[Translator’s notes appear in square brackets]

[Personal information has been redacted.]


Honourable Chief Justice of the Islamic Revolutionary Court, City of Hamadan


With utmost respect we would like to bring to your attention:

On the eve of 28 Bahman 1359 [17 February 1981] a member of the prosecutor’s staff by the name of brother Rastandeh, accompanied by two of the Revolutionary Guards, presented a list of religious books and Baha’i newsletters to be provided by us for presentation to the Honourable Revolutionary Court and in this regard we would like to provide following statement:

  1. We respectfully draw to the attention of the Honourable Court the “Judicial Principle [concerning the production of] evidence by the claimant”,
  2. In your opinion, is it not contrary to Article 23 of the Constitution, which forbids inquisition, to demand [a copy] of religious books and to associate the contents of [those books] with our case?
  3. Baha’i newsletters from the year 1329 [1950-1951] etc. are from a period when the majority of the accused had not reached the age of maturity.
  4. With all due respect to the authorities, we regret we are not able to provide the requested newspapers and books as some have been out of print for more than thirty years.
  5. Even though there is no relationship between the given list and the subject of the charges, surely those who provided this list to the Prosecutor’s Office also have access to the items to which they are referring and if they have good intentions, they could also definitely provide them to the Prosecutor’s Office.
  6. We enclose the supplementary defence statement, hoping that with your due consideration this will clarify all aspects of the case.


Dear Ayatollah, we are praying and hoping that God assist you to you pass your judgement based on Islamic Justice, Human Rights, and legal precedence.

With utmost respect,

Dr. Firouz Naiemi [Signature]

Dr. Naser Vafaie [Signature]

Tarazollah Khozein [Signature]

Mohammad-Bagher Habibi [Signature]

Mohammad Habibi [Signature]

Hosein Motlagh [Signature]

Hosein Khandel [Signature]