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A/HRC/WGAD/2026/9

Opinion No. 9/2026 concerning Reza Khandan Heris (Islamic Republic of Iran)

UNO-Arbeitsgruppe über willkürliche Inhaftierung (WGAD) · 2026-04-01 · en UN

Opinion; Subjects: IRAN (ISLAMIC REPUBLIC OF), ARBITRARY DETENTION; [WGAD: UNO-Arbeitsgruppe über willkürliche Inhaftierung, willkürliche Haft; Groupe de travail sur la détention arbitraire; Gruppo di lavoro sulla detenzione arbitraria]

Volltext (verifizierbarer Originaltext)

GE.26-05615 (E) 040526 050526

Human Rights Council

Working Group on Arbitrary Detention

Opinions adopted by the Working Group on Arbitrary

Detention at its 105th session, 23 March–1 April 2026

Opinion No. 9/2026 concerning Reza Khandan Heris (Islamic Republic

of Iran)*

1.

The Working Group on Arbitrary Detention was established in resolution 1991/42 of

the Commission on Human Rights. In its resolution 1997/50, the Commission extended and

clarified the mandate of the Working Group. Pursuant to General Assembly resolution 60/251

and Human Rights Council decision 1/102, the Council assumed the mandate of the

Commission. The Council most recently extended the mandate of the Working Group for a

three-year period in its resolution 60/8.

2.

In accordance with its methods of work,1 on 27 October 2025 the Working Group

transmitted to the Government of the Islamic Republic of Iran a communication concerning

Reza Khandan Heris. The Government replied to the communication on 16 December 2025.

The State is a Party to the International Covenant on Civil and Political Rights.

3.

The Working Group regards deprivation of liberty as arbitrary in the following cases:

(a)

When it is clearly impossible to invoke any legal basis justifying the

deprivation of liberty (as when a person is kept in detention after the completion of his or her

sentence or despite an amnesty law applicable to him or her) (category I);

(b)

When the deprivation of liberty results from the exercise of the rights or

freedoms guaranteed by articles 7, 13, 14, 18, 19, 20 and 21 of the Universal Declaration of

Human Rights and, insofar as States Parties are concerned, by articles 12, 18, 19, 21, 22, 25,

26 and 27 of the Covenant (category II);

(c)

When the total or partial non-observance of the international norms relating to

the right to a fair trial, established in the Universal Declaration of Human Rights and in the

relevant international instruments accepted by the States concerned, is of such gravity as to

give the deprivation of liberty an arbitrary character (category III);

(d)

When asylum-seekers, immigrants or refugees are subjected to prolonged

administrative custody without the possibility of administrative or judicial review or remedy

(category IV);

(e)

When the deprivation of liberty constitutes a violation of international law on

the grounds of discrimination, based on birth, national, ethnic or social origin, language,

religion, economic condition, political or other opinion, gender, sexual orientation, disability

or any other status, that aims towards or can result in ignoring the equality of human beings

(category V).

* Miriam Estrada Castillo did not participate in the discussion of the case.

1 A/HRC/36/38.

United Nations

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General Assembly

Distr.: General

5 May 2026

Original: English

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1.

Submissions

(a)

Communication from the source

4.

Reza Khandan Heris is a national of the Islamic Republic of Iran. He resided in Tehran

and was 60 years old at the time of his arrest.

5.

Mr. Khandan Heris is a graphic designer and human rights defender. He is married to

a human rights lawyer and activist, who was subject of the Working Group’s opinion

No. 21/2011, Nasrin Sotoudeh.

6.

For decades, Mr. Khandan Heris advocated against compulsory veiling laws and the

death penalty in the Islamic Republic of Iran. He has been a consistent supporter of, and

collaborator in, the work of his spouse. He gained international prominence when he took to

social media and began publicly campaigning for his wife, following her arrest.

7.

In 2018, as part of a campaign to show support for women protesting against the

compulsory veiling laws, Mr. Khandan Heris began producing pins that read “I object to the

compulsory hijab”. These pins reportedly became a global symbol of the country’s women’s

rights movement.

(i)

Context

8.

Mr. Khandan Heris and one of his colleagues were originally arrested in September

2018 for producing and distributing the pins, and for posting online updates about

Ms. Sotoudeh’s arrest which had occurred in June 2018. Mr. Khandan Heris was imprisoned

for 111 days before being released in December 2018 due to the health impact of a hunger

strike that he was undertaking.

9.

Mr. Khandan Heris and his colleague attended the initial court session, but refused to

attend the following hearings, in protest. At the start, the court rejected the lawyers of the

defendants’ choosing, indicating that they would have to either accept court-appointed

lawyers or forgo legal representation. After much insistence and pressure, the court ultimately

accepted the lawyers but reportedly subjected them to harassment and threats.

10.

On 22 January 2019, both men were sentenced in absentia by Branch 15 of the Tehran

Revolutionary Court to six years of imprisonment, five of which were enforceable, for

“gathering and colluding with the intention of committing a crime against national security”,

and to one year of imprisonment on the charge of “propaganda activities against State”.

Mr. Khandan was also banned from leaving the country or engaging in online activities for

two years. However, Mr. Khandan Heris’s sentence was not carried out. As Mr. Khandan

Heris’s wife was also detained at the time and the couple had two minor children, his lawyer

applied for bail, which was granted.

11.

In February 2023, Mr. Khandan Heris was summoned to appear within 30 days for

the execution of his sentence, weeks after his spouse called for the release of Mr. Khandan

Heris’s colleague, whose life was in danger following a hunger strike. The summons was not

enforced at that time.

12.

The source also informs the Working Group about the discovery online of a leaked

letter indicating that the charges against Mr. Khandan Heris had been dropped and his case

had been closed. However, neither Mr. Khandan Heris nor his legal team were notified of the

closure of the case. While unaware of this important fact, Mr. Khandan Heris’s lawyer filed

a “resumption of proceedings” before the Court of Appeals on 25 September 2024, which

resulted in a reduction of the 2019 sentence from five years of imprisonment to four years,

one month and 10 days, of which three years and six months are enforceable.

(ii)

Arrest and detention

13.

