2107853 (Refugee) - [2024] ARTA 542

2107853 (Refugee) [2024] ARTA 542 (12 November 2024)
DECISION AND
REASONS FOR DECISION
Respondent:Minister for Home Affairs

Tribunal Number: 2107853
Tribunal:General Member P Noonan
Date:12 November 2024

Place:Melbourne
Decision:The Tribunal sets aside the decision under review and remits the application for a protection visa for reconsideration, in accordance with the order that the applicant meets the following criteria:
·s 36(2)(a) of the Migration Act.

Statement made on 12 November 2024 at 3:25pm

CATCHWORDS
REFUGEE – Protection Visa – Iran – religion – Christian convert from Islam – imputed with a political opinion against the Iranian authorities – effective state protection is not available – applicant has a well-founded fear of persecution for reason of religion – decision under review set aside

LEGISLATION
Migration Act 1958, ss 5, 36, 65, 91, 499
CASES
Chan Yee Kin v MIEA (1989) 169 CLR 379
DBB16 v MIBP (2018) 260 FCR 447
MICMSMA v CBW20 [2021] FCAFC 63
Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 369 of the Migration Act 1958 and replaced with generic information.
STATEMENT OF REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 2 June 2021 to refuse to grant the applicant a protection visa under s 65 of the Migration Act 1958 (Cth) (the Act).
The applicant who claims to be a national of Iran, applied for the visa on 13 October 2020. The delegate refused to grant the visa on the basis that the applicant does not engage Australia’s protection obligations.
The applicant appeared before the Tribunal on 25 October 2024 to give evidence and present arguments. The Tribunal hearing was conducted with the assistance of an interpreter in the Persian and English languages.
The applicant was represented in relation to the review. The representative attended the Tribunal hearing.
Procedural history
The extensive procedural history to this case is summarised as follows: according to
Departmental records, the applicant arrived in Australia by sea at the Territory of Ashmore
and Cartier Islands on [date] May 2013; on 13 June 2013 the applicant was assessed as an
‘unauthorised maritime arrival’ and granted a Temporary Safe Haven (Subclass 449) visa; at
the time, the grant of the Subclass 449 visas was considered to trigger the statutory bar
under s 91K against making further visa applications.
In DBB16 v MIBP (2018) 260 FCR 447, the Full Federal Court determined that a person who
arrived in Australia by sea at the Territory of Ashmore and Cartier Islands was not an
‘unauthorised maritime arrival’ (as was defined in s 5AA of the Act). Following the Full
Federal Court judgment in MICMSMA v CBW20 [2021] FCAFC 63, the s 91K bar does not
apply to applicants who arrived in Australia by sea at Ashmore.
Accordingly, the applicant is not a ‘fast track applicant’ (as defined in s 5(1)) and a decision
to refuse to grant him a Safe Haven Enterprise visa (SHEV) is a Part 7-reviewable decision by the Tribunal.
The applicant made the SHEV application that is the subject of the current review on
13 October 2020, which was refused on 2 June 2021.
The applicant had made an earlier SHEV application on 3 April 2017. That visa application
was originally assessed as invalid by operation of the statutory bar under s 91K, consistent
with the Department’s view of the law as it stood at that time. As set out above, that view
was subsequently held to be incorrect by the courts.
It appears from Departmental records that the first SHEV application has been reassessed
as a valid application and is awaiting processing by the Department.
Given the first SHEV and the second SHEV are applications for visas of the same subclass,
the validity of the second SHEV is not affected by item 1404(3)(f) of Schedule 1 to the
Migration Regulations 1994 (Cth) (the Regulations) for making a valid visa application.
Criteria for protection visa
The criteria for a protection visa are set out in s 36 of the Act and Schedule 2 to the Regulations. An applicant for the visa must meet one of the alternative criteria in s 36(2)(a), (aa), (b) or (c). That is, he or she is either a person in respect of whom Australia has protection obligations under the ‘refugee’ criterion, or on other ‘complementary protection’ grounds, or is a member of the same family unit as such a person and that person holds a protection visa of the same class.
Section 36(2)(a) provides that a criterion for a protection visa is that the applicant for the visa is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee.
