Neo-Dhimmitude in Iran: Religious Hierarchy and Minority Life Under the Islamic Republic

Abstract

The Islamic Republic of Iran denies Zoroastrians and the Bahai’s equal citizenship even as it recognizes Zoroastrian religious identity. Under the 1979 constitution, Twelver Ja‘fari Shi‘ism is the official religion. The constitution recognizes only Zoroastrians, Jews, and Christians while excluding Baha’is from public life.

Consequently, Baha’is endure an extreme form of exclusion. Denied legal existence, they face systematic barriers to education (including university expulsion and raids on the Baha’i Institute for Higher Education), public and private employment, property ownership, and dignified burial rites. They also endure arbitrary arrests framed as security measures.

Zoroastrians endure controlled inclusion. Constitutionally recognized and allotted a parliamentary seat, they maintain rituals and associations under supervision, yet remain barred from high office, disadvantaged in public employment and inheritance. The state celebrates pre-Islamic heritage while constraining the living community.

These policies established and maintain Shi‘a supremacy in the Islamic Republic of Iran.

Introduction

Why do religious minorities in Iran continue to experience unequal legal and social treatment in a state that presents itself as the guardian of religious morality and constitutional order?[1] The question is not simply whether discrimination exists, but how it is organized, justified, and sustained across different categories of minority life.[2] In the Islamic Republic, religious identity is not a private matter alone; it is filtered through institutions, law, and political theology in ways that shape access to rights, visibility, and belonging.[3] This article begins with that puzzle and examines how minority status is constitutionally constructed, legally administered, and politically sustained within the governing logic of the Islamic Republic.

This question matters because religious freedom is often discussed in abstract terms, while the Iranian case shows how deeply it can be tied to citizenship, sovereignty, and state legitimacy.[4] When a government differentiates among communities not only by belief but by legal status, it transforms pluralism into hierarchy. Its consequences extend well beyond freedom of worship, shaping access to education, employment, political representation, public recognition, and ultimately the meaning of citizenship itself.[5] Understanding this process is therefore essential not only for studies of Iran, but also for broader debates on minority governance under authoritarian rule.

Existing scholarship and policy reporting have documented persecution, exclusion, and discrimination against Iran’s religious minorities, yet they often address these issues through separate, community-specific analyses.[6] What remains underexamined is the comparative structure that links these patterns together. Few studies, however, compare a constitutionally recognized religious minority with a constitutionally unrecognized religious community within a single analytical framework[7]. Why are some minorities denied recognition altogether, while others are recognized yet remain constrained? What kind of political order can produce both overt exclusion and controlled inclusion within the same constitutional framework? This article addresses that gap by comparing two communities whose experiences illuminate different layers of the same system.

The central argument is that the Islamic Republic governs religious diversity through a hierarchical order of belonging rather than through equal citizenship. To explain this order, the article employs neo-dhimmitude as an analytical framework for understanding how modern state power can reproduce graded forms of religious subordination without replicating the precise institutions of the premodern dhimma system. The Baha’i and Zoroastrian communities are particularly instructive because they occupy sharply different positions within Iran’s legal and political landscape. Their comparison reveals not only distinct forms of marginalization, but also the governing logic that organizes them.[8]

The study adopts a comparative qualitative approach. It draws upon constitutional provisions, legal and administrative documents, judicial practice, human rights reporting, and related documentary materials to trace how minority status is defined and enforced. The analysis combines legal interpretation with comparative case-study analysis to identify institutional patterns and the ideological continuities that sustain them.[9] Rather than treating each community as an isolated case, the article examines them together in order to identify recurring patterns in the state’s management of religious difference. This approach makes it possible to assess both institutional design and its lived consequences.[10]

The article proceeds in seven parts. The first section traces the conceptual movement from classical dhimma to neo-dhimmitude. The second examines the broader structure of religious hierarchy under the Islamic Republic. The third and fourth sections analyze the Baha’i and Zoroastrian communities, respectively. The fifth offers a comparative analysis of exclusion and controlled recognition. The sixth considers the implications for religious freedom, minority rights, and policy toward Iran. The final section presents the article’s conclusions.

1. From Classical Dhimma to Neo-Dhimmitude

The concept of dhimma emerged as one of the foundational legal institutions through which classical Islamic governance regulated the status of non-Muslim communities living under Muslim rule.[11] In its historical form, dhimma granted limited protection to the People of the Book in exchange for accepting a subordinate position within the Islamic order.[12] This arrangement was not simply a private religious accommodation; it was a public hierarchy that defined who could belong, on what terms, and under what conditions. Non-Muslims were permitted to live under Muslim sovereignty, but their protection came at the price of unequal status, restricted political authority, and a visible reminder that full membership in the ruling moral order belonged to Muslims alone.[13]

Over time, the practical application of dhimma varied across empires, regions, and historical periods. At times it functioned as a relatively stable mode of coexistence; at other times it became a harsher instrument of humiliation, taxation, and exclusion.[14] Yet its underlying logic remained consistent: non-Muslim communities were incorporated into the polity as tolerated subjects rather than equal citizens. Their place in society was legally recognized, but that recognition was conditional and asymmetrical. The classical system therefore established a durable template for differentiated belonging, one that linked religion to civil status and political hierarchy.

In modern scholarship, this legacy has often been revisited through the term neo-dhimmitude, a concept used to describe contemporary systems that reproduce similar forms of subordination in new institutional settings.[15] The term does not imply a mechanical repetition of medieval law. Rather, it refers to the transformation of older hierarchical logics into modern state structures, where exclusion may be administered through constitutions, bureaucracies, education systems, judicial practices, and official discourse instead of through overtly premodern legal codes.[16] Neo-dhimmitude thus names a political condition in which a state does not merely tolerate religious minorities, but governs them through graded rights, managed visibility, and institutionalized inequality.

The present study applies this analytical framework to the Islamic Republic of Iran because its constitutional order makes religious hierarchy legally visible while simultaneously presenting itself as a modern constitutional state. Articles 12 and 13 distinguish between officially recognized religious minorities and communities excluded from constitutional protection, thereby providing a useful point of departure for examining how religious hierarchy is institutionalized through law rather than expressed merely through political rhetoric.[17] The next section demonstrates how these historical principles are translated into the constitutional architecture of the Islamic Republic, where religious hierarchy is embedded not only in ideology but also in positive law and state institutions.

2. Religious Hierarchy under the Islamic Republic

The constitutional order of the Islamic Republic does not treat religion as one identity among others; it places religion at the center of the state’s political architecture. Article 12 establishes Twelver Ja‘fari Shi‘ism as the official religion of Iran, while also giving recognized status to other Islamic schools, and Article 13 extends formal recognition only to Zoroastrians, Jews, and Christians.[18] This arrangement creates a bounded pluralism: difference is acknowledged, but only within categories defined by the state and only on terms the state controls. Religious hierarchy is therefore not an incidental by-product of governance; it constitutes one of the organizing principles of the constitutional order itself.

Article 4 makes that hierarchy operative across the entire legal system. It requires all civil, penal, financial, economic, administrative, military, political, and other laws and regulations to be based on Islamic criteria, which means that the constitution does not merely protect religion; it subordinates law to a particular religious standard.[19] In principle, this makes Islam the benchmark against which legislation is measured, and in practice it ensures that minority rights remain conditional on compatibility with the state’s religious-legal order. Article 19, by contrast, speaks the language of equality by rejecting privilege on the basis of color, race, language, and similar attributes, yet it notably does not list religion among the protected grounds. The omission matters: it reveals that the constitution can affirm a general ideal of equality while leaving religious difference outside the strongest anti-discrimination language.[20]

That design becomes even more significant when read alongside the doctrine of velayat-e faqih, which anchors ultimate political authority in the guardianship of the Islamic jurist.[21] Under this principle, sovereignty is not merely constitutional in a procedural sense; it is moral and jurisprudential, vested in an interpretation of Islamic legitimacy that stands above ordinary political competition. In practice, this means that constitutional recognition does not produce equal civic standing. Instead, recognition operates as a mechanism of differentiation, separating communities permitted to exist within the system from the religious establishment empowered to define the system itself.[22]

The Guardian Council is the key institutional mechanism that translates this hierarchy into day-to-day governance. It reviews legislation for conformity with Islam and the constitution, and it also vets candidates for elected office, giving unelected clerical authority decisive leverage over both lawmaking and political participation.[23] Even when an elected legislature passes laws or when minority candidates secure votes, those outcomes remain vulnerable to reversal if they conflict with the Council’s understanding of Islamic legitimacy. The result is a polity in which formal procedures exist, but ultimate authority is reserved to bodies shaped by religious criteria rather than democratic competition.[24]

The consequence is a layered citizenship order. Formally recognized minorities can practice certain rites, maintain some communal institutions, and claim limited representation, yet these rights remain contingent upon compliance with Islamic criteria and administrative supervision.[25] Equal citizenship would mean that legal standing follows membership in the political community, not the state’s assessment of religious conformity. Formal recognition, however, works differently: it grants permission to exist and to exercise limited rights, while preserving the state’s power to narrow, supervise, or revoke those rights.[26] In this sense, recognition can coexist with hierarchy rather than undermine it. A community may be visible to the constitution and still remain structurally unequal before the law.