On 13 December 2024, Mr. Khandan Heris was arrested again at his residence by the

Security Police. At the time, he and a friend were in the parking lot of their apartment

building, working on a home project. The officers claimed that he was being arrested for

traffic violations. When Mr. Khandan Heris’s spouse asked to see the warrant, it was

discovered that the warrant made no mention of any such violations. Instead, the warrant

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produced, issued by the Security Prosecutor’s Office, gave “gathering and colluding with the

intention of committing a crime against national security” (art. 610 of the Islamic Penal

Code), “propaganda activity against the Islamic Republic of Iran” (art. 500 of the Islamic

Penal Code) and “encouraging people in society to engage in corruption and prostitution”

(art. 639 of the Islamic Penal Code) as the reasons for Mr. Khandan Heris’s arrest.

14.

As Mr. Khandan Heris was being arrested, his spouse asked the officers if they would

let him say goodbye to his child. They agreed, but when she returned with the child, the

officers had already left with Mr. Khandan Heris. Mr. Khandan Heris’s wife then went to

Janat Abad Police Station, where Mr. Khandan Heris was being held, however she was

refused entry as she does not wear a hijab.

15.

The following morning, on 14 December 2024, Mr. Khandan Heris was brought to

the prosecutor at the court in Evin Prison, where he was interviewed. He was then transferred

to prison quarantine, where he stayed for nine days with no outside contact. The source notes

that the day of his most recent arrest coincided with the enactment of the country’s new law

imposing harsher punishments on women and girls who did not wear the hijab, which

Mr. Khandan’s spouse had forcefully criticized.

16.

Mr. Khandan Heris’s wife has not been authorized to see her husband due to her

refusal to wear a headscarf. When Mr. Khandan Heris’s child attempted to visit Mr. Khandan

Heris on 29 January 2025, he was reportedly beaten by six prison officers, handcuffed, and

charged with “destruction of government property”, “insulting government officers” and

“resisting government officials”. This incident has greatly affected Mr. Khandan Heris’s

child and family.

17.

Mr. Khandan Heris’s detention has taken place under severe prison conditions that

have amplified challenges to his physical and mental health. Amidst overcrowding,

unsanitary conditions, being placed in solitary confinement and having communication with

his family severed, the detention has reportedly left Mr. Khandan Heris isolated and

vulnerable.

18.

Furthermore, with the escalating tensions between Iran (Islamic Republic of) and

Israel, and a conflict in June 2025, Mr. Khandan Heris and other inmates sent a letter on

13 June 2025 to the head of the judiciary requesting him to apply Supreme Judicial Council

resolution No. 211 dated 23 Dey 1365 (13 January A.D. 1987), which stipulates that

whenever wartime conditions arise and endanger prisoners’ lives, it is necessary for

prosecutors to review the situation of prisoners and proceed with accepting conversion of

bail, conditional release, and similar measures. The letter further cited articles 197 and 201

of the executive regulations of the Prison Organization, and the country’s security and

correctional measures, as provisions supporting the authority of the head of the judiciary to

grant leave to eligible prisoners. Despite the letter, and a meeting with prison officials, no

action was taken by the prison administration or the judiciary.

19.

On 23 June 2025, when Evin Prison was bombed, 71 people in and around the prison

were reportedly killed, including inmates. Mr. Khandan Heris, along with the other prisoners

detained for political reasons, was transferred to Tehran’s Fashafoyeh Prison, where

conditions are reportedly worse. The transfer occurred without any clear indication or

announcements, in the middle of the night. Prisoners were reportedly chained together in

pairs, and even though many of them were wounded or in poor physical condition, none were

taken to a hospital. The conditions in Fashafoyeh Prison include severe water shortages,

overcrowding, lack of hygiene, heavy pollution and frequent verbal and physical abuse.

20.

After 45 days in that prison, Mr. Khandan Heris was transferred back to the

still-damaged Evin Prison, where he remains to date.

(iii)

Legal analysis

21.

The source submits that the detention of Mr. Khandan Heris is arbitrary, falling under

categories I, II, III and V of the Working Group.

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a.

Category I

22.

The source recalls that the Working Group has found detention to be arbitrary where

the law justifying the deprivation of liberty is extremely vague and lacks the requisite degree

of precision and legal certainty, leading to deprivation of liberty which is unreasonable or

unnecessary.2 The Working Group continuously expresses concern under category I about

criminal charges that “might allow an excessively broad interpretation of its provisions due

to their vagueness … resulting in unjustified and arbitrary criminalization of the legitimate

exercise of the right to freedom of expression”.3

23.

Mr. Khandan Heris was convicted under article 500 (“propaganda activity against the

Islamic Republic of Iran”) and article 610 (“gathering and colluding with the intention of

committing a crime against national security”) of the Islamic Penal Code. It is argued that

due to the vague, open-ended application of these legal provisions, Mr. Khandan Heris could

not have known that his actions would amount to criminal conduct. Moreover, the source

notes that in 2012, the Special Rapporteur on the situation of human rights in the Islamic

Republic of Iran submitted a report to the Human Rights Council describing these provisions

as “vaguely defined” and noting that they “contravene international human rights law and

unduly limit freedom of expression, association and assembly”.4

24.

Furthermore, the Working Group found in another case regarding the Islamic

Republic of Iran that the above-mentioned legal provisions were not consistent with the

Universal Declaration of Human Rights or the Covenant5 and that both article 500 and

article 610 of the Islamic Penal Code “are so vague and broad that they could … result in

penalties being imposed on individuals who had merely exercised their rights under

international law”.6 The determination of what constitutes an offence under these provisions

appears to be left entirely to the discretion of the authorities, notes the source. In 2019, the

Working Group found that the vagueness and broadness of article 500 and other provisions

of the Islamic Penal Code made it impossible to invoke a legal basis for deprivation of

liberty,7 and were therefore incompatible with article 15 (1) of the Covenant and article 11 (2)

of the Universal Declaration of Human Rights.

25.

According to leaked documents, Mr. Khandan Heris’s case was closed due to an

amnesty that was never notified to Mr. Khandan Heris and his lawyers. In this regard, the

authorities appear also to be in violation of article 14 (7) of the Covenant, as Mr. Khandan

Heris is being punished for an offence for which he has already been convicted and granted

amnesty. The Working Group has found that postponement of one’s release from prison after

being amnestied or pardoned cannot be justified under international law. 8 The Working

Group also noted, in that instance, that deprivation of liberty subsequent to the date on which

an individual should have been released after being amnestied is arbitrary and in

contravention of article 9 of the Universal Declaration of Human Rights.9

b.

Category II

26.

