Methodology: Mapping the Suppression of Protesters in Iran
The documentation of Abdorrahman Boroumand Center for Human Rights (ABC) is inclusive. It documents all protest-related killings without discrimination based on gender, nationality, ethnicity, religion, or political affiliation or any other criteria. We strive to restore dignity to victims and their families, amplifying voices often silenced or ignored by formal judicial processes.
ABC prioritizes primary sources and strives to collect the best available information from multiple sources to understand the context of the protests and arbitrary killings and establish motives and patterns. We gather and verify data through trusted, credible sources, including first-hand testimonies from victims’ families, independent eyewitness accounts, and interviews with lawyers and other informed sources, and official records as well as published sources. Publicly accessible sources used include books and articles, published official reports of incidents, official statements, reports by the United Nations and governments, human rights organizations’ reports, and credible media reports and social media posts.
Interviews, which are semi-structured, are conducted with the utmost care and sensitivity, adhering to survivor-centered approaches to minimize the risk of re-traumatization. Participation is strictly voluntary, with clear oral consent obtained after explaining the purpose, nature, and intended use of the information. We emphasize confidentiality, implementing robust data protection protocols to safeguard identities. In cases where anonymity cannot be fully ensured, we may withhold or refrain from publishing specific details to protect individuals at risk.
Arbitrary and extrajudicial killings in Iran are politically sensitive and aimed at spreading fear and silencing victims, witnesses, and the voices of dissent. The sheer volume of protest-related deaths and extensive efforts by the Islamic Republic to silence families who seek justice for their loved ones also adds to the complexity of documenting these types of cases. Any investigation conducted in such circumstances, without free and safe access to victims and/or official records is by nature constrained and incomplete and cannot result in an exhaustive record of victims; ABC verifies information it collects to the best of its ability. ABC furthermore continues to track development of cases and continuously updates them when resources are available.
The Right to Protest in International Law
The term “protest” is not defined in international law nor is there a single formulated “right to protest”. However, the right to protest is firmly grounded in a number of distinct but interconnected fundamental human rights, including the rights to freedom of expression, to freedom of association and assembly, and to participate in public affairs. Further obligations arise in the context of exercising the right to protest and include, for example, the right to be free from arbitrary detention and the right to liberty and security of the person. These latter obligations are typically engaged in the context of state responses to protests and the treatment of protesters.
As explained by the United Nations (UN) Special Representative of the Secretary-General on the situation of human rights defenders:
In its General Comment No 37,[ii] The UNHRC explained that the right of peaceful assembly, an individual right exercised collectively, applies to everyone—citizens and non-citizens alike.
This right is protected under Article 21
“regardless of the location—outdoors, indoors and online; in public and private spaces; or a combination thereof—and covers various forms of assembly, including demonstrations, protests, meetings, processions, rallies, sit-ins, candlelit vigils and flash-mobs, whether they are stationary or mobile.”
The UN Human Rights Committee (UNHRC) has also set out how “[p]rotests engage both freedom of expression and assembly”, given that protestors “will express themselves verbally, as well as through non-verbal expression.”[iii] As the UNHRC has explained,
Everyone must be able to express their grievances or aspirations in a peaceful manner, including through public protests, without fear of reprisals or of being intimidated, harassed, injured, sexually assaulted, beaten, arbitrarily arrested and detained, tortured, killed or subjected to enforced disappearance.[iv]
The UNHRC emphasizes that peaceful assemblies must be facilitated, not stifled, and that states must presume assemblies are peaceful unless strong evidence proves otherwise. Spontaneous assemblies, including those without prior notification, are also protected. Moreover, online assemblies fall within the scope of Article 21 protections. Blanket bans, discriminatory enforcement, and restrictions based on content or viewpoint are considered inconsistent with international law.