This hierarchy is sustained through law, but it is reinforced by ideology. Twelver Shi‘ism functions not only as the state religion but also as the normative horizon through which belonging is defined. Because the Islamic Republic ties public authority to this official religious identity, political inclusion becomes inseparable from theological conformity. That connection affects who can hold office, who can be trusted, who can teach, and whose testimony or community life is treated as socially and legally secure.[27] Even where minorities are formally protected, their protection takes the form of managed tolerance rather than equal citizenship.

Seen this way, the distinction between religious hierarchy and citizenship hierarchy is crucial. Religious hierarchy classifies communities according to their proximity to the state’s official creed; citizenship hierarchy determines the practical consequences of that classification in education, employment, representation, family law, and public life.[28] The two hierarchies reinforce one another. A community’s religious status shapes its civic possibilities, while its civic limits confirm its subordinate religious position. The result is a constitutional order in which equality is mediated through religious legitimacy rather than guaranteed through citizenship.

Beyond these formal mechanisms, the constitution also embeds hierarchy through selective rights and symbolic inclusion. Recognized minorities may receive limited protection in matters of personal status and religious observance, but these protections do not amount to equal participation in the political community. Their rights are framed as exceptions within an Islamic order rather than as expressions of neutral citizenship. This distinction matters because it allows the state to present itself as accommodating diversity while preserving a sharper boundary between the dominant religious majority and those who are merely tolerated. In effect, the constitution produces a hierarchy of presence: some communities are allowed to appear within the public order, but only in ways that confirm the Islamic framework that authorizes their presence.

Against this constitutional and ideological framework, the following two case studies illustrate how different legal classifications produce different forms of exclusion under the same governing system. The Bahai case shows what it means to be placed outside the constitutional order altogether, while the Zoroastrian case shows what it means to be recognized yet constrained. The following case studies demonstrate that these constitutional distinctions are not merely symbolic categories. They produce distinct legal realities through which the Islamic Republic administers religious diversity as a hierarchy of differentiated citizenship rather than a system of equal rights.

3. Case Study I — The Bahá’í Community

The Bahá’í faith emerged in nineteenth-century Iran from the religious ferment surrounding the Bábí movement. In 1844, Sayyid ‘Ali-Muhammad of Shiraz, known as the Báb, announced a new religious mission that challenged prevailing expectations within Shi‘a Islam and attracted followers across Iran. The movement was met with intense clerical and governmental opposition, culminating in the execution of the Báb in 1850 and widespread persecution of his followers. Bahá’u’lláh, one of the most prominent figures associated with the Bábí movement, subsequently declared that he was the messenger whose coming the Báb had foretold. His teachings became the foundation of the Bahá’í faith, which developed as a distinct religious community during the second half of the nineteenth century.

Although it originated in Iran, the Bahá’í faith developed a universal rather than ethnically or nationally bounded religious identity. Among its central teachings are the unity of humankind, the spiritual equality of human beings, the progressive character of divine revelation, and the importance of overcoming religious, racial, and national divisions. Bahá’í teachings also emphasize education, the harmony of science and religion, and the construction of social institutions capable of advancing cooperation across communal boundaries. The principle of the oneness of humanity occupies a particularly important place in Bahá’í thought and helps explain the community’s emphasis on education, social participation, and nonviolent forms of collective life.

From its beginnings, however, the Bahá’í community’s development in Iran was inseparable from recurrent persecution. Its emergence from a predominantly Shi‘a environment, combined with theological claims regarded by Shi‘a clerical authorities as incompatible with orthodox doctrine, placed the community in a persistently vulnerable position. Despite periods in which Bahá’ís were able to establish schools, charitable activities, administrative institutions, and relatively stable communities, their religious identity remained politically and socially contested. By the twentieth century, the Bahá’í community had become an established element of Iranian society while continuing to experience periodic campaigns of repression and exclusion. Bahá’í educational and community institutions functioned in Iran before 1979, but the establishment of the Islamic Republic transformed this older pattern of vulnerability into a far more systematic structure of state exclusion.

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This historical background is essential to understanding the community’s position under the Islamic Republic. Bahá’ís are not a recently arrived or foreign religious population; the faith itself originated in Iran and its adherents have participated in Iranian social life for generations. Yet the post-1979 constitutional order does not recognize the Bahá’í faith among Iran’s protected religious minorities. The resulting contradiction is central to the present case study: a religion born in Iran has been placed outside the Islamic Republic’s constitutionally recognized religious order. It is from this position of non-recognition that many of the subsequent restrictions on Bahá’í education, employment, property, institutional life, and political belonging have developed.

The experience of the Bahá’í community represents the clearest illustration of how the Islamic Republic transforms religious difference into a system of institutional exclusion. Unlike recognized minorities whose presence is managed within the constitutional order, Bahá’ís are placed outside it altogether, not simply as a disadvantaged group but as a community whose legal existence is repeatedly denied in practice and in official discourse.[29] This exclusion is not episodic. It is structural, extending across education, work, property, public memory, and the ability to reproduce community life.[30] The result is a form of state power that does not merely punish individual Bahá’ís, but seeks to render Bahá’í collective life fragile, invisible, and easily interrupted.[31]

That exclusion is visible first in the legal and constitutional domain. The post-1979 order did not recognize Bahá’ís among the protected religious minorities, Successive state policies have treated the Bahá’í faith not as a religion entitled to constitutional protection but as a politically suspect movement lacking legitimate legal standing.[32] This matters because constitutional non-recognition does more than withhold symbolic inclusion; it creates the conditions for downstream discrimination across the entire administrative system. In the Iranian case, the absence of protection is itself productive: it authorizes officials, courts, schools, and employers to treat Bahá’ís as outside the normal rights-bearing community.[33]

Education has long been one of the most powerful instruments of this exclusion. Bahá’í children have faced pressure to conceal their identity, and Bahá’í students have been systematically blocked from university admission, expelled once identified, or forced to deny their faith in order to register.[34] The community’s response has been both resilient and deeply revealing of the state’s hostility. When barred from formal higher education, Bahá’ís helped create the Bahá’í Institute for Higher Education (BIHE), an improvised and nonviolent educational network designed to preserve learning under conditions of systematic denial.[35]

The state repeatedly targeted this effort as well, raiding instructors, confiscating materials, and treating education itself as a site of repression rather than a neutral public good.[36] The creation of BIHE illustrates not only resilience but also the emergence of parallel civil institutions when access to state institutions is systematically denied. The emergence of BIHE also demonstrates that systematic exclusion may generate parallel institutions outside the state, thereby revealing both the resilience of the community and the limits of state control.

