[PROVISIONAL TRANSLATION FROM PERSIAN]
[Translator’s notes appear in square brackets]
[Personal information has been redacted.]
4 Azar 1369 [25 November 1990]
In the Name of God
The Esteemed Chief Justice of the Supreme Court
Subject: Request to appeal Court Order number 21025, dated 2 Khordad 1369 [23 May 1990], case reference 112/262/68, Branch 3 of Prosecutor’s Office in the Central Province. According to the above court order issued at that Branch, all of the belongings of the undersigned, Mrs. Shoaiyyeh Miraftab, and my brother Nasrollah Miraftab, were confiscated due to our travels abroad and our being Baha’is. Based on the following, this court order was issued contrary to the law and against the illumined Sharia:
1. According to the court order, the reason for the confiscation is that my brother and I are excluded from the protection of the Islamic Republic of Iran. This is against the law, as I am an Iranian citizen and have never renounced my citizenship of the Islamic Republic of Iran. That is why I returned to my country with my Iranian passport, issued at the Iranian embassy in London. If I spent a few years out of the country, it was to nurse my sick father; I returned to Iran after his passing. Moreover, I have never committed any crime nor taken any action contrary to the laws and regulations of the Islamic Republic of Iran, whether in or out of the country.
On the other hand, according to all laws, particularly the Constitution of the Islamic Republic of Iran, I must benefit from all the social rights of Iranian citizens. Since there is nothing in my file contrary to what I have said, nor has anything been proven against me, and since there is no such legal article that is documented by the Islamic Consultative Assembly, or the Judiciary of the Islamic Republic of Iran, it is certain that, since I did not withdraw myself from the protection of the Islamic Republic of Iran, and due to the lack of any legal documents in this case, the order has no legal basis. The order has legal flaws and is in violation of the law.
2. According to the current regulations, the issuance of any court order regarding confiscation of property must be approved by the National Supreme Court or the Supreme Court of Qom. This court order is not binding, due to its lack of approval by the said authorities; therefore, any action to enforce this court order [illegible] lacks legality and if an enforcement order is issued, it would be illegal and ineffective.
3. The very important point in this file is that since it was issued as a result of the owners’ absence and their being abroad, if the files were completed and sent to the commission of judges for the Execution of Imam [Khomeini]’s Order, issuance of the order should be by previous appointment and invitation by advertisement prior notice. But in my case, I must inform you that I was in Tehran in Khordad of 1369 [May 1990]. Unfortunately, no attention was paid to my petitions and letters or in-person requests. It is important to note that none of these were reflected in the file and such documents are missing in my file. Moreover, I have travelled abroad and returned many times during those years; this was an important matter in the issuance of the order and loss of my rights. Considering the fact that I was present, I cannot be considered a fugitive and unworthy of state protection; therefore, the court order will not be binding on me. I request that this order be revoked for investigation to establish the truth in this regard.
Considering the above, and the conditions in which the file was prepared, and my presence in the country at the time it was issued and enforced, as well as acceptance of my citizenship and nonexistence of any offence, and the fact that I have no other place to live nor do I have any other source of income, and as announced by the authorities, Baha’ism was not and is not considered a crime, I request an investigation and cancellation of the court order.
4 Azar 1369 [25 November 1990] [signature]