Mr. Khandan Heris was detained due to his production and distribution of “I object to

the compulsory hijab” pins. The source recalls that article 19 (1) and (2) of the Covenant and

article 19 of the Universal Declaration of Human Rights guarantee freedom of opinion and

expression. Specifically, this right includes the freedom to impart information and ideas of

all kinds, regardless of frontiers, either orally, in writing or in print, in the form of art, or

through any other media of a person’s choice. According to the Human Rights Committee,

this right includes the right to express dissenting political opinions, the right to participate in

discussions on human rights and the right to comment on public affairs. Importantly, the

Committee explains that article 19 (2) also safeguards the means of dissemination through

2 Opinion No. 8/2017, para. 36.

3 Opinion No. 20/2017, para. 35.

4 A/HRC/19/66, para. 13.

5 Opinion No. 19/2018, paras. 30 and 31.

6 Ibid., para. 33.

7 Opinion No. 32/2019, para. 31.

8 Opinion No. 7/2004, para. 9.

9 Ibid., para. 10.

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which expression is shared, including “books, newspapers, pamphlets, posters, banners, dress

and legal submissions”.10 The pins that Mr. Khandan Heris produced and distributed are

clearly protected by this right.

27.

The right to freedom of opinion and expression has limitations under international

law; however, as the Human Rights Committee emphasizes, these restrictions “may never be

invoked as a justification for the muzzling of any advocacy of multiparty democracy,

democratic tenets and human rights”. 11 For a State to legitimately restrict expression,

restrictions must adhere to a three-part test: they must be provided by law, they must only be

imposed to protect a legitimate interest recognized under international law and they must

conform to the tests of necessity and proportionality.12

28.

The restriction of Mr. Khandan Heris’s expression is not provided for by law. The

source notes that nowhere under international law is the distribution of political pins a crime

or evidence of a crime for which detention can be imposed. While the State contends that

these actions amounted to propaganda under article 500 of the Islamic Penal Code, several

United Nations bodies have raised concerns about this law, indicating that “prosecutors and

revolutionary courts have systematically used these laws to target, harass and imprison

peaceful protesters”, in violation of international law.13

29.

Furthermore, the restriction of Mr. Khandan Heris’s expression was not imposed to

protect a legitimate interest, nor was it necessary or proportional. Article 19 (3) of the

Covenant allows for limitations of expression if they are for the following aims: respect for

the rights or reputations of others, and the protection of national security, public order and

public health or morals. The authorities have argued that national security is their legitimate

aim, however the source notes that there is no link between the aim and application of the

law – detaining a person for sharing political pins is not necessary for the protection of

national security.

30.

The failure of the authorities to identify any evidence linking Mr. Khandan Heris’s

distribution of pins to any national security threat demonstrates manipulation of the law to

suppress dissenting views. The Human Rights Committee emphasizes that arresting,

torturing, or threatening the life of a human rights defender never meets the “necessity” test.14

Ultimately, if a State restricts expression on legitimate grounds, “it must demonstrate in

specific and individualized fashion the precise nature of the threat, and the necessity and

proportionality of the specific action taken, in particular by establishing a direct and

immediate connection between the expression and the threat”.15 The State cannot identify a

legitimate threat posed by Mr. Khandan Heris, nor a legitimate justification for his detention.

31.

The Human Rights Council has opined that restricting the following is not compatible

with any limitations on article 19 (3) of the Covenant: discussion of government policies,

political debate, reporting on human rights and government activities, political activities,

peaceful demonstrations, and the expression of opinion and dissent.16 The source thus also

claims that the detention of Mr. Khandan Heris also constitutes an undue restriction on his

right to freedom of peaceful assembly and association. Freedom of peaceful assembly and

association are guaranteed by articles 21 and 22 (1) of the Covenant and article 20 (1) of the

Universal Declaration of Human Rights.

32.

For the past decade, Mr. Khandan Heris has been an avid participant in the work of

his spouse, who is a globally recognized human rights defender, lawyer, and figure in the

women’s rights movement in the Islamic Republic of Iran. The source contends that

Mr. Khandan Heris’s detention directly resulted from his association with and participation

in the women’s rights movement. Moreover, it is submitted that his arrest sends a broader

message to the movement, by signalling that those who challenge the State are at risk of

reprisal.

10 Human Rights Committee, general comment No. 34 (2011), paras. 11 and 12.

11 Ibid., para. 23.

12 Ibid., para. 22.

13 A/HRC/31/26, para. 29; and opinion No. 19/2018, paras. 30 and 31.

14 Njaru v. Cameroon (CCPR/C/89/D/1353/2005), para. 6.4.

15 Human Rights Committee, general comment No. 34 (2011), para. 35.

16 Human Rights Council resolution 12/16, para. 5 (p) (i).

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33.

With regard to his right to the freedom of assembly, Mr. Khandan Heris’s distribution

of pins occurred in the context of the widespread protests of 2018 – an affirmation that his

actions constituted participation in a peaceful assembly. The Human Rights Committee

explains that symbols used during protests, such as flags, uniforms, signs and banners, should

be regarded as legitimate forms of expression. 17 The source argues that the pins that

Mr. Khandan Heris distributed fall within these protections.

34.

The source argues that although the right to freedom of peaceful assembly and

association is not absolute, Mr. Khandan Heris’s exercise of his right did not exceed the

limitations set forth in the Covenant. It recalls that on multiple occasions, the Working Group

has found that belonging to a human rights organization and forming part of a group that

counters the Government constitute legitimate exercise of the right to association enshrined

in the Covenant and Universal Declaration of Human Rights.18

35.

Furthermore, the source notes that Mr. Khandan Heris was detained on the very day

that a new law relating to the mandatory hijab mandate was set to be enacted – a law against

which both Mr. Khandan Heris and his wife were planning to take a peaceful initiative.

According to the source, this context illustrates the authorities’ motivation to detain him in

retaliation for their advocacy and influence in the Iranian women’s rights movement.

36.

Finally, the source contends that Mr. Khandan Heris was detained because of his

advocacy in pursuit of non-discrimination. It notes that fundamental freedoms are enabling

rights which allow citizens and human rights defenders to advocate for other freedoms and

rights enshrined in international law. As the Human Rights Council foregrounds, the rights

to freedom of assembly and association are critical for the full enjoyment of civil and political

rights and of economic, social and cultural rights. 19 Mr. Khandan Heris exercised these

fundamental freedoms with the overarching goal of combating the discriminatory practices

that Iranian women are subject to. Article 7 of the Universal Declaration of Human Rights

and article 26 of the Covenant affirm that all people are equal before the law and are entitled

to equal protection without discrimination. In this context, the General Assembly has

explicitly condemned “the discriminatory compulsory veiling laws and policies of the Islamic

Republic of Iran, which fundamentally undermine the human rights of women and girls”.20

The source submits that Mr. Khandan Heris’s distribution of pins, bearing the message

“I object to the compulsory hijab”, is a direct act of advocacy for realization of the substantive

right to non-discrimination and equal protection under the law. The targeting of Mr. Khandan

Heris constitutes, in effect, the targeting of this message of non-discrimination. As such, his

prosecution is not only an attack on his civil and political freedoms but is contrary to the

principles expressed in article 7 of the Universal Declaration of Human Rights and article 26

of the Covenant.

c.