Employment reveals the same pattern at the level of livelihood. Bahá’ís have been barred from public-sector jobs, denied promotions, and excluded from many forms of government service.[37] In many cases, even private employment has not offered real security: employers have been pressured to dismiss Bahá’í workers once their identity became known, while professional licenses and trade permits have been withheld or revoked. The effect is economic suffocation rather than isolated hardship. When a state blocks education and employment simultaneously, it does not simply limit opportunity; it narrows the horizon of social continuity across generations.[38]

The campaign has also extended into the material infrastructure of community life. Property confiscation has been central to the persecution, affecting homes, businesses, administrative buildings, and communal assets.[39] Bahá’í cemeteries have been vandalized, seized, or denied ordinary protections, turning the dead as well as the living into targets of administrative control.[40] These acts are not random desecrations. They are part of a broader strategy of erasure that attacks the places through which memory, belonging, and continuity are reproduced. When cemeteries are denied dignity and businesses are denied legitimacy, the state is not merely restricting rights; it is interrupting the social reproduction of a religious community.[41]

Arrests and imprisonment complete this architecture of pressure. Since the revolution, Bahá’ís have been arrested, detained, interrogated, and in many cases prosecuted on charges framed in security terms rather than openly religious ones.[42] The securitization of Bahá’í identity serves an important political function by reframing religious discrimination as the neutral enforcement of national security and public order. Yet the consistency of the pattern makes the underlying logic hard to miss. The state does not only respond to individual acts; it repeatedly treats Bahá’í affiliation itself as grounds for suspicion.[43] This logic has been sustained by propaganda that portrays Bahá’ís as enemies, spies, or agents of foreign influence, reinforcing a climate in which repression appears justified as national defense.[44]

What emerges from these different domains is a coherent system of exclusion. Bahá’ís are not simply denied one right after another; rather, the denial of one sphere of life reinforces the denial of the next. Exclusion from university helps produce exclusion from employment. Exclusion from employment increases vulnerability to confiscation and licensing pressure. Confiscation, in turn, weakens the community’s institutions, while arrests intensify fear and reduce the space for collective action.[45] The state thus governs Bahá’í life through cumulative attrition: a steady compression of legal status, social visibility, and economic capacity.[46]

This is why the Bahá’í case is analytically central to the argument of this article. It shows the extreme end of the hierarchy produced by the Islamic Republic: a community outside the constitutional circle of recognition, managed through a combination of legal invisibility, bureaucratic obstruction, and punitive coercion.[47] If the Zoroastrian case reveals controlled inclusion, the Bahá’í case reveals the logic of complete containment. Taken together, the Bahá’í and Zoroastrian cases demonstrate that the Islamic Republic does not merely differentiate among religious minorities; it institutionalizes unequal citizenship through a structured hierarchy of recognition, exclusion, and political belonging.

The Bahá’í experience demonstrates that the Islamic Republic does not merely deny rights; it restructures the very conditions under which a religious community can survive, reproduce itself, and remain visible within public life.

The Bahá’í experience therefore reveals not merely the persecution of a single religious community, but the operation of a constitutional and administrative order in which exclusion itself becomes an instrument of governance. It is this logic of institutionalized exclusion that provides the benchmark against which the experience of constitutionally recognized minorities, particularly the Zoroastrian community, can be meaningfully understood.[48]

4. Case Study II — The Zoroastrian Community

Zoroastrianism is one of the oldest religious traditions associated with Iran and occupies a distinctive place in the country’s historical and cultural development. Its teachings are traditionally associated with Zarathustra, or Zoroaster, and center on devotion to Ahura Mazda, moral responsibility, and the human obligation to choose truth and right action in a world characterized by the struggle between constructive and destructive forces. The ethical ideal commonly summarized as “good thoughts, good words, and good deeds” remains one of the most recognizable formulations of Zoroastrian religious life and continues to shape contemporary Zoroastrian understandings of moral identity.

For centuries before the Islamic conquest of Iran, Zoroastrian traditions were deeply intertwined with Iranian political culture and religious life. The religion became particularly significant under the great pre-Islamic Iranian empires, and Zoroastrian institutions, texts, rituals, and ethical concepts became part of the country’s civilizational inheritance. The Islamic conquest dramatically altered the community’s political position. Zoroastrians gradually became a religious minority under Muslim rule, and over subsequent centuries substantial portions of the population converted to Islam. Other Zoroastrians preserved their ancestral religion in Iran, while some migrated to India, where their descendants became known as the Parsis.

The survival of a Zoroastrian community inside Iran is therefore historically significant. By the nineteenth and twentieth centuries, major Zoroastrian communities were concentrated particularly in Yazd and Kerman, while social reform, educational development, migration, and ties with Parsi communities abroad contributed to changes in communal life. In modern Iran, Zoroastrians came to occupy an unusual position: they represented a small living religious minority, yet at the same time their faith was inseparable from a much larger national memory of pre-Islamic Iran. This distinction between Zoroastrianism as celebrated heritage and Zoroastrians as living citizens would become politically important under the Islamic Republic.

Unlike the Bahá’í faith, Zoroastrianism is explicitly recognized by the constitution of the Islamic Republic as one of Iran’s protected religious minorities. That recognition permits communal religious life and limited institutional and political representation, including a reserved parliamentary seat. Yet recognition has never meant full civic equality. The historical significance of the Zoroastrian case therefore lies precisely in this tension: the state acknowledges the religion as both an ancient component of Iranian civilization and a legally recognized minority faith, while continuing to define the boundaries within which the living community may participate in political and social life. This makes the Zoroastrian experience especially useful for examining the distinction at the heart of this article between constitutional recognition and equal citizenship.

The Zoroastrian case illustrates the second model of neo-dhimmitude identified in this study: not exclusion through constitutional invisibility, but subordination through managed recognition. Zoroastrians are constitutionally recognized, politically visible, and culturally legible within Iranian public memory, yet their recognition remains conditional and carefully bounded. The state admits the community into the legal order while preserving the power to supervise its institutions, narrow its rights, and define the terms on which Zoroastrian identity may appear in public life. In that sense, this case is not about full inclusion; it is about managed inclusion.[49]

This managed inclusion rests on a long and contradictory history. Zoroastrianism is deeply embedded in Iran’s civilizational self-image, and the Islamic Republic often celebrates pre-Islamic antiquity as part of the national past. At the same time, the living Zoroastrian community that carries this heritage continues to face restrictions in law and practice. [50] That distinction between heritage and the living community is central. The state may applaud Iran’s ancient cultural depth, but it does not therefore grant equal civic standing to the minority that embodies that past. The result is a politics of selective remembrance: pre-Islamic symbols are welcomed when they can be folded into national narrative, but the people attached to those symbols remain subject to administrative restraint.[51]

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Constitutional recognition gives Zoroastrians a formal foothold. The constitution identifies them as a recognized religious minority and permits them to perform rites and ceremonies within the limits of the law.[52] They also enjoy a reserved seat in parliament, which gives the appearance of representation and signals that the state acknowledges the community as part of the national body.[53] Yet this recognition is not equivalent to equality. It does not remove the wider constitutional architecture in which Islamic criteria define the outer limits of law, office, and public legitimacy. The community is visible, but only as a minority whose visibility is already framed by the state’s religious order.[54]

Representation has therefore remained symbolic more than transformative. The parliamentary seat can communicate inclusion, but it cannot by itself alter the structural conditions under which Zoroastrians participate in public life. The episode of Sepanta Niknam’s [55]suspension from the Yazd city council is especially telling: it showed that electoral success could still be challenged when a Zoroastrian’s presence appeared to violate the religious expectations of the system. The Niknam case demonstrates that constitutional recognition does not immunize minority participation from ideological intervention. Electoral legitimacy remains subordinate to the religious legitimacy claimed by the state.[56]

In other words, representation exists, but it is exposed to veto by the institutions that guard the state’s Islamic character. The message is clear: a minority may be elected, but it may not fully define the political space in which it is elected.

The Sepanta Niknam Case: The Limits of Recognized Citizenship

The case of Sepanta Niknam provides one of the clearest illustrations of the tension between constitutional recognition and equal political participation in the Islamic Republic. Niknam, a Zoroastrian economist and a prominent member of the Zoroastrian community in Yazd, was first elected to the Yazd City Council in 2013. His religious identity was neither concealed nor incidental to his candidacy. He openly campaigned as a Zoroastrian and won more than 20,000 votes. Four years later, in the May 2017 local elections, he ran again and was reelected with 21,717 votes, demonstrating that his political legitimacy extended well beyond Yazd’s relatively small Zoroastrian community and included Muslim voters as well.

