[PROVISIONAL TRANSLATION FROM PERSIAN]
[Translator’s notes appear in square brackets]
[Personal information has been redacted.]
Dated ------ Month ------ 134------
Record registration number ------
Petition to the Court [Form]
Petitioner: Manijeh Hemmati
[Defending Authority]: Department of Education, City of Arak
Lawyer, or representative, or guardian ------
Claim sought: Reversal and annulment of order number 56200/5, issued on 9 Mehr 1358 [1 October 1979] by the Department of Education of Arak, and issuance of an order to permit [her] return to service and to be paid the salary and benefits along with compensation for losses.
Reason for the application, explanation of the petition, and statement of all legitimate reasons for the claim with indication of exclusivity:
The Almighty said: “O you who have believed, persistently stand firm in justice, witnesses for Allah, even if it be against yourselves” [Quran, 4:135].
I, the undersigned, holder of birth certificate number [redacted] issued in Arak, was employed by the Ministry of Education based on official order number 10280 - dated 28 Esfand 1352 [18 March 1974 ]. Since the beginning of my employment until the issuance of the illegal order to be expelled and cut off from service, I have paid my [pension contributions] and have engaged in carrying out my duties with utmost trustworthiness. Unfortunately, the authorities, contrary to religious standards and the law, and by enforcing prejudices that can in no wise be considered in line with the luminous religion, have trampled on all relevant principles and have ended my service as an official employee of the government without any fault on my part.
In the Islamic government, enforcement of the teachings and laws of the Holy Quran are, no doubt, incumbent upon all people; no one can be deprived of their basic social rights based on their religious beliefs, as stated in the unequivocal verse, “There shall be no compulsion in [acceptance of] religion. The right course has become clear from the wrong” [Quran-2:256], and “For you is your religion, and for me is my religion [Quran-109:6].” I am a believer in the truth of the Great Messenger and the Pure Imams, peace be upon Them. In addition, as the esteemed court is aware, the leader of the revolution and the respected ayatollahs have repeatedly stated and clearly announced, as stated in the aforementioned unshakable verses, that all religious minorities, whether officially recognized or not, are entitled to full social rights under the Islamic government. There is no doubt that the religious decrees of these respected ayatollahs must be followed. In addition, the Constitution of the Islamic Republic, in Article 14, has forbidden investigation into individual beliefs of the people of the country and, based on this principle, all individuals in the country have equal rights before the law.
In closing, I wish to state that the government of Iran is a signatory to the Universal Declaration of Human Rights, and the rights of individuals can in no way be violated or taken away from them due to their religious beliefs, race, etc. Therefore, it is clear that the petitioned department has, illegally and contrary to all religious and legal standards, undertaken to issue an order to expel me—official employee of the government. In view of all of the above statements, I request that you review this matter and direct that that order be revoked, return me to my service, and pay all aspects of my lawful wages.
The evidence consists of:
- Two notarized copies of the illegal order of expulsion from service.
- My personnel file at the Department of Education, which speaks to the manner of my employment, service record, lawful salary and benefits, payment of [pension contributions] and the losses sustained. If needed, please provide an authorization for me to obtain these documents from my personnel file and present them to you.
Respectfully, Manijeh Hemmati
Place to attach stamp
- Name of the agent responsible for notice.
- Date of delivery of the petition to the agent.
- Referring the review of the case
- Time of written response (the summary of Article 26 must be read and [the petitioned authority] must respond to the petitioner within ten days after receiving the petition. It should attach its reasons and documents according to Article 5, and should consider Articles 8 to 11, in addition to item 7 of Article 5 of Article 37 (sic). If the response to the petitioner is not received by the court by the end of the tenth day, the court will attend to the request of the petitioner in absentia and will issue its judgement.)
- Date of notice given to the petitioned authority.
[Administrative fees were paid]