Category III

37.

Mr. Khandan Heris was denied access to counsel of his choice. Under article 14 (3) (d)

of the Covenant, accused individuals are guaranteed a defence through legal assistance of

their own choosing. During his original sentencing in 2019, the court obstructed Mr. Khandan

Heris’s right to counsel of his own choice, throughout the proceedings.

38.

In this context, the source recalls that the court insisted that Mr. Khandan Heris must

be represented by a court-appointed lawyer, denying him any say in the selection of his

defence. As a result, for three months, Mr. Khandan Heris was unable to be represented

effectively by the lawyer of his choice, leaving him without effective legal representation

during that period. The source also recalls the Working Group’s assertion that persons

deprived of their liberty have the right to legal assistance by counsel of their choice at any

time during their detention, including immediately after apprehension, and must be promptly

informed of this right upon apprehension.21 According to the source, this right has been

violated, which follows a larger pattern of similar violations in the country. As discussed by

17 See the Committee’s general comment No. 34 (2011), para. 11.

18 Opinion No. 10/1993, para. 5 (h); and opinion No. 26/1992.

19 Human Rights Council resolution 15/21, p. 1.

20 General Assembly resolution 79/183, para. 15.

21 Opinion No. 81/2021, para. 105.

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the Independent International Fact-Finding Mission on the Islamic Republic of Iran, the “vast

majority of those detained” following the 2022 protests “had no access to a lawyer during the

entire investigation” and those who did were “routinely denied access to independently

appointed lawyers, including at trial”.22

39.

Following sustained pressure, the court finally accepted Mr. Khandan Heris’s lawyer.

He was, however, reportedly subjected to physical and verbal harassment when he appeared

at court for the trial. Following the trial, the lawyer reportedly faced continued targeting by

State authorities, putting his life at risk and forcing him to flee the country. As a result of the

State’s targeting of his lawyer, Mr. Khandan Heris was again denied effective access to legal

counsel of his choice, as the legal professional concerned was no longer present in the country

or able to represent him without risk of reprisal. The source submits that the intimidation,

threats and surveillance that Mr. Khandan Heris’s lawyer experienced directly undermined

this principle and Mr. Khandan Heris’s right to counsel under article 14 of the Covenant.

40.

Furthermore, Mr. Khandan Heris was denied access to a competent, independent and

fair tribunal. The source recalls that article 14 (1) of the Covenant provides that “everyone

shall be entitled to a fair and public hearing by a competent, independent and impartial

tribunal established by law”, which is reiterated in article 10 of the Universal Declaration of

Human Rights. In addition, the Body of Principles for the Protection of All Persons Under

Any Form of Detention or Imprisonment requires “a judicial or other authority” to have “the

strongest possible guarantees of competence, impartiality and independence”. The Human

Rights Committee has emphasized that the right to be tried by an independent and impartial

tribunal is an absolute right that may not be subject to any exception23 and that States must

ensure “the actual independence of the judiciary from political interference by the executive

branch” and protect “judges from any form of political influence in their decision-making”.24

41.

In this context, the source submits that the Iranian judiciary is heavily influenced by

the Government. In the revolutionary courts, the magistrate acts as both prosecutor and judge

in the same case, creating threats to fairness and impartiality. In 2024, the Independent

International Fact-Finding Mission on the Islamic Republic of Iran explained that the

criminal and revolutionary courts showed “manifest bias against protesters and real or

perceived political opposition”, thus creating a situation where human rights defenders would

inevitably be subject to detention.25 The source notes that the judge presiding over Branch 15

of the Tehran Revolutionary Court at the time of Mr. Khandan Heris’s sentencing was

sanctioned by the United States Department of the Treasury and the European Union due to

his harsh sentences on human rights activists and peaceful demonstrators.

42.

The source recalls that the Special Rapporteur on the situation of human rights in the

Islamic Republic of Iran has underscored that the absence of an independent judiciary, and

its consistent politicization, particularly through the use of the revolutionary courts, has been

a significant factor in the failure of accountability within the country. 26 The Special

Rapporteur further found that the judiciary, and specifically the revolutionary courts,

“persistently violate the rule of law, natural justice principles and the international human

rights obligations undertaken by the Islamic Republic of Iran”.27

43.

The source submits that as a human rights defender, Mr. Khandan Heris was targeted

by the court, which sought to criminalize his persistent dissent. Mr. Khandan Heris was

subjected to a revolutionary court, acting as a tool of repression and lacking independence,

impartiality and fair trial guarantees.

d.

Category V

44.

The Working Group has previously underlined that deprivation of liberty for reasons

of discrimination includes discrimination based on “a person’s status as a human rights

22 A/HRC/55/67, para. 57.

23 González del Río v. Peru (CCPR/C/46/D/263/1987), para. 5.2.

24 See the Committee’s general comment No. 32 (2007), para. 19.

25 A/HRC/55/67, para. 55.

26 A/HRC/55/62, para. 88.

27 Ibid.

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defender”, and in particular, “discrimination in the exercise of rights elaborated under

declaratory instruments such as the Declaration on Human Rights Defenders”.28

45.

Mr. Khandan Heris is being targeted and detained due to his status as a human rights

defender, who has consistently and peacefully advocated against mandatory hijab laws and

spoken in favour of women’s rights more broadly. Together with his wife, he has reportedly

been subject to retaliation for defending fundamental rights.

46.

It is argued that Mr. Khandan Heris’s ability to engage in this work is protected under

the Declaration on Human Rights Defenders. Specifically, under article 6 (b), Mr. Khandan

Heris is guaranteed the freedom to “publish, impart or disseminate to others views,

information and knowledge on all human rights and fundamental freedoms”. It is submitted

that the authorities infringed on this freedom by arresting and detaining Mr. Khandan Heris

for spreading human rights messaging via the pins.

47.

