recognised by a medical council alone has the right to treat a patient by exhibiting a name board with the prefix 'Dr.' to his name. The bachelor's degree in Physiotherapy is only a paramedical graduate degree. Petitioner obtained the said degree from Rajiv Gandhi University of Health Sciences, Karnataka, in the year 2006. That does not entitle the petitioner to address himself as a doctor or to add the prefix 'Dr.' to his name. A person qualified in physiotherapy cannot attend to any patient independently and he cannot prescribe medicines. He can attend to a patient only with the instruction and close supervision of a medical practitioner. Petitioner has apparently attended a 25-day course on Orthopedic Manual Therapy in Australia. On the said basis, he has been exhibiting his name board as a 'Manipulative Physiotherapist and Spine Specialist'. The same is misleading and illegal. Reliance is also placed on the dictum laid down by the Patna High Court in its judgment in Sarjoo Prasad and others v. The State of Bihar and others [(2003) SCC OnLine Pat 188]. It had been held therein that occupational therapists/ physiotherapists could not use the prefix 'doctor' in their names and that they could not prescribe allopathic WP(C) NO.190/2013 10 2025:KER:11812 medicines. Even if occupational therapy and physiotherapy have acquired the status of recognised disciplines in medical science, the practitioners thereof cannot practice modern scientific medicines. The learned Government Pleader submitted that no person can practice medicine in any State unless he possesses the requisite qualification and is enrolled as a medical practitioner on the State Medical Register. The consequences of the breach of these provisions are indicated in Sub-section 3 of Section 15 which stipulates a punishment of imprisonment for a term which may extend to one year or with a fine which may extend to one thousand rupees or with both. A person who does not have knowledge of a particular medical system of medicine, but practices in that system is a quack and a mere pretender to medical knowledge or skill, or to put it differently, a charlatan. Reliance is placed on the dictum laid down in this respect by the Hon'ble Supreme Court in Poonam Verma v. Ashwin Patel and others [(1996) 4 SCC 332]. Placing reliance on the judgment rendered by the Calcutta High Court in Sanjib Das v. State of West Bengal and others [2014 KHC 2010], it is contended by the learned Government Pleader that a person WP(C) NO.190/2013 11 2025:KER:11812 who has obtained a medical qualification in terms of the Indian Medical Council Act, 1956 and whose name appears in the register of medical practitioners as contemplated under the said Act of 1956, alone is entitled to use the prefix 'Doctor' or 'Dr'. To allow any other person to use such a prefix and to practise medicines would be against the scheme of the Indian Medical Council Act, 1956 and the Indian Medical Degrees Act, 1916. Relying on the dictum laid down by the Hon'ble Supreme Court in Medical Council of India and another v. State of Rajasthan and another [1996 KHC 1062] it is submitted that the basic qualification for registration as a medical practitioner is an M.B.B.S. degree and no person is entitled to be registered by the State Medical Board under the Medical Council Act, 1956 unless he has qualified himself in medicine. My attention is also invited to the judgment rendered by the High Court of Madras in Physiotherapists Development Association v. State of Tamil Nadu and another (W.P.No.21225 of 2014 dated 17.08.2022) wherein the challenge to the orders issued by the Government preventing the physio therapists from using the words 'Dr.' before their name was considered. Relying on the dictum laid down by the WP(C) NO.190/2013 12 2025:KER:11812 Hon'ble Supreme Court in Poonam Verma (supra), it was held that a physiotherapist only provides a supportive treatment of medicine and they cannot become part of an alternative system of medicine in order to confer the title of a 'Doctor' which allows them to independently practice, diagnose and treat patients. It was further held that the title 'Dr.' is only conferred on those persons who possess recognised qualifications as per the Indian Medicine Central Council Act and who are registered before the concerned State Medical Councils. As regards the claim of the petitioner to be a specialist in 'Manipulative Physiotherapist and Spine Specialist', relying on the dictum laid down by the Allahabad High Court in Neetu Rastogi Dr. v. Union of India and others [2017 KHC 3789] it was contended that a person cannot claim to be a specialist on the strength of a Diploma Certificate and such a certificate will not confer any authority of such person to claim the specialisation. Placing reliance on the judgment of the Hon'ble Supreme Court in Kerala Ayurveda Paramparya Vaidya Forum v. State of Kerala and others [2018 (3) KHC 185], it was submitted that the capacity to diagnose the disease would depend upon the fact as to whether WP(C) NO.190/2013 13 2025:KER:11812 the practitioner has the necessary professional skill to do so. Even a person who has acquired the prescribed diploma or degree from a recognised institution would not be entitled to practice medicine unless he is so registered under the provisions of the Indian Medicine Central Council Act. Referring to the dictum in Dr. A.K. Sabhapathy v. State of Kerala and others (AIR 1992 SC 1310) it is submitted that permitting a person to practice who does not possess the recognised medical qualification in the allopathic medical qualification for that system of medicine is inconsistent with the provisions of the Indian Medicine Central Council Act. As regards the definition of the term 'treatment' relying on the reference in The Medical Relief Society of South Kanara, Manipal v. Union of India [(1999) SCC OnLine Kar 77], it was submitted that it includes examination and diagnosis as well as application of remedies. The diagnosis of the disease may itself involve a prolonged investigation and may in turn constitute a part of the treatment to be given to the patient, it is contended. The petitioner with his qualifications is thoroughly incompetent to do such 'treatment'/ 'diagnosis'. The learned Government Pleader also WP(C) NO.190/2013 14 2025:KER:11812 placed reliance on the dictum laid down by this Court in State of Kerala v. Dr. C.K.Bharathan [1989 KHC 170]; and submits that it had been held therein that if the accused had made the name board with the questioned degrees, or if the accused got the prescribed slips printed describing himself as holder of such degrees, perhaps such acts would only have reached the stage of preparation. But, when he released such prescription slips to others or when he exhibited such names for others to read, he crosses the stage of preparation and transgresses into the realm of attempt. The learned Government Pleader thus submitted that the charge laid against the petitioner vide Ext.P1 is sustainable and he should stand trial. Any interference at this stage with the charge sheet is premature and a sufficient prima facie case has been made out against him to sustain the charge.