A person is a refugee if, in the case of a person who has a nationality, they are outside the country of their nationality and, owing to a well-founded fear of persecution, are unable or unwilling to avail themselves of the protection of that country: s 5H(1)(a). In the case of a person without a nationality, they are a refugee if they are outside the country of their former habitual residence and, owing to a well-founded fear of persecution, are unable or unwilling to return to that country: s 5H(1)(b).
Under s 5J(1), a person has a well-founded fear of persecution if they fear being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, there is a real chance they would be persecuted for one or more of those reasons, and the real chance of persecution relates to all areas of the relevant country. Additional requirements relating to a ‘well-founded fear of persecution’ and circumstances in which a person will be taken not to have such a fear are set out in ss 5J(2)–(6) and ss 5K–LA, which are extracted in the attachment to this decision.
If a person is found not to meet the refugee criterion in s 36(2)(a), he or she may nevertheless meet the criteria for the grant of the visa if he or she is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of being removed from Australia to a receiving country, there is a real risk that he or she will suffer significant harm: s 36(2)(aa) (‘the complementary protection criterion’). The meaning of significant harm, and the circumstances in which a person will be taken not to face a real risk of significant harm, are set out in ss 36(2A) and (2B), which are extracted in the attachment to this decision.
Mandatory considerations
In accordance with Ministerial Direction No. 84, made under s 499 of the Act, the Tribunal has taken account of the ‘Refugee Law Guidelines’ and ‘Complementary Protection Guidelines’ prepared by the Department of Home Affairs, and country information assessments prepared by the Department of Foreign Affairs and Trade (DFAT) expressly for protection status determination purposes, to the extent that they are relevant to the decision under consideration.
CONSIDERATION OF CLAIMS AND EVIDENCE
The issue in this case is whether the applicant is a person in respect of whom Australia has protection obligations under the ‘refugee’ criterion, or on other ‘complementary
protection’ grounds, or is a member of the same family unit as such a person and that
person holds a protection visa of the same class. For the following reasons, the Tribunal has
concluded that the decision under review should be remitted for reconsideration with the
direction that the applicant satisfies s 36(2)(a) of the Migration Act.
Country of nationality
There is no dispute that the applicant is an Iranian citizen who travelled to Australia on a genuine Iranian passport. The Tribunal has assessed his claims against Iran as his country of nationality and the receiving country.
The applicant’s personal background
The applicant is around [age] years old. Since being in Australia he has had a relationship with an Australian citizen and they have an Australian citizen child who was born in [year]. The applicant has parents still residing in Iran and siblings residing in Iran and [another country]. Prior to coming to Australia the applicant had travelled on two occasions to [a named country] for a holiday. On each occasion he returned to Iran. In Australia the applicant worked as a [occupation] however he suffered a severe back injury and now suffers from chronic back pain. He is now separated from his partner and has a Family Court Order that allows him care of the child on a shared care basis.
The Tribunal accepts the above to be true.
The applicant’s claims for protection
The applicant wrote in his claim for protection that he fears returning to Iran because he is a Christian convert from Islam. His partner is a Christian woman and they are raising their son as a Christian. He also fears harm in Iran due to being imputed with a political opinion against the Iranian authorities.
Claim – Christian conversion
The delegate did not accept the applicant’s conversion to Christianity was genuine. The delegate found the applicant’s explanations as to why he joined a Christian church to be unconvincing and his knowledge of Christianity to be lacking in an expected level of depth of understanding.
The Tribunal discussed with the applicant that it must assess, for the purposes of s 5(J)(6), whether his claimed conversion to Christianity is conduct engaged in for the sole purpose of strengthening his claim to be a refugee and that it must disregard this conversion if not so satisfied.
The Tribunal notes the delegate’s concerns about the genuineness of the applicant’s conversion activities. The delegate noted reports that Christian conversion is a recognised strategy for obtaining asylum in the West among the Iranian diaspora. The delegate was also concerned about the applicant’s perceived inability to articulate his motivations for converting in a plausible way and an apparent rudimentary knowledge of Christian concepts, despite purportedly engaging in the religion for many years.