The controversy surrounding his second election exposed a fundamental contradiction within the Islamic Republic’s treatment of recognized religious minorities. Shortly before the May 2017 elections, Guardian Council chairman Ahmad Jannati declared that non-Muslims should not be permitted to represent Muslim-majority constituencies, arguing that such representation was incompatible with Islamic law. Yet existing legislation governing local councils permitted adherents of religions recognized under Articles 12 and 13 of the constitution—including Zoroastrians, Jews, and Christians—to stand for local office. Parliament maintained that the existing law allowed Niknam’s candidacy, producing a direct conflict between statutory political participation and the Guardian Council’s interpretation of Islamic criteria.

After Niknam’s reelection, Ali Asghar Bagheri, a Muslim candidate who had failed to win a council seat, challenged his membership. Branch 45 of the Administrative Court subsequently ordered Niknam’s temporary suspension from the Yazd City Council. The significance of the decision extended far beyond one municipal office. Niknam had been legally permitted to run, had already served a full term, and had again been chosen by the electorate. His removal therefore raised a more fundamental question: could the votes of Muslim citizens legitimately place a constitutionally recognized non-Muslim in a position of political authority over a Muslim-majority constituency? The dispute revealed that electoral legitimacy and formal religious recognition could still be subordinated to an ideological interpretation of the state’s Islamic character.

The suspension triggered an unusually visible institutional conflict. Parliament Speaker Ali Larijani and other lawmakers opposed the exclusion of recognized religious minorities from local elections, while President Hassan Rouhani also publicly criticized the treatment of Niknam. Parliament attempted to amend the law explicitly to affirm the right of constitutionally recognized minorities to run in local elections, but the Guardian Council rejected the amendment. The disagreement eventually produced a formal deadlock between Parliament and the Guardian Council and was referred to the Expediency Council under Article 112 of the constitution.

Niknam remained unable to exercise his elected mandate for approximately nine months. In July 2018, however, the Expediency Council resolved the institutional dispute by a two-thirds majority and affirmed the right of members of constitutionally recognized religious minorities to stand in local council elections. Niknam subsequently reclaimed his seat on the Yazd City Council. The outcome restored his individual political position and established an important protection for recognized religious minorities in local elections. Yet the fact that such an intervention was necessary is itself analytically significant. A Zoroastrian citizen who had twice won the support of voters had been removed from office because his religious identity was deemed potentially incompatible with exercising authority in a Muslim-majority constituency.

There is no publicly available evidence indicating that Sepanta Niknam was required to make personal gestures of political submission in order to regain his seat. Contemporary accounts instead attribute his reinstatement to a prolonged institutional dispute involving Parliament, the Guardian Council, the Rouhani administration, and ultimately the Expediency Council, accompanied by significant public controversy over his suspension. In July 2018, the Expediency Council ruled in favor of the right of constitutionally recognized religious minorities to stand in local council elections, clearing the way for Niknam to return to the Yazd City Council.[57]

The Niknam case therefore captures the central paradox of Zoroastrian citizenship under the Islamic Republic. Constitutional recognition provides Zoroastrians with protections and avenues of participation that are denied to unrecognized communities such as the Bahá’ís, but those rights are neither self-executing nor immune from ideological challenge. Recognition creates political space, yet institutions charged with protecting the Islamic character of the state retain the capacity to contest the boundaries of that space. Niknam ultimately prevailed, but only after a prolonged confrontation among the judiciary, Parliament, the Guardian Council, the executive branch, and the Expediency Council.

For the purposes of neo-dhimmitude, the importance of the case lies precisely in this distinction. Niknam was not excluded because Zoroastrianism lacked constitutional recognition; he was challenged despite that recognition. His experience demonstrates that formal inclusion does not necessarily produce equal citizenship when religious hierarchy remains embedded in the institutions that determine the permissible limits of political participation. The case thus transforms “managed recognition” from an abstract description into an observable institutional process: the minority citizen may participate, may be elected, and may even prevail, but the boundaries of that participation remain subject to negotiation with a political order in which religious legitimacy can supersede civic equality.

The practical limits on Zoroastrian life are equally important. Conversion is not treated as a neutral private choice but as a politically charged boundary,[58] because the state’s legal and social order is structured to discourage religious movement away from Islam and to police the public visibility of non-Muslim identity.[59] In personal status matters, Zoroastrians retain some communal life, but that autonomy exists under a broader system in which family law is never fully detached from religious hierarchy. The same is true of inheritance, where legal equality does not operate on a neutral basis but remains shaped by the state’s broader confessional logic.[60] Even where explicit coercion is absent, the structure itself creates asymmetry.

The consequences can be particularly stark in inheritance disputes. Under Article 881 bis of Iran’s Civil Code, religious identity can determine whether an heir is legally entitled to inherit: where a non-Muslim dies and a Muslim heir exists among the potential heirs, the Muslim heir may take precedence over non-Muslim relatives who would otherwise inherit according to ordinary degrees of kinship. For a Zoroastrian family, the practical consequence is that conversion by one family member to Islam can alter the distribution of an estate and potentially disadvantage relatives who remain Zoroastrian. The rule therefore carries consequences beyond the disposition of property after death. It introduces religious hierarchy directly into family relationships, creating the possibility that differences of faith within the same family may determine access to assets accumulated across a lifetime.

Employment and political advancement make that asymmetry especially concrete. Zoroastrians face severe disadvantages in access to public-sector employment, and their paths into high government positions are effectively blocked.[61] They are also excluded from many institutions of authority, which means that recognition does not translate into meaningful access to state power. This is one of the clearest signs that the Islamic Republic distinguishes between being formally present in the nation and being entitled to shape the state. The former is permitted; the latter is reserved. The community may be represented, but it is not empowered.

The associations that sustain Zoroastrian communal life are similarly constrained. They are important institutions of memory, education, and welfare, but they operate under supervision and must report to state authorities.[62] This creates a pattern of supervised community life: Zoroastrian organizations may preserve identity, teach youth, and organize ritual life, yet they do so in an environment where their autonomy is partial and contingent. Their institutions are tolerated as long as they remain legible to the state and do not challenge the Islamic framework that encloses them.[63]

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Ancient celebrations such as Sadeh and Mehregan continue to attract attention. Sadeh, whose name is associated with “one hundred,” is traditionally observed fifty days and fifty nights before the arrival of spring and is marked most visibly by the lighting of a large communal fire, symbolizing light, warmth, and the triumph over the darkness of winter. Mehregan, an ancient autumn festival associated with Mehr (Mithra), traditionally celebrates friendship, covenant, gratitude, and the harvest. Both festivals connect contemporary Zoroastrian religious and communal life to traditions deeply rooted in pre-Islamic Iranian civilization.[64] But public participation is often restricted, and the government’s willingness to treat these festivals[65] as heritage does not extend to granting the Zoroastrian community unconstrained public space.

These restrictions can be quite literal. Authorities have at times limited attendance at Zoroastrian celebrations to members of the community, preventing the broader public from entering festival sites or participating in ceremonies. In January 2025, for example, public participation in Sadeh celebrations was restricted even as interest in the festival was reportedly growing among non-Zoroastrian Iranians. Such measures allow the state to tolerate the ceremony as a bounded minority or heritage event while limiting its transformation into a larger public expression of pre-Islamic Iranian identity.

