Registration Without License: AHPC’s Legal Failure

Introduction: The Crisis of Registration Without Licensing for Allied Health Professionals in Pakistan

Registration without license is a growing concern for Allied Health Professionals in Pakistan. While the Allied Health Professionals Council (AHPC) was established to regulate and support the profession, its current practice of issuing only registrations—while withholding licenses—is causing legal, economic, and professional harm. Many qualified individuals are left in limbo, labeled as “under supervision” without legal backing. This blog explores how registration without license not only violates the AHPC Act 2022 but also disrupts the careers of thousands across the country.

What Is the Difference Between AHPC Registration and a License to Practice?

AHPC Registration vs Professional License: Know the Legal Distinction

Registration is your official inclusion in AHPC records.
License is the legal authorization to practice independently in your professional domain.

Without a license, a registered professional cannot practice independently, especially under Punjab Healthcare Commission Act 2010, which treats such practice as illegal.

Why a License Matters: Legal and Career Impacts of Registration Without License

Employers often demand a valid license, not just registration.
Regulatory bodies can fine or prosecute registered-but-unlicensed practitioners as quacks.

Legal Action Against AHPC: The Case Study of Syed Asad ul Abbas Naqvi

Landmark Legal Battle: Fighting Against Registration Without License

In a historic case, Syed Asad ul Abbas Naqvi, a registered Allied Health Professional from Gujranwala, challenged AHPC for refusing to issue licenses despite receiving fees and fulfilling requirements. He filed complaints with the Federal Ombudsman, which ruled in his favor. AHPC, instead of complying, appealed to the President of Pakistan, who also dismissed their appeal.

Despite these legal victories, the AHPC Secretary continued delaying license issuance. Only after a final Implementation Wing complaint and contempt threat did AHPC issue licenses—but with an unlawful disclaimer: “Under Supervision.”

AHPC’s Illegal Categorization and Licensing Restrictions

Unlawful Categorization of Allied Health Professionals by AHPC

Category	Description
A	Graduate Degree (16+ years education)
B	Associate Degree (14 years)
C	Diploma Holders
D	Certificate Holders
E	Skilled Persons

Legal Issue:

The AHPC Act 2022 does not mention or allow categorization or labeling professionals as “under supervision.”
Sections 16(1) and 24(2) clearly state that any qualifying professional must be registered and licensed.

Real Consequences:

Diagnostic professionals are labeled “under supervision” despite having years of training.
Courts have received cases where those who legally challenged AHPC were still issued licenses with disclaimers—an act of retaliation.

Consequences of Withholding Licenses from Allied Health Professionals in Pakistan

Legal Vulnerability

Without a license, Allied Health Professionals are vulnerable to:

Prosecution under healthcare commission laws
Fines and FIRs for illegal practice

Economic Exploitation

Students pay for both registration and license.
Only registration is issued, resulting in financial loss and a waste of years of education.

Professional Stagnation

Labeled professionals cannot practice independently.
Appointments are made based on favoritism, not merit.

Misconceptions About Diagnostic Rights vs. Medical Practice

Some critics falsely claim that Allied Health Professionals are trying to practice as doctors. This is untrue.

What They Demand:

Not the right to prescribe medicine
Yes to the right to perform diagnostic procedures within their specialty (e.g., radiology, pathology, anesthesia)

This is aligned with international standards and the original AHPC Act’s intention.

What the Law Says: AHPC Act 2022 & Punjab Healthcare Commission Act 2010

AHPC Act 2022

Mandates registration and licensing for all qualified AHPs
No mention of categorization or “under supervision”

Punjab Healthcare Commission Act 2010

Practicing without a valid license is illegal
Health professionals must be registered and licensed to offer services

What Needs to Be Done

For AHPC:

Stop issuing licenses with unlawful disclaimers
Respect the Ombudsman and Presidential decisions
Define scope of practice by specialization—not category

For Students and Professionals:

Demand both registration and license
Know your rights under the AHPC Act
File complaints if rights are violated

FAQs: Real Questions from Allied Health Students & Professionals

Q1: I received registration but not a license. Can I work independently?

No. Under the law, you need both to legally practice.

Q2: Is “Under Supervision” a valid legal status?

No. There is no such status defined under AHPC Act 2022.

Q3: I paid for both license and registration. Can I file a legal complaint?

Yes. You can approach the Federal Ombudsman or file a civil claim.

Q4: How does this affect job opportunities in government and private sectors?

Negatively. Without a license, many employers will reject your application.

Q5: Is AHPC allowed to categorize professionals?

No. The AHPC Act makes no provision for such categories.

Conclusion: Your Rights Are Legal Rights—Fight for Them

The Allied Health Professionals in Pakistan deserve more than just hollow recognition. They deserve legal practice rights, fair treatment, and proper representation. The AHPC must stop undermining its own Act. If you’re a student, graduate, or seasoned professional, now is the time to demand justice.