However, there are several factors which in the Tribunal’s view outweigh concerns about the applicant’s stated motivations and knowledge of Christian doctrines and practice. These aspects are set out as follows:
·The applicant presented to the Tribunal with significant amounts of Christian iconography tattooed on visible parts of his body. This included [details deleted].
·A letter of reference from [Church 1], which sets out that the applicant has been continuously involved in worship and attendance at the [Church 1], for at least the past 11 years. Further, that the applicant is personally known to the current Minister of the church and that he was baptised by the previous Reverend (now deceased) in 2015.
·A letter of reference from the Reverend [A], dated 20 July 2016, of the [Church 1], stating that the applicant has been a regular attendee at church since the end of 2014 and who has since participated in many church activities.
·Some limited social media posts of Christian content including church services posted by the applicant.
·The applicant gave evidence to the Tribunal about how peaceful being a Christian made him feel and answered some basic questions about Christian practice and beliefs and his reasons for being baptised and obtaining Christian tattoo iconography in a plausible manner.
·While the applicant may have been initially motivated in his engagement in Christianity by his protection claims, as reflected in some of the concerns raised by the delegate, it is also now the case that he has physically engaged in Christian practice for more than a decade on a continuous basis. He appears to have now deeply engaged in Christian belief on a personal level as reflected by him tattooing Christian iconography over his body. This permanent iconography impressed the Tribunal as a tangible reflection of a now deeply held belief by the applicant of his Christian religion.
Weighing up the above the Tribunal is satisfied that there is sufficient weight of evidence to find that the applicant’s conversion to Christianity has not been undertaken for the sole purpose of furthering his claim to be a refugee. The Tribunal accepts that, with the passage of time, the Christian faith is now an important part of the applicant’s life and identity and that he will not willingly cease to practise his faith if returned to Iran.
Risk on return to Iran – Christian convert
DFAT assesses that Muslim converts to Christianity risk arrest and detention if their conversion is revealed. DFAT also assesses that those who convert while outside of Iran and who intend to continue to practise their Christian religion would face a high level of official discrimination and could be subject to the death penalty.[1] The UK Home Office assesses that, in general, a person who is found to have converted to Christianity and who seeks to openly practise their faith in Iran, is likely to be subject to treatment or discrimination by the state that is sufficiently serious, by its nature or repetition, to amount to persecution.[2]
[1] DFAT Country Information Report, Iran, 24 July 2023, p. 21
[2] >
The Tribunal notes that Christian converts were targeted and arrested in 2023 and 2024 in Iran. In 2024 a female Christian convert was arrested and sentenced to two years imprisonment due to evidence of her Christian activities years earlier in Malaysia.[3] Many other Christian converts have been arrested and imprisoned in 2024.[4] Amnesty International reports that two men have been executed in 2022 for the offence of apostasy on the sole basis of their social media posts.[5] DFAT notes that a wide range of offences are punishable by death, including murder, rape, drug possession and moral crimes that include adultery and same-sex sexual intercourse. Vaguely defined offences such as ‘insulting the prophet’, ‘enmity against God’ and ‘spreading corruption on earth’ (which can include blasphemy and heresy) (see Religion and Sexual Orientation and Gender Identity) also attract the death penalty.[6]
[3] DFAT Country Information Report, Iran, 24 July 2023, para 2.173
While the Tribunal is aware of the DFAT assessment that tattoos in general are common in Tehran amongst young men, there are also a number of recent reports of people being the subject of adverse attention from the authorities due to their tattoos.[7] DFAT specifically assessed in 2013 that outward displays of Christianity and proselytising in the form of visible Chistian tattoos could attract the attention of security authorities.[8]
[7] ‘Iranian Rapper Detained in Turkey Faces Deportation’, The New York Times, 30 January 2020,
[8] ‘IRN15158 Tattoos and Christian symbols in Iran’, Australia: Department of Foreign Affairs and Trade (DFAT), CX314473
In this case the Tribunal is especially concerned about the applicant’s treatment at the pinch point of immigration control upon his arrival back into Iran. The applicant would be returning as a former Muslim, who is now overtly displaying Christian symbols that could not be covered up. DFAT advises returnees travelling on a laissez-passer are questioned at the airport upon return (usually for between 30 minutes and one hour) and arrest and mistreatment are not common during this process.[9] The applicant would be returning on a laissez-passer. As such he would be subject to questioning. The Tribunal considers that it is probable that the applicant’s Christian tattoos would lead to questions about his potential conversion while residing in the West for many years. As apostasy and conversion is a crime punishable by death, and country information reflects a continuing crackdown on Christian converts, the Tribunal considers there is a chance that is not negligible that the applicant would be subjected to extended questioning, leading to charges of apostasy. It is also clear that the longer a person is held in custody by the authorities the greater the chance that they will be subjected to serious harm.