States can restrict the right to protest under very specific and limited circumstances. The UNHRC stresses that in cases of restriction, “authorities must be able to show that any restrictions meet the requirement of legality, and are also both necessary for and proportionate to at least one of the permissible grounds for restrictions enumerated in article 21.” The Committee further states that “the imposition of any restrictions should be guided by the objective of facilitating the right, rather than seeking unnecessary and disproportionate limitations to it. Restrictions must not be discriminatory, impair the essence of the right, or be aimed at discouraging participation in assemblies or causing a chilling effect.”[v]
While the Committee doesn’t define “excessive force” in a single phrase, it is clearly understood as any force used by law enforcement during an assembly that is unnecessary, disproportionate, or not a last resort, especially when it causes harm or death in violation of international standards.
The Right to Freedom of Expression
Article 19 of the Universal Declaration of Human Rights (UDHR) provides that “[e]veryone has the right to freedom of opinion and expression”, which “includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers”.
The right to freedom of expression can be subject to limitations, as is clear from Article 19, ICCPR. While everyone has the right “to hold opinions without interference” (paragraph 1) and “to freedom of expression” (paragraph 2) — which includes the “freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print, in the form of art, or through any other media of his choice” — these rights may be restricted where such restrictions are provided by law and are necessary:
- for respect of the rights or reputations of others;
- for the protection of national security or of public order, or of public health or morals.
The freedoms of opinion and expression are described as “indispensable conditions for the full development of the person” and “constitute the foundation stone for every free and democratic society”.[vi] Exercising these interconnected rights, and guaranteeing their protection, “is essential to full and effective participation in a free and democratic society, and is instrumental to the development and strengthening of effective democratic systems.”[vii]
The Right to Freedom of Peaceful Assembly and Association
Article 20(1) UDHR provides that “[e]veryone has the right to freedom of peaceful assembly and association”. In this regard, “association” includes “any groups of individuals or any legal entities brought together in order to collectively act, express, promote, pursue or defend a field of common interests.”[viii] The right to freedom of peaceful assembly includes the right to plan, organize, promote and advertise an assembly in any lawful manner.[ix]
This right is also protected under Articles 21 and 22, International Covenant on Civil and Political Rights (ICCPR), and in various regional treaties. The right to freedom of association and assembly is also protected under a range of other treaties, including those to which Iran is a party.[x]
Article 21 ICCPR provides:
The right of peaceful assembly shall be recognised. No restrictions may be placed on the exercise of this right other than those imposed in conformity with the law and which are necessary in a democratic society in the interests of national security or public safety, public order (ordre public), the protection of public health or morals or the protection of the rights and freedoms of others.
For the purposes of Article 21, an “assembly” is generally understood to mean:
an intentional and temporary gathering in a private or public space for a specific purpose, and can take the form of demonstrations, meetings, strikes, processions, rallies or sit-ins with the purpose of voicing grievances and aspirations or facilitating celebrations ... While an assembly is defined as a temporary gathering, this may include long-term demonstrations, including extended sit-ins and “occupy”-style manifestations. Although an assembly has generally been understood as a physical gathering of people, it has been recognized that human rights protections, including for freedom of assembly, may apply to analogous interactions taking place online.[xi]
Article 22(1) ICCPR protects the right to freedom of association, including the right to form and join trade unions. As with the right to freedom of expression, Article 22(2) provides that restrictions upon this right are only “those which are prescribed by law and which are necessary in a democratic society in the interests of national security or public safety, public order (ordre public), the protection of public health or morals or the protection of the rights and freedoms of others”.
The Right to Life
The right to life and the right to be free from the arbitrary deprivation of life are fundamental rights formally codified in Article 6(1) of the International Covenant on Civil and Political Rights: “[e]very human being has the inherent right to life. This right shall be protected by law. No one shall be arbitrarily deprived of his life.”
Under General Comment No. 37 to Article 21 of the ICCPR, the Human Rights Committee outlines the obligations of law enforcement authorities during peaceful assemblies, emphasizing their primary duty to facilitate and protect—not suppress—the right of individuals to gather and express themselves peacefully. Law enforcement officials are required to act as protectors of fundamental rights, ensuring that assemblies can proceed without fear, intimidation, or retaliation. This includes protecting participants from violence or interference by third parties, including counter-demonstrators or hostile actors. The use of force by law enforcement during assemblies must always be a last resort and guided by principles of legality, necessity, proportionality, and accountability.