The source also submits that Mr. Khandan Heris’s arrest and detention is part of a

larger campaign to stifle human rights defenders. In November 2024, a month before

Mr. Khandan Heris’s arrest, the General Assembly expressed concern at “the use of

harassment and intimidation to silence individuals who oppose the Government of the Islamic

Republic of Iran, including human rights defenders and their families, such as through

arbitrary arrest and detention”.29

(b)

Response from the Government

48.

On 26 October 2025, the Working Group transmitted the allegations from the source

to the Government under its regular communications procedure. The Working Group

requested the Government to provide, by 26 December 2025, detailed information about the

current situation of Mr. Khandan Heris and to clarify the legal provisions justifying his

continued detention, as well as its compatibility with the obligations of the Islamic Republic

of Iran under international human rights law and in particular with regard to the treaties

ratified by the State. Moreover, the Working Group called upon the Government to ensure

the physical and mental integrity of Mr. Khandan Heris.

49.

In its response, received on 16 December 2025, the Government submits that

Mr. Khandan was arrested pursuant to an order issued by the competent judicial authority for

offences related to national security and propaganda activities against the State. His arrest

was carried out in accordance with legal procedures and with full respect for religious

principles after the arrest warrant was presented to him. The Government describes

allegations by certain media outlets hostile to the Islamic Republic of Iran, concerning the

manner of his arrest, as false and fabricated. Mr. Khandan Heris had been summoned on

several occasions to appear before the judicial authority but disregarded those summonses,

which ultimately necessitated the issuance of an arrest warrant.

50.

Mr. Khandan Heris has been sentenced, in accordance with the provisions of the

Islamic Penal Code, to three years and six months of imprisonment. Taking into account the

530 days of pardon granted, the sentence is scheduled to begin on 14 December 2024 and to

conclude on 3 September 2026. The judgment was issued in accordance with the law and

with full observance of all legal procedures, which included informing the accused of the

charges, and observing the right of access to a lawyer, the right to appeal and other relevant

safeguards.

51.

Despite benefiting from Islamic clemency and the application of a pardon,

Mr. Khandan has continued “anti-security activities” in prison by publishing false and

misleading letters and reports. He has refused to be presented to the judge or to attend

hearings by videoconference and has persistently declined to comply with lawful orders.

52.

The Government denies that Mr. Khandan Heris has been subjected to physical

mistreatment, characterizing the allegation as entirely false. It states that he has repeatedly

28 Opinion No. 45/2016, paras. 44 and 45.

29 General Assembly resolution 79/183, para. 20.

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resorted to violence in prison and caused damage but has been met with restraint by law

enforcement officers, with many disciplinary violations overlooked.

53.

Mr. Khandan Heris has received medical attention on several occasions: an

examination by an infectious diseases specialist for bronchitis; transfer to a specialized

medical centre on 24 May 2025 for gastrointestinal issues; thyroid function testing at an

external facility; and three authorizations for dental radiography, each of which he declined.

On one occasion, Mr. Khandan himself refused a transfer for gastrointestinal follow-up care.

54.

Mr. Khandan Heris is held in Evin Prison, with access to facilities and services

meeting, and in some cases exceeding, internationally declared standards. He has regular

access to family visits and to his lawyer. He was deprived of visitation rights (except for

visits with his lawyer and officials) for 21 days starting from 1 November 2025, as a

disciplinary sanction for disrupting prison order and refusing to comply with lawful

procedures; this measure has since concluded.

(c)

Additional comments from the source

55.

The Government’s response was submitted to the source, which provided its further

observations on 16 January 2026.

56.

The source reiterates that the legal basis for Mr. Khandan Heris’s arrest and conviction

is inconsistent with international human rights law. His prosecution under articles 500 and

610 of the Islamic Penal Code for producing and distributing pins inscribed with “I object to

the compulsory hijab” directly infringes his rights to freedom of expression, association and

peaceful assembly under articles 19 (1) and (2), 21 and 22 (1) of the Covenant and articles

19 and 20 (1) of the Universal Declaration of Human Rights.

57.

The source notes that the Government acknowledges the application of a “530-day

pardon” to Mr. Khandan Heris’s sentence. This admission confirms the existence of an

amnesty applicable to his case, consistent with the leaked document documenting the formal

closure of his case on grounds of amnesty. Despite the existence of this amnesty,

Mr. Khandan Heris was not informed of it and was subsequently rearrested and detained for

the same conduct, in violation of article 14 (7) of the Covenant.

58.

The Government has not addressed the substantive arguments regarding the

vagueness of articles 500 and 610, the Working Group’s prior findings concerning those

provisions, or the absence of any genuine link between Mr. Khandan Heris’s distribution of

pins and any national security threat. The source recalls that the Covenant may never be

invoked as a justification for suppressing advocacy of human rights, and that the State has

failed to demonstrate necessity or proportionality.

59.

The source underscores the heightened risk to Mr. Khandan Heris’s life arising from

the prison conditions, the bombing of Evin Prison, the transfer to Fashafoyeh Prison and the

ongoing deterioration of the security environment in the Islamic Republic of Iran.

2.

Discussion

60.

The Working Group thanks the source and the Government for their submissions.

61.

The Working Group has in its jurisprudence established the ways in which it deals

with evidentiary issues. In determining whether Mr. Khandan Heris’s detention is arbitrary,

the Working Group has regard to the principles established in its jurisprudence to deal with

evidentiary issues. If the source has established a prima facie case for breach of international

law constituting arbitrary detention, the burden of proof should be understood to rest upon

the Government if it wishes to refute the allegations. Mere assertions by the Government that

lawful procedures have been followed are not sufficient to rebut the source’s allegations.30

30 A/HRC/19/57, para. 68.

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(a)

Preliminary observations

62.

The Working Group notes that Mr. Khandan Heris has previously been the subject of

joint communications by special procedure mandate holders.31 In 2012, a communication was

addressed to the Government concerning a travel ban imposed on Mr. Khandan Heris in

connection with his public campaigning for the release of his wife. In 2018, another

communication was addressed expressing concern about the targeting of Mr. Khandan Heris

and his wife by the Iranian authorities on account of their human rights advocacy. Most

recently, in 2021, a further communication was addressed, raising concern that Mr. Khandan

Heris had allegedly been targeted by the authorities for his activities in support of his wife

and in protest against the country’s compulsory veiling laws. The Working Group observes

that the present case thus arises against a documented background of sustained special

procedures engagement regarding the repeated targeting of Mr. Khandan Heris by the

authorities, and that the concerns raised in those prior communications have not been

resolved.

(b)

Category I

63.