[9] DFAT Country Information Report, Iran, 24 July 2023, para 2.203
DFAT notes that international human rights organisations report that torture and other mistreatment of detainees occurs in Iranian detention facilities, especially as a means to extract information. The US Department of State 2021 Human Rights Report notes torture is especially practised in pre-trial detention and can include threats of execution or rape, forced vaginal and anal examinations, sleep deprivation, suspension, forced ingestion of chemical substances, deliberate lack of medical care, electric shock (including to the genitals), burnings, use of pressure positions and severe and repeated beatings.[10]
[10] DFAT Country Information Report, Iran, 24 July 2023, para 2.217
The criterion in s 5J(1)(a) contains a subjective requirement, that an applicant must in fact hold a fear of being persecuted, while s 5J(1)(b) imposes an objective standard, that there be a real chance the person would be persecuted. A ‘real chance’ is one that is not remote or insubstantial or a far-fetched possibility. A person can have a well-founded fear of persecution even though the possibility of the persecution occurring is well below 50 per cent: Chan Yee Kin v MIEA (1989) 169 CLR 379.
Given all of the above considerations the Tribunal considers that there is a real chance of serious harm to the applicant, which is not far fetched or remote, that upon his return to Iran he will be subjected to serious harm by the authorities for the essential and significant reason of his Christian religion.
The Tribunal finds that any modification of the applicant’s behaviour to avoid a real chance of persecution in Iran on the basis of his Christian faith would be undertaken only to avoid the threat of serious harm and would conflict with characteristics that are fundamental to his identity or conscience in contravention of s 5J(3)(a). Therefore, he is not required and cannot be expected to take steps to modify his behaviour so as to conceal his religion in order to avoid the feared persecution.
As the main perpetrator of harm is the Iranian state and the harm would occur upon immediate entry to Iran, the Tribunal accepts that the real chance of persecution relates to all areas of Iran and effective state protection is not available.
For these reasons, the Tribunal accepts the applicant has a well-founded fear of persecution in Iran for reasons of his religion for the purposes of s 5J. As he is outside his country of nationality and unable to avail himself of the protection of that country owing to his
well-founded fear of persecution, he comes within the definition of a refugee set out in s 5H. It follows that the Tribunal is satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(a).
As the Tribunal has found that the applicant meets the criteria for protection as a refugee because of his Christian conversion it has not set out considerations with respect to his other claim related to his imputed political opinion.
DECISION
The Tribunal sets aside and remits the application for a protection visa for reconsideration, in accordance with the order that the applicant satisfies s 36(2)(a) of the Act.
Date of hearing:   25 October 2024
Representative:   Ms Maria Psihogios
ATTACHMENT – Extract from Migration Act 1958
5 (1) Interpretation
…
cruel or inhuman treatment or punishment means an act or omission by which:
(a)     severe pain or suffering, whether physical or mental, is intentionally inflicted on a person; or
(b)     pain or suffering, whether physical or mental, is intentionally inflicted on a person so long as, in all the circumstances, the act or omission could reasonably be regarded as cruel or inhuman in nature;
but does not include an act or omission:
(c)     that is not inconsistent with Article 7 of the Covenant; or
(d)     arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
degrading treatment or punishment means an act or omission that causes, and is intended to cause, extreme humiliation which is unreasonable, but does not include an act or omission:
(a)     that is not inconsistent with Article 7 of the Covenant; or
(b)     that causes, and is intended to cause, extreme humiliation arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
torture means an act or omission by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person:
(a)     for the purpose of obtaining from the person or from a third person information or a confession; or
(b)     for the purpose of punishing the person for an act which that person or a third person has committed or is suspected of having committed; or
(c)     for the purpose of intimidating or coercing the person or a third person; or
(d)     for a purpose related to a purpose mentioned in paragraph (a), (b) or (c); or
(e)     for any reason based on discrimination that is inconsistent with the Articles of the Covenant;
but does not include an act or omission arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
receiving country, in relation to a non-citizen, means:
(a)     a country of which the non-citizen is a national, to be determined solely by reference to the law of the relevant country; or
(b)     if the non-citizen has no country of nationality—a country of his or her former habitual residence, regardless of whether it would be possible to return the non-citizen to the country.