The same ceremonies that can be celebrated as proof of Iran’s ancient richness are, for the community itself, sites of managed permission. The state celebrates the memory of ancient Persia more readily than it accepts the autonomy of the community that preserves that memory. The Islamic Republic frequently celebrates pre-Islamic heritage as a component of national history while maintaining political and legal constraints on the living Zoroastrian community that embodies that heritage.[66]

At the same time, the community has not remained static. One of the most striking developments in recent years has been a revival of Zoroastrian identity among younger Iranians. For some, Zoroastrianism offers not merely a religion but a language of cultural authenticity,[67] ethical continuity, and historical rootedness that stands in contrast to the official ideological vocabulary of the state.[68] This revival does not mean that the community has escaped constraint. Rather, it shows that identity can intensify even when institutional power remains limited. Younger Iranians may turn toward Zoroastrian symbols, moral language, or heritage as a way of imagining a more indigenous and less coerced Iranian self-understanding.[69]

Available survey evidence suggests that this phenomenon may extend beyond simple historical curiosity, although its meaning requires caution. GAMAAN’s 2020 survey on Iranian attitudes toward religion found that only about one-third of respondents identified as Shi‘a Muslim, while approximately 7.7 percent identified themselves as Zoroastrian. The same survey found substantial movement away from organized religion more broadly. These findings should not be interpreted as evidence that millions of Iranians have formally converted to Zoroastrianism. Rather, Zoroastrian self-identification may encompass religious belief, cultural identification, political rejection of the Islamic Republic’s imposed religious order, or a broader attempt to reconnect Iranian identity with its pre-Islamic past. In this sense, the contemporary attraction of Zoroastrianism may function for some Iranians less as conventional conversion than as an alternative language of identity through which to distance themselves from the state’s coercive use of Shi‘a Islam.

Yet the practical obstacles remain severe. Demographic decline, migration, intermarriage[70], and the difficulty of sustaining small institutions all continue to weaken communal continuity.[71] Zoroastrian identity can therefore expand as a cultural reference point even while the community’s institutional life contracts.[72] That tension is important: it shows that symbolic revival is not the same as structural recovery. The living community must still contend with constrained schools, supervised associations, restricted work opportunities, and limited access to high office. [73] The state may preserve the image of Zoroastrian heritage, but it does not permit that heritage to develop into a fully vibrant and autonomous social force.[74]

This is why the Bahá’í case is analytically central to the argument of this article. It represents the extreme end of the hierarchy produced by the Islamic Republic: a community placed outside the constitutional circle of recognition and governed through legal invisibility, bureaucratic obstruction, and punitive coercion. If the Zoroastrian case illustrates controlled inclusion, the Bahá’í case reveals institutionalized exclusion. Together, the two case studies demonstrate that the Islamic Republic does not merely differentiate among religious minorities; it structures unequal citizenship through differentiated forms of legal recognition and political belonging. More fundamentally, the Bahá’í experience shows that exclusion is not simply the denial of rights. It is a constitutional technology of governance through which the state reshapes the conditions under which a religious community can survive, reproduce itself, and remain visible within public life.

The Zoroastrian experience therefore demonstrates that constitutional recognition, by itself, does not eliminate religious hierarchy. Rather, it reveals a more sophisticated mode of governance in which recognition becomes an instrument of regulation rather than equality. Read alongside the Bahá’í case, it confirms the central argument of this study: the Islamic Republic administers religious diversity through differentiated forms of legal recognition, institutional control, and unequal citizenship, all designed to preserve the supremacy of the state’s official interpretation of Twelver Shi’a Islam.[75]

The Zoroastrian experience therefore demonstrates that constitutional recognition, by itself, does not eliminate religious hierarchy. Rather, it reveals a more sophisticated mode of governance in which recognition becomes an instrument of regulation rather than equality. Read alongside the Bahá’í case, it becomes evident that the critical question is not whether minorities are recognized, but how different forms of recognition and exclusion operate within a single constitutional order. The following comparative analysis develops this argument by examining how these two distinct legal statuses ultimately serve the same architecture of ideological rule.

5. Comparative Analysis

The comparison between the Bahá’í and Zoroastrian communities shows that the Islamic Republic does not apply a single uniform model of minority governance. It uses a graded system in which some communities are excluded from constitutional recognition altogether, while others are admitted into the legal order but only under supervision. In that sense, the difference between the two cases is real, but it is not a difference between freedom and oppression. It is a difference between exclusion and controlled inclusion inside one ideological structure.[76]

The Bahá’í case illustrates the most severe form of that structure. Bahá’ís are denied constitutional recognition and are therefore positioned outside the circle of legitimate religious belonging. This exclusion is not symbolic only; it has direct consequences in education, employment, property rights, and state interaction. As this research shows, their status is not simply “limited recognition” but a more radical form of non-recognition in which the community is treated as ideologically illegitimate and administratively disposable.[77] The state’s message is not that Bahá’ís belong in a subordinate position; it is that they do not belong within the constitutional framework at all.[78]

The Zoroastrian case occupies a different point on the same spectrum. Zoroastrians are recognized by the constitution and are therefore granted a visible place in the state’s legal vocabulary. They can invoke certain rights, maintain communal institutions, and hold a reserved parliamentary seat. Yet this recognition does not free them from hierarchy. Their rights remain narrow, their representation symbolic, and their autonomy partial. The state permits Zoroastrian existence, but only in forms compatible with Islamic criteria and administrative oversight.[79] Recognition therefore functions as a boundary mechanism: it separates those who may live inside the system from those who may not, while preserving the state’s power to decide what “inside” means.[80]

This is why the distinction between “inside recognition” and “outside protection” matters analytically. Bahá’ís are outside constitutional protection, which makes their exclusion immediate and systemic. Zoroastrians are inside constitutional recognition, but that inclusion is conditional and supervised. The first model produces erasure; the second produces containment. Both serve the same political project: the preservation of a single ideological order defined by Twelver Shi‘ism and guarded by institutions that translate theology into law.[81]

The difference between the two communities is also visible in the way the state handles visibility. Bahá’ís are rendered invisible or suspect, so that ordinary life becomes impossible. Zoroastrians, by contrast, are visible enough to be celebrated as part of Iran’s historical inheritance, but not empowered enough to convert that visibility into equal citizenship. This is where the heritage/community distinction becomes crucial. The regime may praise ancient Iranian civilization, pre-Islamic festivals, or Zoroastrian roots as part of a national narrative, yet it still constrains the actual community that embodies that legacy. In other words, the state can celebrate symbols while restricting subjects.[82]

The comparison therefore reveals a deeper structural continuity. The Islamic Republic does not operate through a simple binary of inclusion and exclusion. Instead, it distributes minority status across a hierarchy of legal forms: denial, recognition, supervision, and symbolic incorporation. Bahá’ís occupy the zone of denial; Zoroastrians occupy the zone of recognition without equality. But both zones are governed by the same sovereign logic. The state remains the final interpreter of legitimacy, and that legitimacy is religious before it is civic.[83]

This is the key point: the contrast between the two communities does not show inconsistency in the system; it shows how the system works. A regime that can deny one minority a legal existence while granting another a limited and supervised one is not moving between tolerance and intolerance. It is operationalizing hierarchy through differentiated legal treatment. The Bahá’í case reveals the logic of outright exclusion. The Zoroastrian case reveals the logic of controlled inclusion. Together, they show that the Islamic Republic manages religious diversity not by equalizing difference, but by ranking it.[84]

The theoretical value of this comparison is therefore substantial. It demonstrates that “recognition” can itself be a technique of domination when it is embedded in an order that reserves ultimate authority to a single religious ideology. It also shows why the language of equal citizenship is more demanding than the language of formal recognition. Equal citizenship would require that the state treat religious identity as irrelevant to the basic distribution of rights and political standing. The Iranian model does the opposite: it uses religious identity to determine the depth of protection, the scope of representation, and the degree of permissible belonging.[85]

Seen together, Bahá’ís and Zoroastrians expose the full range of neo-dhimmitude in contemporary Iran. One community is excluded from the constitutional community of rights; the other is admitted into it under constraint. The first is denied recognition; the second is granted recognition without equality. Both, however, remain subordinated to one ideological system that translates Twelver Shi‘a supremacy into constitutional and administrative practice.

Taken together, these two case studies demonstrate that the Islamic Republic does not simply classify religious minorities differently. It constitutionalizes difference by transforming recognition into a graded system of citizenship, visibility, and political belonging. Neo-dhimmitude, in this sense, is not merely a historical analogy; it is a contemporary mode of governance through which religious hierarchy is reproduced in constitutional and administrative form.[86]

The Zoroastrian experience therefore demonstrates that constitutional recognition, by itself, does not eliminate religious hierarchy. Instead, it exposes a more sophisticated mechanism of governance in which recognition itself becomes an instrument of regulation rather than equality. Read together, the Bahá’í and Zoroastrian experiences reveal that the decisive issue is not the presence or absence of legal recognition, but the different constitutional techniques through which the state organizes religious hierarchy. It is this underlying logic that the following comparative analysis seeks to explain.