The source submits that Mr. Khandan Heris’s detention lacks any valid legal basis on

two distinct grounds. First, articles 500 and 610 of the Islamic Penal Code, under which he

was convicted, are so vague and overly broad that they cannot provide a lawful basis for

deprivation of liberty consistent with the principle of legality. Second, documents leaked by

the Edalat-e-Ali platform establish that Mr. Khandan Heris’s case was closed by way of

amnesty, a fact never communicated to him or his legal team; his continued detention for the

same conduct therefore violates the ne bis in idem guarantee under article 14 (7) of the

Covenant and article 9 of the Universal Declaration of Human Rights.

64.

With regard to articles 500 and 610 of the Islamic Penal Code, the Working Group

has on multiple occasions expressed serious concern about both provisions. In opinion

No. 19/2018, it found that they “are so vague and overly broad that they could result in

penalties being imposed on individuals who have merely exercised their rights under

international law”, and that these provisions are inconsistent with the Universal Declaration

of Human Rights and the Covenant.32 In opinion No. 32/2019 it went further, finding that the

vagueness and breadth of article 500 made it impossible to invoke a legal basis for

deprivation of liberty in that case, rendering detention under that provision incompatible with

article 11 (2) of the Universal Declaration of Human Rights and article 15 (1) of the

Covenant.33 These findings are directly applicable in the present case. Mr. Khandan Heris’s

conduct amounting to the production and distribution of pins reading “I object to the

compulsory hijab”, constitutes a paradigmatic exercise of the right to freedom of expression.

He could not have foreseen, on the basis of the text of articles 500 or 610 of the Islamic Penal

Code, that such peaceful advocacy would constitute criminal conduct. The Working Group

reiterates that the principle of legality requires that laws be formulated with sufficient

precision so that the individual can access and understand the law, and regulate his or her

conduct accordingly.34

65.

The Government asserts in general terms that Mr. Khandan Heris was convicted in

accordance with the provisions of the Islamic Penal Code and with due observance of legal

procedures. It does not contest the Working Group’s prior findings on the vagueness of

articles 500 and 610, nor does it provide any individualized explanation of how the

distribution of pins reading “I object to the compulsory hijab” could constitute an offence

under those provisions consistent with international standards. In the absence of such

explanation, the Working Group reaffirms its prior conclusions and finds that the deprivation

of liberty of Mr. Khandan Heris lacks a legal basis that meets the requirements of articles 3

and 9 of the Universal Declaration of Human Rights and article 9 of the Covenant.

31 See IRN 16/2021, IRN 11/2018 and IRN 18/2012. These communications are available from

https://spcommreports.ohchr.org/Tmsearch/TMDocuments.

32 Opinion No. 19/2018, para. 33.

33 Opinion No. 32/2019, para. 31.

34 See, for example, opinion No. 41/2017, paras. 98–101. See also opinion No. 62/2018, paras. 57–59;

and Human Rights Committee, general comment No. 35 (2014), para. 22.

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66.

The Working Group additionally notes with concern the question of amnesty.

Documents leaked by Edalat-e-Ali and submitted by the source establish that a decision was

issued by Branch 1 of the Execution of Criminal Sentences Court in District 33, closing

Mr. Khandan Heris’s case on the grounds of amnesty. The Government, in its reply,

acknowledges that a “530-day pardon” was applied to Mr. Khandan Heris’s sentence, without

explaining the relationship between this partial pardon and the case-closure document that

the source has adduced. Critically, the Government does not contest the core allegation that

Mr. Khandan Heris and his lawyers were never notified of any amnesty or pardon decision.

The principle of legality and the right to liberty require that any amnesty or pardon be

communicated to the person concerned and be given immediate effect. The Working Group

has previously held that continued detention following a release order or amnesty has no legal

basis justifying further deprivation of liberty and is thus arbitrary, in clear violation of

article 9 of the Universal Declaration of Human Rights and article 9 (1) of the Covenant.35

The Government has not offered an explanation that adequately refutes the conclusion that

the detention of Mr. Khandan Heris violates these norms.

67.

The Working Group therefore concludes that Mr. Khandan Heris’s deprivation of

liberty violates articles 3 and 9 of the Universal Declaration of Human Rights and article 9

of the Covenant, and is arbitrary under category I.

(c)

Category II

68.

The Working Group goes on to consider whether Mr. Khandan Heris’s detention

results from the exercise of rights guaranteed under the Universal Declaration of Human

Rights and the Covenant, as submitted by the source.

69.

The undisputed facts establish that Mr. Khandan Heris was arrested and convicted for

producing and distributing pins reading “I object to the compulsory hijab”, an activity directly

connected to advocacy of women’s rights and to the right to non-discrimination. This

constitutes expression in the form of political advocacy. The Human Rights Committee has

confirmed in its general comment No. 34 (2011) that article 19 (2) of the Covenant protects

the freedom to impart information and ideas of all kinds through any medium of one’s choice,

and that this encompasses the means of dissemination, including books, newspapers,

pamphlets, posters, banners, dress and legal submissions.36 The distribution of political pins

falls squarely within this protection.

70.

Permissible restrictions on freedom of expression are subject to a tripartite test under

article 19 (3) of the Covenant: they must be provided by law, serve a legitimate purpose, and

be necessary and proportionate. The Working Group has already found, under category I,

that articles 500 and 610 do not satisfy the “provided by law” requirement of sufficient

precision and legal certainty. In its reply, the Government has not identified any specific

national security threat posed by the distribution of pins, nor has it demonstrated a direct and

immediate connection between Mr. Khandan Heris’s expression and any harm to others. The

Human Rights Committee has stated that a State invoking national security as a basis for

restricting expression must demonstrate in specific and individualized fashion the precise

nature of the threat, and the necessity and proportionality of the specific action taken, in

particular by establishing a direct and immediate connection between the expression and the

threat.37 No such demonstration has been made here.

71.

The Working Group further notes that Mr. Khandan Heris’s arrest occurred on

13 December 2024, the date on which the new Law on Protection of the Family through the

Promotion of the Culture of Chastity and Hijab was due to enter into force and against which

his wife had been a leading public opposition figure, which indicates a retaliatory motivation.

The Human Rights Committee has made clear that article 19 (3) of the Covenant may never

be invoked as a justification for the muzzling of any advocacy of multiparty democracy,

35 Opinions No. 1/2021, para. 84; No. 8/2020, para. 53; No. 9/2011, para. 38; No. 7/2011, paras. 15–17;

No. 3/2011, para. 20; No. 3/2010, para. 6; No. 21/2007, para. 19; and No. 5/2005, para. 19; and

decisions No. 45/1995, para. 6; and No. 61/1993, para. 6. See also Human Rights Committee, general

comment No. 35 (2014), para. 22.

