A Faith Denied: The Persecution of the Baha'is of Iran
A decade after the execution of the Báb, in 1863, Bahá’u’lláh, one of the followers of the Báb, announced that he was “Him Whom God Shall Make Manifest.”9 Bahá’u’lláh was imprisoned in the Síyáh-Chál in Tehran for four months in 1852 and thereafter spent much of his subsequent life in prison and then in exile, where he died in 1892, although his teachings continued to be widely disseminated.10
One of the central tenets of the Bahá'í faith is the notion of “progressive revelation,” which is the belief that each of the world’s major religions represents an evolution in God's message to mankind.11 These teachings, and the claim made by both the Báb and Bahá’u’lláh to be divine messengers, are the main reasons the Bahá'í faith is considered to be heretical by Muslims, who believe Mohammed to be the final prophet. The declaration of the Báb as the “Hidden Imam”12 is particularly offensive to Shi’ites. This has contributed to a widely-held perception of the Bahá’ís as “public enemies who must be controlled, punished or… forcibly deconverted.”13 In addition, the interpretation of Shi’a law practiced by the Islamic Republic asserts that conversion away from Islam into another faith—apostasy—is an offense punishable by death.14 This prohibition is also used to justify punishment of individuals who, under duress, agree to convert to Islam, but subsequently resume the practice of their own faith.15
A significant doctrinal shift from the Bábís to the Bahá’í faith was the renouncement of violence, even in the face of persecution.16 Nonetheless, persecution of the Bahá’ís continued in the late 19th century. Influenced by the Shi’a clergy and fueled by nationalism, in the late 19th and early 20th century Iranians viewed the global message of the Bahá’í faith as an alien, even pro-western influence in Iran.17 There are presently five million Bahá’í faithful worldwide and an estimated 350,000 Bahá’ís still living inside Iran.18
MOMEN, THE BÁBÍ AND BAHÁ’Í RELIGIONS, supra note 1, at xxii.
See Bahá’í International Community, Historical Introduction to Bahá’u’lláh, available online at http://info.bahai.org/article-1-3-2-2.html (accessed November 9, 2006); see also Office of Public Information of the Bahá’í International Community, THE BAHÁ’ÍS: A PROFILE OF THE BAHÁ’Í FAITH AND ITS WORLDWIDE COMMUNITY 54-62 (1994). After Bábís continued to flock to Baghdad to see Bahá’u’lláh, Iran pressured the Ottoman government into removing him further from Iran. The region of Bahá’u’lláh’s exile is now part of Israel and this is seen as the cause of two of the major allegations against the Bahá’ís: first, that they are the same as Israelis and Zionists, and secondly, that their contributions to their World Center in Haifa support Zionist activities. LIFTING THE VEIL, supra note 4 at 223, notes that Bahá’u’lláh was exiled by Ottoman officials to Palestine some 80 years prior to the formation of Israel.
 Bahá’ís believe that Abraham, Krishna, Zoroaster, Moses, Buddha, Jesus, and Muhammad were all divine messengers; see Bahá’í International Community, The Bahá’í Faith and Other Religions, available online at http://www.bahai.org/dir/other_religions (accessed November 13, 2006).
Shi’a doctrine emphasizes that Mohammad bin Mahdi, the Twelfth and last Imam of the Shi'a sect, also known as the “Hidden Imam”, will return at the time of the last judgment and will save the world.
Denis MacEoin, The Bahá’ís of Iran: The Roots of Controversy, BRITISH SOCIETY FOR MIDDLE EASTERN STUDIES BULLETIN (Vol. 14, No. 1, 1987) at 77.
 Under Iranian jurisprudence (based on interpretations of Khomeini’s Risalih) two forms of apostasy (murtad) are recognized: murtad fitri (referring to a case where an apostate’s family is Muslim) and murtad milli (referring to a case where someone converts to Islam and then converts into another faith). Both types can be punishable by death. In cases of murtad milli, government officials may meet with the accused apostate and try to convince him or her to remain Muslim; if the apostate refuses, a judge will decide the appropriate punishment. See AYATOLLAH RUHOLLAH KHOMEINI, TAHRIR AL-WASILAH (Beirut: Tawzi’ Dar al-Ta’aruf lil-Matbu’aat) 366, 494-495 (1984).
 For an example of the legal treatment of individuals accused of apostasy, see Minutes of the Interrogation, Case of Dhabíhu'lláh Mahrámí, Islamic Revolutionary Court of the Province of Yazd (Branch no. 1), Court classification no. 74/2288/D, Appeal no. 74/2312/D-R (January 2, 1996) (on file with IHRDC).
ELIZ SANASARIAN, RELIGIOUS MINORITIES IN IRAN 51 (2000) [hereinafter SANASARIAN].
SHAHROUGH AKHAVI, RELIGION AND POLITICS IN CONTEMPORARY IRAN: CLERGY-STATE RELATIONS IN THE PAHVALI PERIOD 77 (1980) [hereinafter AKHAVI] .
See Bahá’í International Community, What is the Bahá’í Faith?, available online at http://www.bahai.org/faq/facts/bahai_faith (accessed November 28, 2006). The banning of Bahá’í administrative institutions has made it difficult to obtain an exact count of the number of Bahá’ís remaining in Iran. The above estimate of the current number of Bahá’ís in Iran was cited by Bahá’í International Community, Persecution, available online at http://www.bahai.org/dir/worldwide/persecution (accessed November 28, 2006).