8. Having heard both sides in detail and perusing the documents produced, the questions that come to the fore for consideration are whether the Writ Petition filed by the petitioner seeking to quash Ext.A1 charge sheet is maintainable in law and if it is maintainable, whether a case has been made out to quash the WP(C) NO.190/2013 15 2025:KER:11812 same.

9. A petition under Section 482 of the Cr.P.C. though is the most frequently availed and preferred route while seeking to quash criminal proceedings or a charge sheet, the extraordinary jurisdiction vested in this Court under Article 226 is not a totally prohibited or closed option. In Neeharika Infrastructure (supra) the Hon'ble Supreme Court has pithily laid down the parameters that would be applicable and/or the aspects required to be considered by the High Court while entertaining a petition under Section 482 Cr.P.C. and/or under Article 226 inter alia while quashing a criminal charge. This Court has in Leby Sajeendran v. State of Kerala [2024 KHC Online 7029] while considering a Writ Petition filed seeking to quash a final report laid in a Section 309 IPC matter, held that though the jurisdiction of this Court under Article 226 is couched in wide terms and exercise thereof is not subject to any restrictions, the ideal course would have been to resort to Section 482 Cr.P.C. for quashing the final report. Taking note of the dictum as laid down in Neeharika Infrastructure (supra) which reiterates that invoking the jurisdiction under Article 226 is not an anathema to the prayer to WP(C) NO.190/2013 16 2025:KER:11812 quash a criminal charge sheet and the fact that this Writ Petition had been admitted way back in the year 2013, I feel it not proper to relegate the party to resort to the remedy under Section 482 Cr. P.C. at this point of time. Hence in the facts and circumstances of this case, this Writ Petition filed invoking Article 226 of the Constitution seeking to quash Ext. P1 charge sheet is treated as maintainable.