6. Policy Implications

The comparative evidence presented in this article suggests that the treatment of religious minorities in Iran is not an isolated human-rights problem but a defining characteristic of the Islamic Republic’s constitutional order. Consequently, effective policy cannot focus solely on individual violations; it must address the institutional architecture that produces them. The constitutional and administrative hierarchy that shapes the lives of Bahá’ís and Zoroastrians shows that discrimination is embedded in law, not merely in practice. That means international responses should not treat individual abuses as isolated incidents; they should address the system that produces them. Recent USCIRF reporting continues to describe Iran as a country where violations of freedom of religion or belief remain systematic and severe, with Bahá’ís among the communities most targeted.[87]

More fundamentally, policymakers should avoid interpreting limited administrative concessions as indicators of structural reform. Because religious hierarchy is embedded in constitutional design rather than administrative discretion, isolated improvements affecting individual communities cannot by themselves demonstrate meaningful institutional change.

For a human-rights framework, the first implication is that formal recognition should never be confused with equality. In other words, policymakers should evaluate religious freedom in Iran through institutional indicators rather than isolated incidents. The Zoroastrian case shows that a minority can be constitutionally recognized and still remain subject to supervision, restricted representation, and practical exclusion from higher levels of power. The Bahá’í case goes further, showing that non-recognition itself becomes a tool of exclusion across education, employment, burial, and property. Human-rights policy therefore needs to distinguish between symbolic accommodation and effective rights protection. A state can celebrate diversity rhetorically while preserving a hierarchy that systematically limits minority life.[88]

This is why the issue belongs squarely within international policy rather than being treated as a purely domestic Iranian matter. The repression documented in the sources of this research affects not only private belief but also public institutions: schools, workplaces, cemeteries, businesses, and communal associations. Human Rights Watch describes Iran’s treatment of Bahá’ís as a crime against humanity of persecution, underscoring the severity of the pattern. When repression is this coordinated, international monitoring, documentation, and diplomatic pressure are not optional; they are necessary forms of accountability.[89]

For U.S. policy, the central point is that religious freedom should remain part of the core language used in any engagement with Tehran. USCIRF has repeatedly urged the United States to designate Iran as a Country of Particular Concern and to make improvement in religious freedom a central benchmark of policy. That approach is consistent with the structure revealed by the evidence presented in this article: since religious hierarchy is built into the state’s legal design, U.S. policy should not assume that marginal administrative concessions are enough. Pressure should target the institutions that reproduce exclusion, including the legal framework governing education, employment, representation, and property.

At the same time, the policy response should not be limited to sanctions rhetoric. Effective policy also requires support for documentation, public reporting, and transnational advocacy networks that protect vulnerable communities and preserve evidence. This is especially important when the state seeks to recast persecution as ordinary law enforcement. Supporting independent reporting helps prevent that normalization. The 2024 HRW report on Bahá’ís and the 2025 USCIRF update both show that the pattern remains active and adaptive, not historical or residual.[90]

A second recommendation is to support cultural and academic exchange while protecting minority communities from state retaliation. Religious minorities inside Iran often live under pressure precisely because their institutions are fragile and highly visible. International engagement that preserves educational links, scholarly attention, and diaspora networks can help sustain communities that the state seeks to fragment. USCIRF has long recommended reducing barriers to unofficial cultural and academic exchange, and that remains relevant here.[91]

The broader diplomatic lesson is that any policy toward Iran should recognize the difference between heritage and living community.[92] The Islamic Republic can appropriate pre-Islamic symbols as national culture while continuing to constrain the actual communities associated with those symbols. It can also deny a community recognition altogether while still benefiting from the fact that it exists as a global human-rights issue. Policy must therefore avoid being misled by ceremonial inclusion or nationalist symbolism. What matters is not whether the regime occasionally celebrates diversity, but whether it allows minorities to live with equal dignity and security.[93]

In practical terms, the United States and its partners should prioritize four measures. First, maintain public and multilateral pressure on Iran regarding violations of freedom of religion or belief. Second, support documentation of abuses and the preservation of evidence for future accountability. International organizations should continue documenting systematic discrimination while preserving evidence for future legal accountability.

Third, democratic governments should strengthen academic, cultural, and civil-society engagement with vulnerable minority communities both inside Iran and throughout the diaspora. Finally, future diplomatic engagement with Tehran should recognize that the treatment of religious minorities reflects the constitutional logic of the state itself rather than temporary administrative practice. These steps do not solve the structural issue on their own, but they align policy with the reality in this article demonstrates: in Iran, religious hierarchy is built into the system itself.

Ultimately, the evidence presented in this article suggests that neo-dhimmitude in contemporary Iran should be understood not as a historical survival of classical Islamic governance, but as a modern constitutional strategy through which unequal citizenship is institutionalized, religious hierarchy is normalized, and ideological supremacy is preserved.[94]

In sum, effective policy depends upon an accurate diagnosis of the problem. The challenge is not merely the persistence of discrimination against particular religious communities, but the constitutional and ideological structure that produces differentiated citizenship as a principle of governance. The concluding section draws together these findings and considers their broader implications for the study of religion, constitutionalism, and minority rights in contemporary Iran.

Conclusion

This article has argued that religious inequality in the Islamic Republic is not merely the product of sporadic discrimination, local prejudice, or inconsistent enforcement. It is built into the constitutional and political architecture of the state itself. The framework of velayat-e faqih, together with Articles 4, 12, 13, and the authority of the Guardian Council, creates a legal order in which Twelver Shi‘ism is not simply the majority religion but the interpretive center of sovereignty. In that order, religion is not one identity among others. It becomes a criterion of political legitimacy, a basis for legal classification, and a mechanism through which the state distributes inclusion and exclusion.[95]

The comparative study of the Bahá’í and Zoroastrian communities makes this logic especially clear. The Bahá’í community occupies the most extreme position in the hierarchy: it is excluded from constitutional recognition and treated as a presence that the state neither protects nor fully admits into the legal community. That exclusion produces cumulative effects across every domain examined in this article—education, employment, property, burial, and the right to sustain communal life. Human Rights Watch has described Iran’s treatment of Bahá’ís as systematic persecution that may amount to a crime against humanity, while recent reporting continues to document arrests, prison sentences, confiscations, and intensified pressure on Bahá’í women.[96] The pattern is not incidental. It reflects a state strategy of denying equal civic existence to a community defined as ideologically suspect.[97]

The Zoroastrian case demonstrates a different, but still subordinated, form of minority management. Zoroastrians are formally recognized by the constitution, represented by a reserved parliamentary seat, and permitted limited religious practice. Yet their inclusion remains conditional, supervised, and structurally inferior. Their public identity is tolerated so long as it fits within the boundaries of an Islamic political order that remains under clerical guardianship.[98] In this sense, recognition is not equivalent to equality. It is a controlled form of visibility, one that permits the community to exist while preventing it from becoming an autonomous source of political or legal authority. The distinction between formal recognition and equal citizenship is therefore not semantic; it is the core of the constitutional hierarchy itself.[99]

The broader comparative implication is that the Islamic Republic governs religious diversity through graded status rather than uniform rights. Bahá’ís are placed outside the constitutional community of protection, while Zoroastrians are placed inside it but under supervision. One community is denied recognition; the other is granted recognition without full rights. Both are bound by the same ideological structure, and both reveal the same principle: the state does not neutralize religion in public life but incorporates it into the mechanisms through which political belonging is assigned.[100] This is why the article’s conceptual language of neo-dhimmitude is analytically useful. It captures a system in which unequal status is not residual or accidental, but normalized through law, administration, and ideological discipline.