36 Human Rights Committee, general comment No. 34, para. 12.

37 Ibid., para. 35. See also Shin v. Republic of Korea (CCPR/C/80/D/926/2000).

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democratic tenets and human rights.38 The Government has not provided any explanation that

severs the arrest from this retaliatory context.

72.

The Working Group considers that Mr. Khandan Heris’s rights to freedom of peaceful

assembly and association are similarly engaged. His activities were carried out in the context

of the 2018 protest movement opposing compulsory veiling laws and reflected his sustained

association with the women’s rights movement led by Ms. Sotoudeh. The Working Group

recalls that it has previously found that belonging to a human rights organization and forming

part of a group that counters the government constitutes a legitimate exercise of the right to

association enshrined in articles 21 and 22 (1) of the Covenant. 39 The Government’s

invocation of national security to justify the suppression of peaceful political association

lacks the specificity required under articles 21 and 22 (1) of the Covenant.

73.

Having regard to the above, the Working Group concludes that Mr. Khandan Heris’s

deprivation of liberty results from the exercise of his rights to freedom of expression, peaceful

assembly and association guaranteed by articles 19, 20 and 21 of the Universal Declaration

of Human Rights and articles 19, 21 and 22 (1) of the Covenant, and is arbitrary under

category II.

(d)

Category III

74.

Given its finding that the detention of Mr. Khandan Heris was arbitrary under

category II, the Working Group emphasizes that no trial should have taken place.

Nevertheless, the trial took place, and therefore, the Working Group will proceed with

examination of the source’s submissions concerning the denial of fair trial rights.

75.

Regarding the right to counsel, article 14 (3) (d) of the Covenant guarantees the right

to communicate with and to be defended by counsel of one’s own choosing. In limited

scenarios, counsel can be assigned by the court, but for a court to assign a lawyer over the

wishes of the accused, the substitution must be based on “an objective and sufficiently serious

purpose”.40 The source submits that, during the proceedings against Mr. Khandan Heris

before Branch 15 of the Tehran Revolutionary Court, in 2019, the Court rejected his chosen

lawyers and required him to accept court-appointed representation. As a result, he was

deprived of effective legal representation by counsel of his choosing for a period of

approximately three months. When his chosen lawyer was ultimately accepted, the State

subjected that lawyer to persistent harassment and threats, ultimately forcing him into exile

and again depriving Mr. Khandan of effective legal assistance. The Government does not

address this specific allegation, noting broadly that the judgment was issued in accordance

with the law and with full observance of all legal procedures, including the right of access to

a lawyer.

76.

The Working Group recalls that all persons deprived of their liberty have the right to

legal assistance by counsel of their choice at any time during their detention, including

immediately after their apprehension, and such access is to be provided without delay.41

Furthermore, the Human Rights Committee emphasizes that the right to counsel depends on

lawyers being “able to advise and to represent persons charged with a criminal offence in

accordance with generally recognized professional ethics without restrictions, influence,

pressure or undue interference from any quarter”.42 The forced departure of Mr. Khandan

Heris’s lawyer following State harassment constitutes a serious violation of this principle.

The Working Group thus finds that Mr. Khandan Heris was denied access to legal assistance

following his arrest, in violation of his right to adequate time and facilities for the preparation

of his defence and to communicate with counsel, under article 14 (3) (b) of the Covenant.

38 Human Rights Committee, general comment No. 34, para. 23. See also Human Rights Committee,

Mukong v. Cameroon (CCPR/C/51/D/458/1991).

39 Opinions No. 73/2025, No. 54/2024 and No. 3/2024.

40 Human Rights Committee, general comment No. 32, para. 37.

41 A/HRC/45/16, paras. 51–53; see also the United Nations Basic Principles and Guidelines on

Remedies and Procedures on the Right of Anyone Deprived of Their Liberty to Bring Proceedings

Before a Court, principle 9 and guideline 8.

42 Human Rights Committee, general comment No. 32, para. 34.

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77.

The Working Group recalls that judicial independence is a sine qua non for the right

to a fair hearing, enshrined in article 10 of the Universal Declaration of Human Rights and

article 14 (1) of the Covenant, and that the Human Rights Committee has stated that the

requirement of competence, independence and impartiality of a tribunal in the sense of

article 14 (1) is an absolute right that is not subject to any exception.43 The Working Group

has repeatedly found that the revolutionary courts do not meet international standards of

independence or impartiality, and that their very operation itself creates a strong presumption

that an individual has not been tried by an independent and impartial tribunal. 44 In its

reasoning, the Working Group noted findings of the Special Rapporteur on the situation of

human rights in the Islamic Republic of Iran that the absence of an independent judiciary,

and its consistent politicization, particularly through the use of the revolutionary courts, has

been a significant factor in the failure of accountability within the country.

78.

In this context, the Working Group notes that Mr. Khandan Heris was convicted by

Branch 15 of the Tehran Revolutionary Court. According to the source, Mr. Khandan Heris’s

case was presided over by a judge known for harsh rulings in politically sensitive cases. The

source specifically notes that the judge has been sanctioned by both the United States of

America and the European Union for his alleged role in human rights abuses. 45 The

Government has not provided any information capable of rebutting these concerns. The

Working Group therefore concludes that Mr. Khandan Heris was not tried by an independent

and impartial tribunal, in violation of article 10 of the Universal Declaration of Human Rights

and article 14 (1) of the Covenant.

79.

The Working Group therefore finds that the violations of Mr. Khandan Heris’s right

to a fair trial are of such gravity as to give his deprivation of liberty an arbitrary character and

concludes that his detention is arbitrary under category III.

(e)

Category V

80.

The source submits that Mr. Khandan Heris’s deprivation of liberty is motivated by

discrimination based on his status as a human rights defender and his political opinion. It

recalls that, for decades, he has peacefully advocated against compulsory veiling laws and in

support of women’s rights, in close collaboration with his wife, and that his arrest occurred

on the precise day that a new repressive veiling law was to enter into force – a law that his

wife had been publicly opposing. The source contends that this targeting forms part of a

documented systematic campaign by the authorities against human rights defenders and their

families, and that Mr. Khandan Heris’s detention constitutes discrimination in the exercise

of rights elaborated under the Declaration on Human Rights Defenders, contrary to articles 2

and 7 of the Universal Declaration of Human Rights and articles 2 (1) and 26 of the Covenant.