…
5H    Meaning of refugee
(1)For the purposes of the application of this Act and the regulations to a particular person in Australia, the person is a refugee if the person is:
(a)     in a case where the person has a nationality – is outside the country of his or her nationality and, owing to a well-founded fear of persecution, is unable or unwilling to avail himself or herself of the protection of that country; or
(b)     in a case where the person does not have a nationality – is outside the country of his or her former habitual residence and owing to a well-founded fear of persecution, is unable or unwilling to return to it.
Note:     For the meaning of well-founded fear of persecution, see section 5J.
…
5J     Meaning of well-founded fear of persecution
(1)For the purposes of the application of this Act and the regulations to a particular person, the person has a well-founded fear of persecution if:
(a)     the person fears being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion; and
(b)     there is a real chance that, if the person returned to the receiving country, the person would be persecuted for one or more of the reasons mentioned in paragraph (a); and
(c)     the real chance of persecution relates to all areas of a receiving country.
Note:     For membership of a particular social group, see sections 5K and 5L.
(2)A person does not have a well-founded fear of persecution if effective protection measures are available to the person in a receiving country.
Note:     For effective protection measures, see section 5LA.
(3)A person does not have a well-founded fear of persecution if the person could take reasonable steps to modify his or her behaviour so as to avoid a real chance of persecution in a receiving country, other than a modification that would:
(a)     conflict with a characteristic that is fundamental to the person’s identity or conscience; or
(b)     conceal an innate or immutable characteristic of the person; or
(c)     without limiting paragraph (a) or (b), require the person to do any of the following:
(i)alter his or her religious beliefs, including by renouncing a religious conversion, or conceal his or her true religious beliefs, or cease to be involved in the practice of his or her faith;
(ii)conceal his or her true race, ethnicity, nationality or country of origin;
(iii)alter his or her political beliefs or conceal his or her true political beliefs;
(iv)conceal a physical, psychological or intellectual disability;
(v)enter into or remain in a marriage to which that person is opposed, or accept the forced marriage of a child;
(vi)alter his or her sexual orientation or gender identity or conceal his or her true sexual orientation, gender identity or intersex status.
(4)If a person fears persecution for one or more of the reasons mentioned in paragraph (1)(a):
(a)     that reason must be the essential and significant reason, or those reasons must be the essential and significant reasons, for the persecution; and
(b)     the persecution must involve serious harm to the person; and
(c)     the persecution must involve systematic and discriminatory conduct.
(5)Without limiting what is serious harm for the purposes of paragraph (4)(b), the following are instances of serious harm for the purposes of that paragraph:
(a)     a threat to the person’s life or liberty;
(b)     significant physical harassment of the person;
(c)     significant physical ill‑treatment of the person;
(d)     significant economic hardship that threatens the person’s capacity to subsist;
(e)     denial of access to basic services, where the denial threatens the person’s capacity to subsist;
(f)     denial of capacity to earn a livelihood of any kind, where the denial threatens the person’s capacity to subsist.
(6)In determining whether the person has a well‑founded fear of persecution for one or more of the reasons mentioned in paragraph (1)(a), any conduct engaged in by the person in Australia is to be disregarded unless the person satisfies the Minister that the person engaged in the conduct otherwise than for the purpose of strengthening the person’s claim to be a refugee.