10. The next question to be considered is whether the petitioner has made a case for quashing Ext. A1 charge sheet. This in turn would require me to assess whether a prima facie case has been made out regarding the offences under which the petitioner is charged and then the crucial question whether the charge sheet laid is liable to be quashed. It is trite law that the power of quashing criminal proceedings should be exercised with great circumspection and that too in the rarest of rare cases. It is not justified for the High Court to embark upon an enquiry as to the reliability or genuineness or otherwise of the allegations made in the final report or complaint. [See State of West Bengal and others v. Swapan Kumar Guha and others [1982 KHC 419]; Pratibha Rani v. Suraj Kumar and another [1985 KHC 597]; State of U.P. v. O.P.Sharma [1996 KHC WP(C) NO.190/2013 17 2025:KER:11812 1061]; Rashmi Kumar v. Mahesh Kumar Bhada [1997 KHC 1337]; State of Kerala v. O.C.Kuttan [1999 KHC 172]; Mahendra K.C. v. State of Karnataka and another [2021 KHC 6665]; Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra and another (2021 (3) KHC 25)]. This Court had in PNB Housing Finance Ltd. v. State of Kerala [2023 (3) KHC 637] considered the scope and ambit of its own jurisdiction while exercising the powers to quash criminal proceedings and have concluded that finding on the veracity of a material relied on by the prosecution in a case where the allegations levelled by the prosecution discloses a cognizable offence is not a consideration for the High Court while exercising jurisdiction under Section 482 Cr.P.C. Though in the case at hand, the petitioner has invoked Article 226 and sought to quash the charge sheet, the circumspection and care to be exhibited while entertaining such a writ is the same or even more rigorous as that under Section 482 Cr.P.C. Petitioner has been charged under Section 419 of the IPC, Sections 38 and 39 of the Travancore Cochin Medical Practitioner's Act 1953, and Section 17 (4) of the Indian Medical Council Act, 1956. The offence of cheating has been WP(C) NO.190/2013 18 2025:KER:11812 defined in Section 415 of the Indian Penal Code. To constitute an offence under Section 419 of the IPC all the ingredients of Section 415 IPC must be present. The ingredients required to constitute an offence of cheating are as follows:

(i) There should be fraudulent or dishonest inducement of a person by deceiving him;
(ii) (a) the person so deceived should be induced to deliver any property to any person or to consent that any person shall retain any property; or (b) the person so deceived should be intentionally induced to do or omit to do anything which he would not do or omit if he were not so deceived; and
(iii) in cases covered by (ii) (b), the act or omission should be one which causes or is likely to cause damage or harm to the person induced in body, mind, reputation or property.

11. A roving inquiry into the facts and circumstances as revealed from the pleadings and documents put forth in this W.P.(C) so as to assess whether the ingredients constitute the offence of cheating and whether the evidence laid out in the charge sheet would be sufficient to meet the mandates of Section 415 of the WP(C) NO.190/2013 19 2025:KER:11812 Indian Penal Code is not contemplated in this writ proceedings under Article 226 of the constitution. Hence I forebear from appreciating the worth or the evidentiary value of the material produced along with the Writ Petition and the statement. Suffice it to say that it is trite law as confirmed by the precedents that as per the extant laws, a person who possesses a medical graduate degree recognised by a medical council alone has the right to treat a patient by exhibiting a name board with the prefix 'Dr.' to his name. Occupational therapists/physiotherapists could not use the prefix 'doctor' in their names and they could not prescribe allopathic medicines. a person who has obtained a medical qualification in terms of the Indian Medical Council Act, 1956 and whose name appears in the register of medical practitioners as contemplated under the said Act of 1956, alone is entitled to use the prefix 'Doctor' or 'Dr'. To allow any other person to use such a prefix and to practise medicines would be against the scheme of the Indian Medical Council Act, 1956 and the Indian Medical Degrees Act, 1916. The precedents as laid down in the Medical Council of India (supra), Poonam Verma (supra) Physiotherapists Development WP(C) NO.190/2013 20 2025:KER:11812 Association (supra) substantiate the above conclusion. Coming to the question of whether the petitioner had in the facts and circumstances put forth himself as a doctor to the public at large and had used office stationery and name board on the street with 'Dr' or 'Doctor' prefixed to his name as alleged in the charge sheet and whether he 'treated' patients putting forth himself as a doctor are all essentially question of fact to be decided on the merits of the evidence to be tendered in the matter. Though contentions for and against have been raised before me regarding the name board on the street and the office stationary allegedly used by the petitioner, I refrain from discussing the merits of the same. Though the law on the point as to whether a person who has not been conferred the title of a 'Doctor' after a prescribed course of study can use it as a prefix in his name as of right has been considered and laid down in the precedents as relied on by the learned Government Pleader as elaborated above, the applicability of the same to the facts of the case of the petitioner is a question that has to be answered on the basis of evidence to be tendered in trial.

In view of the above, I find that the contentions put forth by WP(C) NO.190/2013 21 2025:KER:11812 the petitioner to quash Ext.P1 charge sheet are not maintainable. The Writ Petition is dismissed. It is clarified that no observations have been made on the merits of the matter and the proceedings pursuant to Ext.P1 charge shall be conducted untrammelled by any observations made in this judgment. All interlocutory applications stand closed.

