[PROVISIONAL TRANSLATION FROM PERSIAN]

 

[Translator’s notes appear in square brackets]

[Personal information has been redacted.]

 

File Number: -----

[Emblem]

The Judiciary 

Court of Administrative Justice

 

Referring the case to the Branch: -----

Signature of Administrative Justice: -----

Number and Date of Registration: -----

 

In the Name of God

Petition Form

Particulars of the Parties – Appellant:

Name and Surname: Laghaollah Baghaie

Name of the Father: Khodagholi

Profession: Maker of spectacles

Residence: [redacted]

Attorney for the Appellant: ------

Appellee: Department of Commerce of the City of Khomein

Subject of Grievance and Claim: Closure of the shop and sealing of business premises not sanctioned by law and requesting the re-opening [of business premises] - Description of the petition

Statement, Reasoning and Proofs: -----

The Honourable Chief Adjudicator of the Court of Administrative Justice

Respectfully, I, Laghaollah Baghaie, convey the following: According to the official licence number 890Ayn-Ta-16385/8/K, dated 8 Aban 1369 [30 October 1990], and the renewed occupational licence number /103/B, dated 22 Tir 1376 [13 July 1997], as the owner of the optical lenses dealership in the City of Khomein, established in 1360 [1981], I have been in this job for 17 years and my technical and disciplinary competence, as well as my place of business, have been approved by the competent authorities.

Recently, during a holiday, the Department of Commerce sealed my shop, with no court order or official permission. Despite numerous visits, I have not received any response. As I have neither committed any crime or illegal action, nor has anyone complained, and considering that all my necessary documents and permissions have been handed over to the Department of Health and they have issued me the permits based on those documents, the sealing of my shop by the Department of Commerce is not legally permissible; therefore, I request that you investigate the matter and issue the appropriate order.

Meanwhile, many of my documents, even my savings account books and customers’ glasses, are inside the shop and all my customers are left unattended. By having my shop sealed, I have found difficulties maintaining my livelihood. Please issue a temporary order to open and unseal the shop until the final judgment is determined.

Thank you in advance for your attention in this matter.

Also attached are: 1- A copy of business licence 2- A copy of licence to make optical lenses from the Ministry of Health, Treatment and Medical Education 3- A copy of my certification from Khomein law enforcement [police] department 4- A copy of my certification from Islamic Revolutionary Committee of Khomein city.

We seek success from God