Neo-Dhimmitude and the Five Core Social Motives

Susan Fiske’s core social motives approach offers a useful framework for understanding how neo-dhimmitude affects not only individual rights but also the capacity of minority communities to sustain themselves. Fiske identifies five fundamental social motives—belonging, understanding, control, self-enhancement, and trust, summarized by the acronym BUC(k)ET. Individuals and communities are more likely to flourish when they can experience social acceptance, make sense of their environment, exercise meaningful control over resources and outcomes, maintain a positive sense of worth, and trust the institutions and people around them.[100]

Viewed through this framework, the distinction between the Bahá’í and Zoroastrian experiences becomes especially revealing. Bahá’ís confront systematic exclusion, while Zoroastrians experience recognized but constrained inclusion. Both arrangements can interfere with the social conditions that allow minority communities to remain cohesive and viable, although the mechanisms and severity differ substantially.

Belonging is weakened most directly for Bahá’ís by constitutional non-recognition. They remain Iranian citizens, yet their faith has no recognized place within the Islamic Republic’s official religious order. Restrictions involving education, employment, burial, property, and communal institutions reinforce this exclusion. Zoroastrians formally belong within the constitutional system, but that belonging can remain conditional; the Sepanta Niknam case demonstrates how even an elected member of a recognized minority could see his political participation challenged on religious grounds.

Understanding is affected when citizenship becomes unpredictable. Bahá’ís may possess citizenship while their religious community remains legally invisible; Zoroastrians may possess constitutional recognition while discovering that recognition does not always guarantee equal treatment. In both cases, religious identity complicates the ability to understand citizenship as a stable and consistently applied status.

Control is undermined when religious hierarchy limits access to resources and institutions. Educational and employment restrictions, property confiscation, licensing pressures, and interference with communal organization reduce the ability of Bahá’ís to shape their individual and collective futures. Zoroastrians retain substantially greater institutional space, but restrictions involving political advancement, public employment, inheritance, conversion, associations, and public religious activity can similarly constrain communal autonomy.

Self-enhancement is affected when the state attaches unequal civic value to religious identity. Bahá’ís face non-recognition and stigmatization that can communicate institutional inferiority. Zoroastrians encounter a different contradiction: the state may celebrate Zoroastrianism as part of Iran’s ancient heritage while limiting the equality and autonomy of the living community that preserves it. Heritage can therefore be honored even while its custodians remain constrained.

Finally, trust becomes difficult to sustain when institutions charged with protecting citizens also enforce religious hierarchy. For Bahá’ís, surveillance, arrests, educational exclusion, and property seizures can transform encounters with the state into sources of insecurity. Zoroastrians possess greater legal protection, but cases such as Niknam’s demonstrate that even recognized rights can become vulnerable to ideological intervention.

The BUC(k)ET framework thus reveals what a catalogue of legal restrictions alone cannot. Minority communities require more than permission to worship or formal constitutional recognition. Their members must also be able to belong, understand the rules governing them, exercise meaningful control over their lives, maintain individual and collective dignity, and trust the institutions around them. When these conditions are persistently weakened, the consequences can extend beyond individual discrimination to emigration, institutional contraction, declining communal participation, and diminished confidence in a shared future. Bahá’ís confront this pressure primarily through exclusion; Zoroastrians through containment. Neo-dhimmitude therefore operates not only as a hierarchy of rights, but as a structure capable of weakening the social conditions necessary for minority communities to endure and flourish.[101]

The comparison also shows how the regime’s treatment of heritage differs from its treatment of living communities. The state may celebrate pre-Islamic symbols, festivals, and historical narratives as part of a broader Iranian civilization, yet it continues to regulate, constrain, or marginalize the communities that embody that heritage in the present. This is particularly visible in the Zoroastrian case, where ancient festivals such as Sadeh can be publicly framed as national heritage even when access to the community’s living religious life remains restricted. Likewise, the Bahá’í case shows that a community can be made legally invisible while its material presence is still subjected to surveillance, confiscation, and criminalization. In both cases, the state converts cultural memory into political control.[102]

This article also demonstrates that state violence against religious minorities is not limited to dramatic episodes of arrest or imprisonment. It is sustained through the quieter mechanisms of exclusion: denial of access to education, obstruction of employment, limits on communal institutions, interference in burial practices, and pressure on associations and businesses. Those mechanisms matter because they shape the conditions under which a community can reproduce itself over time. If a state prevents children from studying, adults from working, families from burying their dead with dignity, and associations from functioning freely, it is not simply discriminating. It is undermining the social continuity of the group itself. That is why structural discrimination must be understood as a form of slow violence rather than as a series of isolated violations.[103]

The policy implications follow directly from this analysis. International actors should not approach Iranian religious freedom as a secondary issue to be addressed only after larger geopolitical concerns. It is central to understanding the character of the regime. Human-rights diplomacy, documentation efforts, and multilateral pressure are necessary not because they will by themselves transform the Iranian system, but because they can make visible the constitutional logic that sustains minority repression. Recent USCIRF reporting and Human Rights Watch documentation underscore the continuing urgency of this issue and support the conclusion that external scrutiny remains essential.[104]

(Shutterstock)

For the United States in particular, the paper suggests that policy toward Iran should explicitly integrate religious freedom into its broader approach. That means maintaining clear support for documentation and accountability, encouraging international coordination, and recognizing that gestures of cultural pluralism inside Iran do not eliminate the state’s underlying hierarchy. U.S. policy should also support pathways for at-risk minorities, including humanitarian protection, asylum, and preservation of community evidence and archives. Most importantly, it should treat the persecution of Bahá’ís and the containment of Zoroastrians not as separate minority issues, but as evidence of a shared system in which the state uses religion to organize political belonging.[105]

Ultimately, the article has shown that the Islamic Republic does not merely regulate religion; it orders society through religion. Bahá’ís are excluded from constitutional belonging, Zoroastrians are contained within conditional recognition, and both are situated beneath a single ideological order that translates Shi‘a supremacy into law, administration, and political hierarchy. The significance of this pattern extends beyond the two communities studied here. It reveals a governing logic in which difference is not tolerated as equality, but managed as rank. In that sense, the Iranian case is not only a study of minority repression.

More broadly, the Iranian case demonstrates that neo-dhimmitude is not merely a historical legacy of Islamic governance but a modern constitutional strategy through which religious hierarchy is translated into unequal citizenship, institutionalized through law, and reproduced by state power. The significance of this finding extends beyond Iran itself. It suggests that contemporary authoritarian regimes may preserve religious supremacy not despite constitutional institutions, but through them.

The Iranian experience therefore extends beyond the study of one state or two minority communities. It raises a broader theoretical question for comparative constitutionalism: how modern constitutional systems can employ the language of legality while institutionalizing unequal citizenship through religious hierarchy. In this sense, neo-dhimmitude should be understood not merely as a historical inheritance, but as a contemporary mode of authoritarian constitutional governance.

Endnotes

[1] Constitution of the Islamic Republic of Iran, arts. 4, 12–13; U.S. Department of State, 2023 Report on International Religious Freedom: Iran (Washington, DC: Office of International Religious Freedom, 2024), 1–3; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (Paris: FIDH, 2003), 44–47.

[2] U.S. Commission on International Religious Freedom, 2025 Annual Report: Iran (Washington, DC: USCIRF, 2025), 24–27; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran (London: Minority Rights Group International, 2022), 7–12.

[3] Constitution of the Islamic Republic of Iran, arts. 4, 12–13, and 19; Usama Hasan, From Dhimmitude to Democracy: Islamic Law, Non-Muslims and Equal Citizenship, Religious Reform Series 3 (London: Quilliam, 2015); Abdal Hakim Murad, Qur’anic Truth and the Meaning of “Dhimma” (Dubai: Kalam Research & Media, 2010).

[4] U.S. Department of State, 2023 Report on International Religious Freedom: Iran, 1–5; U.S. Commission on International Religious Freedom, 2025 Annual Report: Iran, 24–27; Ceasefire Centre for Civilian Rights, Centre for Supporters of Human Rights, and Minority Rights Group International, Rights Denied: Violations against Ethnic and Religious Minorities in Iran (London: Minority Rights Group International, 2018).