Sd/-

SYAM KUMAR V.M. JUDGE csl WP(C) NO.190/2013 22 2025:KER:11812 APPENDIX PETITIONER'S DOCUMENTS:

EXT.P1 : TRUE COPY OF THE CHARGE SHEET SUBMITTED BY THE KANNUR TOWN POLICE BEFORE THE JUDICIAL 1ST CLASS MAGISTRATE COURT - I, KANNUR EXT.P2 : TRUE COPY OF THE ARTICLE AVAILABLE IN WEBSITE. EXT.P3 : TRUE COPY OF THE PUBLIC NOTICE PUBLISHED BY THE INDIAN ASSOCIATION OF PHYSIOTHERAPISTS EXT.P4 : TRUE COPY OF RECENT ARTICLE PUBLISHED IN INDIAN EXPRESS AND AVAILABLE IN WEBSITE.
EXT.P5 : TRUE COPY OF THE DEGREE CERTIFICATE DATED 03.03.2006 AWARDED TO THE PETITIONER IN THE 8TH CONVOCATION OF RAJIV GANDHI UNIVERSITY OF HEALTH SCIENCES, KARNATAKA EXT.P6 : TRUE COPY OF THE CERTIFICATE ISSUED TO THE PETITIONER BY THE INDIAN ASSOCIATION FOR PHYSIOTHERAPIST EXT.P7 : TRUE COPY OF THE CERTIFICATE UNDER THE SCHEME EDUCATION FOR HEALTH PROFESSIONALS IN MANUAL CONCEPT ISSUED BY THE CURTIN UNIVERSITY EXT.P8 : TRUE COPY OF THE CERTIFICATE IN SPINAL MANUAL THERAPY IN THE EDUCATION FOR HEALTH PROFESSIONALS PROGRAMME SPONSORED BY CURTIN UNIVERSITY OF TECHNOLOGY, PERTH, AUSTRALIA EXT.P9 : TRUE COPY OF ONE OF ARTICLES PUBLISHED IN THE INTERNET EXT.P10 : COPY OF THE JUDGMENT DATED 9.6.2011 AND MADE IN WP(C) NO.36941/2010 OF THIS COURT EXT.P11 : TRUE COPY OF THE INTERIM ORDER DATED 26.12.2012 IN WP(C) NO.22347/2012 OF THIS COURT WP(C) NO.190/2013 23 2025:KER:11812 EXT.P12 : TRUE COPY OF THE RELEVANT PAGES OF MHATMAGANDHI UNIVERSITY REGULATION SCHEME AND SYLLABUS FOR BACHELOR OF PHYSIOTHERAPY EXT.P13 : TRUE COPY OF THE LETTER ISSUED BY THE MEDICAL COUNCIL OF INDIA DATED 29.9.1994 EXT.P14 : TRUE COPY OF THE RELEVANT PAGE OF MODEL CURRICULUM HANDBOOK IN PHYSIOTHERAPY ISSUED BY THE MINISTRY OF HEALTH AND FAMILY WELFARE ALLIED HEALTH SECTION 2015-2016.

EXT.P15 : TRUE COPY OF TEH CERTIFICATE OF REGISTRATION ISSUED BY KERALA DENTAL COUNCIL EXT.P16 : TRUE COPY OF THE CERTIFICATE OF REGISTRATION ISSUED BY TRAVANCORE COCHIN MEDICAL COUNCIL FOR INDIAN SYSTEM OF MEDICINE.

EXT.P17 : TRUE COPY OF THE EMAIL COMMUNICATION DATED 2.5.2018 EXT.P18 : TRUE COPY OF THE COMMUNICATION DATED 23.05.2016 ISSUED BY REGIONAL PASSPORT OFFICE, KOZHIKODE ANNEXURE A1 : TRUE COPY OF THE RELEVANT PAGES OF PASSPORT BEARING NO.K0513335 DATED 21.11.2011 ISSUED BY REGIONAL PASSPORT OFFICE, KOZHIKODE ANNEXURE A2 : TRUE COPY OF THE SHOWCAUSE NOTICE DATED 9.5.2016 ANNEXURE A3 : TRUE COPY OF THE REPLY DATED 21.5.2016 ANNEXURE A4 : TRUE COPY OF THE COMMUNICATION DATED 23.05.2016 ANNEXURE A : TRUE COPY OF THE COMMUNICATION DATED 23.5.2016 ISSUED BY REGIONAL PASSPORT OFFICER ANNEXURE B : TRUE COPY OF THE OFFER LETTER ISSUED BY M/S.VASAN EYE CARE, DUBAI, UAE WP(C) NO.190/2013 24 2025:KER:11812 RESPONDENTS' DOCUMENTS :

ANNEXURE R1(a) : TRUE COPY OF ENQUIRY REPORT