5K    Membership of a particular social group consisting of family
For the purposes of the application of this Act and the regulations to a particular person (the first person), in determining whether the first person has a well‑founded fear of persecution for the reason of membership of a particular social group that consists of the first person’s family:
(a)     disregard any fear of persecution, or any persecution, that any other member or former member (whether alive or dead) of the family has ever experienced, where the reason for the fear or persecution is not a reason mentioned in paragraph 5J(1)(a); and
(b)     disregard any fear of persecution, or any persecution, that:
(i)the first person has ever experienced; or
(ii)any other member or former member (whether alive or dead) of the family has ever experienced;
where it is reasonable to conclude that the fear or persecution would not exist if it were assumed that the fear or persecution mentioned in paragraph (a) had never existed.
Note:     Section 5G may be relevant for determining family relationships for the purposes of this section.
5L    Membership of a particular social group other than family
For the purposes of the application of this Act and the regulations to a particular person, the person is to be treated as a member of a particular social group (other than the person’s family) if:
(a)     a characteristic is shared by each member of the group; and
(b)     the person shares, or is perceived as sharing, the characteristic; and
(c)     any of the following apply:
(i)the characteristic is an innate or immutable characteristic;
(ii)the characteristic is so fundamental to a member’s identity or conscience, the member should not be forced to renounce it;
(iii)the characteristic distinguishes the group from society; and
(d)     the characteristic is not a fear of persecution.
5LA Effective protection measures
(1)For the purposes of the application of this Act and the regulations to a particular person, effective protection measures are available to the person in a receiving country if:
(a)     protection against persecution could be provided to the person by:
(i)the relevant State; or
(ii)a party or organisation, including an international organisation, that controls the relevant State or a substantial part of the territory of the relevant State; and
(b)     the relevant State, party or organisation mentioned in paragraph (a) is willing and able to offer such protection.
(2)A relevant State, party or organisation mentioned in paragraph (1)(a) is taken to be able to offer protection against persecution to a person if:
(a)     the person can access the protection; and
(b)     the protection is durable; and
(c)     in the case of protection provided by the relevant State—the protection consists of an appropriate criminal law, a reasonably effective police force and an impartial judicial system.
…
36     Protection visas – criteria provided for by this Act
…
(2)A criterion for a protection visa is that the applicant for the visa is:
(a)     a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee; or
(aa) a non-citizen in Australia (other than a non-citizen mentioned in paragraph (a)) in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of the non-citizen being removed from Australia to a receiving country, there is a real risk that the non-citizen will suffer significant harm; or
(b)     a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (a); and
(ii)holds a protection visa of the same class as that applied for by the applicant; or
(c)     a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (aa); and
(ii)holds a protection visa of the same class as that applied for by the applicant.
(2A)A non‑citizen will suffer significant harm if:
(a)     the non‑citizen will be arbitrarily deprived of his or her life; or
(b)     the death penalty will be carried out on the non‑citizen; or
(c)     the non‑citizen will be subjected to torture; or
(d)     the non‑citizen will be subjected to cruel or inhuman treatment or punishment; or
(e)     the non‑citizen will be subjected to degrading treatment or punishment.
(2B)However, there is taken not to be a real risk that a non‑citizen will suffer significant harm in a country if the Minister is satisfied that:
(a)     it would be reasonable for the non‑citizen to relocate to an area of the country where there would not be a real risk that the non‑citizen will suffer significant harm; or
(b)     the non‑citizen could obtain, from an authority of the country, protection such that there would not be a real risk that the non‑citizen will suffer significant harm; or
(c)     the real risk is one faced by the population of the country generally and is not faced by the non‑citizen personally.
…

20200423120609; ‘I left Iran so my daughter could choose her own destiny’, Iran Wire, 1 August 2019, 20190802160106; ‘Young Partygoers Arrested In Iran For Resembling “Devil Worshipers”’, Radio Farda, 13 December 2019, 20200423120808; ‘This app will help you avoid Iran's morality police’, The Verge, 12 February 2016, CX6A26A6E1197; ‘Iranian Morality Police Arrest Popular Underground Musician Amir Tataloo’, International Campaign for Human Rights in Iran, 3 December 2013, CX316374; ‘Working underground: the life of an Iranian tattoo artist’, France 24 Observers, 15 July 2013, CIS26056; ‘A silent act of resistance: the hidden tattoo studios of Tehran’, The Guardian, 8 February 2019, 20190208102919; ‘The dangerous task of tattooing in Iran’, CE NoticiasFinancieras, 4 February 2019, 20190208155409