Authorities must give priority to de-escalation techniques such as communication and negotiation before considering enforcement actions. Any intervention must be impartial and free from discrimination based on the identity or viewpoint of the demonstrators. When force is used, it must comply with international standards, particularly the UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials. Force becomes excessive—and therefore unlawful—when it is not necessary to achieve a legitimate objective, when it is disproportionate to the threat posed, or when it is not the least harmful means available.
Lethal force, including the use of firearms, is subject to the most stringent standards. It is lawful only in situations where it is strictly unavoidable to protect life from an imminent threat. Under no circumstances is the use of firearms permissible to disperse a crowd or respond to non-lethal threats, including property damage or disorder. Such use would be considered manifestly disproportionate and a violation of both the right to life under Article 6 of the ICCPR and the right to peaceful assembly.
Less-lethal weapons such as tear gas, batons, and rubber bullets may also constitute excessive force when used indiscriminately, against peaceful protesters, at close range, or without adequate warning. Their use must always be subject to the same strict standards of necessity and proportionality.
Importantly, the Committee stresses that when force results in death, serious injury, or credible allegations of unlawful conduct, the state is under an obligation to conduct prompt, independent, impartial, and effective investigations. Where violations are established, authorities must ensure accountability and provide remedies to victims or their families. Failure to investigate or provide redress can amount to a separate breach of the ICCPR.
The Committee’s interpretation makes clear that excessive use of force is not merely a matter of degree, but a serious violation of international human rights law, particularly when it results in the death of demonstrators. States must ensure that law enforcement agencies operate under clear, lawful guidelines and are held accountable for any deviation from these standards.
States’ Obligations
States parties to the ICCPR, which Iran has also ratified, have a duty to protect the right to life by law (Article 6). The 1989 Principles on the Effective Prevention and Investigation of Extra-legal, Arbitrary and Summary Execution, provides that states have not only an obligation to prohibit “all extra-legal, arbitrary and summary executions,” but they must “ensure that any such executions are recognized as offenses under their criminal laws, and are punishable by appropriate penalties which take into account the seriousness of such offenses.”
Transparency reinforces the rule of law, while secrecy and failure to hold perpetrators accountable often leads to the repetition of killings. A State’s obligation to ensure the right to life includes a duty to investigate alleged violations of that right promptly and effectively and prosecute human rights violations. According to the UN Special Rapporteurs on Extrajudicial, Summary or Arbitrary Executions, states are obligated under international law “to conduct full, independent and impartial investigations into all allegations of extrajudicial, summary or arbitrary executions transmitted to them, with a view to clarifying the circumstances, identifying and prosecuting those responsible, granting compensation to the victims or their families, and preventing future violations.”
Moreover, victims and their representatives should be entitled to seek and obtain information on the causes leading to their victimization and on the causes and conditions pertaining to the gross violations of international human rights law and serious violations of international humanitarian law and to learn the truth about these violations. The right to the truth is an inalienable and autonomous right, linked to the duty and obligation of the State to protect and guarantee human rights, to conduct effective investigations and to guarantee effective remedy and reparations.
The right to the truth, as defined in a 2006 study of the Office of the UN High Commissioner for Human Rights, “implies knowing the full and complete truth as to the events that transpired, their specific circumstances, and who participated in them, including knowing the circumstances in which the violations took place, as well as the reasons for them.”
Investigations and their outcome must be transparent and open to the scrutiny of the general public and of victims’ families. Any limitations on transparency must be strictly necessary for a legitimate purpose, such as protecting the privacy and safety of affected individuals, ensuring the integrity of ongoing investigations, or securing sensitive information about intelligence sources. In no circumstances may a state restrict transparency in a way that would result in impunity for those responsible.