81.

The undisputed facts establish that Mr. Khandan Heris has spent decades engaged in

human rights defence work, in particular in support of women’s rights and opposition to

compulsory veiling laws, in close collaboration with his wife, a recognized human rights

defender who has herself been subjected to arbitrary detention. His arrest occurred on the day

that a new veiling law was to come into force, which his wife had been actively opposing.

Multiple United Nations mechanisms, including the General Assembly, have documented the

country’s systematic targeting of human rights defenders and their families, with the General

Assembly expressing specific concern at repressive activities conducted by the Islamic

Republic of Iran to harm, silence and intimidate individuals who oppose the Government of

the Islamic Republic of Iran and who bring attention to human rights violations, including

human rights defenders, journalists, dissidents and their families.46

82.

The Working Group has previously considered cases involving women who have

expressed their opposition to compulsory wearing of the hijab in the Islamic Republic of

Iran.47 In his 2021 report, the Special Rapporteur on the situation of human rights in the

43 Human Rights Committee, general comment No. 32, para. 19. See also González del Río v. Peru,

para. 5.2.

44 See, among others, opinions No. 21/2023 and No. 53/2024.

45 Opinion No. 85/2021, paras. 86 and 87; No. 37/2023, para. 73; and No. 27/2025, para. 79.

46 General Assembly resolution 80/222, para. 21.

47 See opinions No. 15/2021, No. 54/2022, No. 21/2023 and No. 15/2025.

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Islamic Republic of Iran stated that the authorities continued to arrest and imprison women’s

rights advocates who had challenged compulsory veiling, on national security- and

morality-based charges.48 The Working Group further observes that the three prior special

procedure communications sent concerning Mr. Khandan Heris personally document a

consistent and escalating pattern of targeting by the authorities directed at him on account of

his human rights defence activities and his political opinion. That pattern, unremedied across

more than a decade despite repeated international engagement, is itself indicative of

discrimination based on political opinion and on his status as a human rights defender and

reinforces the conclusion that the present detention is motivated by those same discriminatory

grounds rather than by any legitimate law enforcement purpose. The Government has not

offered any information capable of rebutting this presumption.

83.

The Working Group therefore concludes that Mr. Khandan Heris’s deprivation of

liberty constitutes a violation of international law on grounds of discrimination based on his

status as a human rights defender and his political opinion, in violation of articles 2 and 7 of

the Universal Declaration of Human Rights and articles 2 (1) and 26 of the Covenant, and is

arbitrary under category V.

(f)

Concluding remarks

84.

The present case is one of several brought before the Working Group in recent years

concerning arbitrary detention in the Islamic Republic of Iran.49 The Working Group is

concerned that this might indicate a widespread or systemic practice of arbitrary detention in

the country. The Working Group underlines that States have the obligation not to engage in

acts that could constitute crimes against humanity and to prevent and punish them if they are

committed. The Working Group refers the present case to the Special Rapporteur on the

situation of human rights in the Islamic Republic of Iran, for appropriate action.

3.

Disposition

85.

In the light of the foregoing, the Working Group renders the following opinion:

The deprivation of liberty of Reza Khandan Heris, being in contravention of articles 3,

7, 9, 10, 19, 20 and 21 of the Universal Declaration of Human Rights and articles 9,

14, 19, 21, 22 and 26 of the International Covenant on Civil and Political Rights, is

arbitrary and falls within categories I, II, III and V.

86.

The Working Group requests the Government of the Islamic Republic of Iran to take

the steps necessary to remedy the situation of Mr. Khandan Heris without delay and bring it

into conformity with the relevant international norms, including those set out in the Universal

Declaration of Human Rights and the International Covenant on Civil and Political Rights.

87.

The Working Group considers that, taking into account all the circumstances of the

case, the appropriate remedy would be to release Mr. Khandan Heris immediately and accord

him an enforceable right to compensation and other reparations, in accordance with

international law.

88.

The Working Group urges the Government to ensure a full and independent

investigation of the circumstances surrounding the arbitrary deprivation of liberty of

Mr. Khandan and to take appropriate measures against those responsible for the violation of

his rights.

89.

The Working Group requests the Government to disseminate the present opinion

through all available means and as widely as possible.

48 A/HRC/46/50, para. 54.

49 See, for example, opinions No. 18/2013, No. 28/2013, No. 52/2013, No. 55/2013, No. 16/2015,

No. 44/2015, No. 1/2016, No. 2/2016, No. 25/2016, No. 28/2016, No. 50/2016, No. 7/2017,

No. 9/2017, No. 48/2017, No. 49/2017, No. 92/2017, No. 19/2018, No. 52/2018, No. 83/2018,

No. 32/2019, No. 33/2019, No. 20/2022, No. 46/2022, No. 54/2022, No. 82/2022, No. 21/2023,

No. 37/2023, No. 53/2024 and No. 15/2025.

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4.

Follow-up procedure

90.

In accordance with paragraph 20 of its methods of work, the Working Group requests

the source and the Government to provide it with information on action taken in follow-up

to the recommendations made in the present opinion, including:

(a)

Whether Mr. Khandan Heris has been released and, if so, on what date;

(b)

Whether compensation or other reparations have been made to Mr. Khandan

Heris;

(c)

Whether an investigation has been conducted into the violation of

Mr. Khandan’s rights and, if so, the outcome of the investigation;

(d)

Whether any legislative amendments or changes in practice have been made to

harmonize the laws and practices of the Islamic Republic of Iran with its international

obligations in line with the present opinion;

(e)

Whether any other action has been taken to implement the present opinion.

91.

The Government is invited to inform the Working Group of any difficulties it may

have encountered in implementing the recommendations made in the present opinion and

whether further technical assistance is required, for example through a visit by the Working

Group.

92.

The Working Group requests the source and the Government to provide the

above-mentioned information within six months of the date of transmission of the present

opinion. However, the Working Group reserves the right to take its own action in follow-up

to the opinion if new concerns in relation to the case are brought to its attention. Such action

would enable the Working Group to inform the Human Rights Council of progress made in

implementing its recommendations, as well as of any failure to take action.

93.

The Working Group recalls that the Human Rights Council has encouraged all States

to cooperate with the Working Group and has requested them to take account of its views

and, where necessary, to take appropriate steps to remedy the situation of persons arbitrarily

deprived of their liberty, and to inform the Working Group of the steps they have taken.50

[Adopted on 24 March 2026]

50 Human Rights Council resolution 60/8, paras. 6 and 9.