[Translator’s notes appear in square brackets]

[Personal information has been redacted.]



[Judiciary of the Islamic Republic of Iran]

[First page:  complaint about employment, submitted to the Public Court of Tehran (Employment complaints)


Given Name: [Mrs.] Parvin, Surname: Edraki, Father’s name: Aminollah, Date of Birth: [redacted]

Place of Birth: [redacted], Position: Supervisor, Group: [redacted], Base: [redacted], Number of Personnel Department ---------, Place of employment: Hospital of Sorkhe-Hesar

Address of residence: [redacted], Claim: Cancellation of the order issued and return to work and the re-establishment of salary and entitlements from the time when the employee was terminated.


Legal articles used for referral: Article 14 of the Public Services Employment Act and Articles 3, 19, 22, 23, and 28 of the Constitution.


Documents used for referral: two pages - copy of order number [redacted]-[date;] [redacted]

Address of the respondent to the complaint: [redacted] Hospital of Sorkhe-Hesar.

Explanation of complaint (letter of complaint or authorised photocopy of documents for referral, to be sent in duplicate)


Respectfully, herewith are duplicate photocopies of the order for termination of employment. Number [redacted]-[ redacted] I bring to the attention of the respectable Head of the Court the facts provided below:


  1. I am from among the believers and followers of the Baha’i religion and in accordance with divine law and my conscience, I have the duty to uphold the principles of trustworthiness, truthfulness, chastity, purity, piety in all the affairs of my life and to believe in the rightfulness of all heavenly religions, including the sacred religion of Islam and the Quran, as verifiers between truth and falsehood, and believe in God and the immortality of the soul and the next world – all of which are principles of my beliefs. You will agree that, God forbid, if the Baha’i religion which uphold such principals is false, then all divine religions are likewise false.
  2. Clause, 2 Article 21 of the Declaration of Human Rights has recognised the equality of people in entering the Public Service and this has been recognised in section 28 of the Constitution of the Islamic Republic of Iran and in accordance with this principle, the government has the responsibility to provide for everyone, including Baha’is or others, to obtain employment on an equal basis in the private or public sectors.. Therefore, belief in the Baha’i religion, which is [not an officially recognized religion], cannot be an obstacle to prevent Baha’is from taking part in the Public Service and discharging their duties to this sacred land.
  3. Clause T Article 14 of the Public Services Employment Act indicates that one of the requirements for employment is having never being convicted on grounds of holding of corrupt beliefs.

Continued on page 2

Second Page

  • Firstly, according to legal doctrines and the agreement of jurists, under the law,  “corrupt beliefs” applies to political beliefs, and not to religious beliefs.


  • Secondly, under the criminal law of Iran there is no punishment for religious beliefs.


  • Thirdly, to issue an order for conviction on the grounds of corrupt beliefs, the subject should be heard in a legitimate court [of law] and after thorough legal procedure, a final order must be issued. I have to say that never have I been tried in any court regarding my beliefs so there has never been any [legal] decision regarding whether my beliefs are corrupt or good..


  1. According to Article 22 of Constitution of the Islamic Republic of Iran, people’s jobs are exempt from infringement unless this has been allowed by law. Undoubtedly, you are aware that to date no law has passed by the Islamic Consultative Assembly of Iran to give permission to the Ministry of Health to engage in such infringement [of the rights of citizens]. In addition, Article 23 of this law has emphatically prevented inquisition of anyone’s beliefs and has not given any permission for people’s beliefs to be [publicly] censured. Therefore, Circular number 7560 dated 10/10/1359-[31 December 1980] from the Ministry of Health, which contains an order that is clearly in contravention of the provisions of the Constitution is invalid.  The related order that was issued based on that directive is also in contravention of the [current] law.


  1. Pursuant to Clause TH, Article 114 of the Public Services Employment Act and Article 3, Clauses 9 and 14 and Article 19, 22, 23 and 28 of the Constitution of the Islamic Republic of Iran, I request cancellation of the [administrative] order issued and return to my employment and the re-establishment of my salary and entitlements from the time when they were terminated.


With thanks

Parvin Edraki