Despite the existence of several mechanisms that ostensibly accept complaints regarding violations of citizens' rights, such as the Article 90 Commission of the parliament (established based on Article 90 of the Constitution, offering a mechanism to citizens to file complaint against any of the three branches of power) and the Oversight Bodies for the exercise of Citizenship Rights in the country's provincial courts, there is no evidence to suggest that complaints to these bodies are independently reviewed and investigated.68 Additionally and as aforementioned, the absence of a crime of torture in itself under Iranian law prevents prosecution, which is limited to cases of torture provided under the law, and therefore hinders access to justice for victims. The Government of the Islamic Republic of Iran has not duly investigated complaints of torture and ill-treatment, and the shortcomings of the Iranian legal framework hinder accountability for perpetrators. There is no readily available information that might indicate that the Government of the Islamic Republic of Iran has taken measures to prevent the recurrence of acts of torture and ill-treatment, apart from the reported inspections and investigations into complaints. Since 2016, the Working Group on Arbitrary Detention (WGAD) has found at least 38 cases of arbitrary detention in the Islamic Republic of Iran. Despite these opinions, many remain in detention as of December 2020.69 Individuals found to be arbitrarily detained in the Islamic Republic of Iran by the WGAD include but are not limited to: Mr. Arash Sadeghi (Opinion no. 19/2018), Ms. Golrokh Ebrahimi Iraee (Opinion no. 33/2019), Ms. Atena Daemi (Opinion no. 83/2018). In light of the above, the Government of the Islamic Republic of Iran has not adopted all the measures necessary to effectively guarantee the right of anyone to be free from arbitrary deprivation of their liberty. Recommendation Status: This recommendation has NOT been implemented. 68 Joint submission to the Human Rights Committee, Abdorrahman Center, Iran Human Rights Documentation Center (IHRDC), Impact Iran and Human Rights Activists in Iran, 2020, https://tbinternet.ohchr.org/_layouts/15/treatybodyexternal/Download.aspx?symbolno=INT%2fCCPR%2fICS%2fIRN%2f42313 &Lang=en 69 See more: United for Iran, https://ipa.united4iran.org/en/prisoner/ 8