activity that contradicts or interferes with the sacred law of Islam” when it is, among others, part of a “sect”, or through the use of “mind control methods and psychological indoctrination”. However, as stipulated by the Human Rights Committee, the mere ‘contradiction’ or ‘interference’ with the state’s official religion is not a permissible ground for the restriction of the right to religion or belief.19 Additionally, such bill may well disproportionately impact individuals belonging to unrecognized religious minorities, such as Baha’is, often arrested and detained on the basis of their religious beliefs notably on the charge of proselytizing the Baha’i faith.20 According to the Government, the Charter of Citizenship Rights, decreed by the President in 2016, functioned as an administrative mechanism providing guidance for the implementation of the principles, norms and laws stipulated in the Constitution.21 Article 26 of the Charter stipulates that “the Government shall, according to the law, guarantee freedom of speech and expression”.22 Article 43 of the Charter provides that citizens of the Islamic Republic of Iran “have the right to form, join and participate in political parties, societies, social, cultural, scientific, political and trade associations and non-governmental organizations in compliance with the law”.23 In practice the mechanism does not resolve the absence of legal protection for religion minorities against discriminations. Religious minorities recognized by Articles 12 and 13 of the Constitution, have few places of worship compared to their numbers. Sunnis are not allowed to build new mosques in major cities, including Tehran. In addition, a number of Sunni religious seminaries have been destroyed by the government24 and authorities have reportedly been closing Sunni mosques or preventing Sunnis from gathering for congregational prayers.25 Only 1% of religious temples in Iran are non-Muslim.26 In Tehran, there are about 15 churches for 43,987 Christians (one church every 2932 Christians). 27 The lack of official places of worship forces religious minorities to gather in informal assemblies inside their own home, frequently termed “house churches”,28 or in underground prayer halls (namaz khane)29 which often get dismantled by 19 UN Human Rights Committee (HRC), CCPR General Comment No. 22: Article 18 (Freedom of Thought, Conscience or Religion), 30 July 1993, CCPR/C/21/Rev.1/Add.4, available at: https://www.refworld.org/docid/453883fb22.html 20 ARTICLE19, https://www.article19.org/resources/iran-lawmakers-must-urgently-drop-the-bill-that-criminalisesfundamental-rights-and-freedoms/ 21 Report of the Working Group on the Universal Periodic Review Islamic Republic of Iran, 27 December 2019, https://undocs.org/A/HRC/43/12 22 Charter of Citizen’s Rights English translation, December 2016, http://president.ir/en/96865 23 Charter of Citizen’s Rights English translation, December 2016, http://president.ir/en/96865 24 Joint submission to the Human Rights Committee from All Human Rights for All in Iran, Association for Human Rights in Kurdistan – Geneva, Association for the Human Rights of the Azerbaijani People in Iran, Iran Human Rights Documentation Center, OutRight International, Siamak Pourzand Foundation, Small Media, Impact Iran, 2020, <https://tbinternet.ohchr.org/Treaties/CCPR/Shared%20Documents/IRN/INT_CCPR_NGO_IRN_42317_E.pdf> 25 Rights Denied: Violations against ethnic and religious minorities in Iran, https://minorityrights.org/wpcontent/uploads/2018/03/Rights-Denied-Violations-against-ethnic-and-religious-minorities-in-Iran.pdf 26 Based on Province annual data reports, as of 2018. 27 Based on Province annual data reports, as of 2018. 28 Joint submission to the Human Rights Committee from The World Evangelical Alliance, Open Doors, Christian Solidarity Worldwide, Middle East Concern, Article 18, 29 May 2020 , https://articleeighteen.com/wpcontent/uploads/2020/06/F3430b-2020-JointReport_Iran_HRCttee_ListOfIssues-dragged-1.pdf 29 2019 Report on International Religious Freedom: Iran, U.S. Department of State, https://www.state.gov/reports/2019report-on-international-religious-freedom/iran/ 4