[5] Merve Korkmaz, Persecution of Baha’is in Iran: An Historical Overview and Contemporary Insights (master’s thesis, Middle East Technical University, 2013), 40–43; U.S. Commission on International Religious Freedom, Iran Policy Brief: Increased Persecution of Iran’s Baha’i Community in 2019 (Washington, DC: USCIRF, October 2019), 1–4; UK House of Commons Library, Land Rights for Religious Minorities Including Baha’is in Iran, Debate Pack CDP 062 (London: House of Commons Library, April 19, 2021), 2–3.

[6] Mina Yazdani, “Towards a History of Iran’s Baha’i Community during the Reign of Mohammad Reza Shah, 1941–1979,” Iran Namag 2, no. 1 (Spring 2017): 66–93; Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?,” Middle East Journal 65, no. 1 (Winter 2011): 73–84; Korkmaz, Persecution of Baha’is in Iran, 12–17.

[7] For community-specific approaches, see Yazdani, “Towards a History of Iran’s Baha’i Community,” 66–93; Korkmaz, Persecution of Baha’is in Iran, 12–17; Foltz, “Zoroastrians in Iran,” 73–84; Immigration and Refugee Board of Canada, “Iran: Zoroastrianism, Including Its Areas of Practice and Activities; Situation and Treatment of Zoroastrians by Society and Authorities; Religious Texts; Whether All Members Have Access to Religious Texts (2020–February 2022),” Response to Information Request IRN200943.E, March 2, 2022.

[8] Constitution of the Islamic Republic of Iran, arts. 12–13; U.S. Department of State, 2023 Report on International Religious Freedom: Iran, 1–3; UK House of Commons Library, Land Rights for Religious Minorities Including Baha’is in Iran, 2–3; Foltz, “Zoroastrians in Iran,” 73–84.

[9] U.S. Department of State, 2023 International Religious Freedom Report: Iran; Merve Korkmaz, Persecution of Baha’is in Iran: An Historical Overview and Contemporary Insights; materials collected in this study concerning Iran’s Zoroastrian community.

[10] Munazza Batool, “From Dhimmah to Dhimmitude: A Theoretical Analysis of the Interpretations and Models of the Inclusion of Non-Muslims under an Islamic State,” Pakistan Journal of Social Research 4, no. 3 (September 2022): 380–385; Hasan, From Dhimmitude to Democracy; Murad, Qur’anic Truth and the Meaning of “Dhimma.”

[11] Bat Ye’or, The Dhimmi: Jews and Christians under Islam (Rutherford, NJ: Fairleigh Dickinson University Press, 1985); Antoine Fattal, Le Statut Légal des Non-Musulmans en Pays d’Islam (Beirut: Imprimerie Catholique, 1958); Usama Hasan, From Dhimmitude to Democracy: Islamic Law, Non-Muslims and Equal Citizenship, Religious Reform Series 3 (London: Quilliam, 2015); Abdal Hakim Murad, Qur’anic Truth and the Meaning of “Dhimma” (Dubai: Kalam Research & Media, 2010).

[12] Bat Ye’or, The Dhimmi; Antoine Fattal, Le Statut Légal des Non-Musulmans en Pays d’Islam; Mark R. Cohen, Under Crescent and Cross: The Jews in the Middle Ages (Princeton: Princeton University Press, 1994); Usama Hasan, From Dhimmitude to Democracy; Munazza Batool, “From Dhimmah to Dhimmitude,” Pakistan Journal of Social Research 4, no. 3 (2022): 380–385.

[13] Bat Ye’or, The Dhimmi; Bernard Lewis, The Jews of Islam (Princeton: Princeton University Press, 1984); Munazza Batool, “From Dhimmah to Dhimmitude,” 380–385.

[14] Bernard Lewis, The Jews of Islam; Mark R. Cohen, Under Crescent and Cross; Bat Ye’or, The Dhimmi; Usama Hasan, From Dhimmitude to Democracy.

[15] Munazza Batool, “From Dhimmah to Dhimmitude,” 380–385; Usama Hasan, From Dhimmitude to Democracy; Abdal Hakim Murad, Qur’anic Truth and the Meaning of “Dhimma”.

[16] Munazza Batool, “From Dhimmah to Dhimmitude,” 380–385; Usama Hasan, From Dhimmitude to Democracy; Andrew F. March, Islam and Liberal Citizenship: The Search for an Overlapping Consensus (Oxford: Oxford University Press, 2009).

[17] Constitution of the Islamic Republic of Iran, arts. 4, 12–13, 19; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (Paris, 2003), 46–47; Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran (The Hague: Kluwer Law International, 2002); Javaid Rehman, Javaid Rehman, Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran, A/HRC/46/50 (United Nations, 2021).

[18] Constitution of the Islamic Republic of Iran, arts. 12–13; Asghar Schirazi, The Constitution of Iran: Politics and the State in the Islamic Republic (London: I.B. Tauris, 1997), chap. 2; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (Paris: FIDH, 2003), 44–47; Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran (The Hague: Kluwer Law International, 2002), 45–53.

[19] Constitution of the Islamic Republic of Iran, art. 4; Schirazi, The Constitution of Iran, chap. 3; Javaid Rehman, Islamic State Practices, International Law and the Threat from Terrorism (Oxford: Hart, 2005), 105–118.

[20] Constitution of the Islamic Republic of Iran, art. 19; Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran, 49–55; FIDH, Discrimination against Religious Minorities in Iran, 46–47.

[21] Constitution of the Islamic Republic of Iran, arts. 5, 107–112; Ruhollah Khomeini, Islamic Government (Hokumat-e Islami); Asghar Schirazi, The Constitution of Iran, chap. 5.

[22] Schirazi, The Constitution of Iran; Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran; Javaid Rehman, Report of the Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran, UN Doc. A/HRC/46/50 (2021).

[23] Constitution..., arts. 91–99; Schirazi, The Constitution of Iran, chap. 7; Ervand Abrahamian, A History of Modern Iran (Cambridge: Cambridge University Press, 2008), 156–167.

[24] Human Rights Watch, The Boot on My Neck: Iranian Authorities’ Crime of Persecution Against Bahá’ís in Iran (2024); USCIRF, Annual Report 2025; Javaid Rehman, A/HRC/46/50.

[25] Constitution of the Islamic Republic of Iran, arts. 13 and 64; U.S. Department of State, 2023 International Religious Freedom Report; Minority Rights Group International, World Directory of Minorities and Indigenous Peoples: Iran.

[26] Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran; Human Rights Watch, The Boot on My Neck; Javaid Rehman, A/HRC/46/50.

[27] Hamid Dabashi, Theology of Discontent (New York: NYU Press, 1993); Abrahamian, A History of Modern Iran; U.S. Department of State, 2023 International Religious Freedom Report.

[28] Nazila Ghanea, Human Rights, the UN and the Baha’is in Iran; Joshua Castellino and Kathleen A. Cavanaugh, Minority Rights in the Middle East (Oxford: Oxford University Press, 2013), 135–150; Minority Rights Group International, Rights Denied.

[29] International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran; U.K. House of Commons Library, Land Rights for Religious Minorities Including Baha’is in Iran (CDP-2021-0062).

[30] Merve Korkmaz, Persecution of Bahá’ís in Iran; Bahá’í International Community, The Bahá’í Question Revisited (2016); Nazila Ghanea, Human Rights, the UN and the Bahá’ís in Iran (2002); Javaid Rehman, Report of the Special Rapporteur on the Situation of Human Rights in Iran.

[31] Rome Statute of the International Criminal Court, art. 7(1)(h); Human Rights Watch, The Boot on My Neck (2024); Nazila Ghanea, Human Rights, the UN and the Bahá’ís in Iran.

[32] Constitution of the Islamic Republic of Iran, arts. 12–13; U.K. House of Commons Library, Land Rights for Religious Minorities Including Baha’is in Iran.

[33] FIDH and LDDHI, Discrimination against Religious Minorities in Iran; U.S. Department of State, 2023 Report on International Religious Freedom: Iran.

[34] Bahá’í International Community, The Bahá’í Question Revisited (2016); Mina Yazdani, “Higher Education under the Islamic Republic: The Case of the Bahá’ís,” Journal of Educational Controversy 10, no. 1 (2015); Sally Weeks, “How Bahá’ís Helped Bring Modern Education to Iran.”

[35] Bahá’í Institute for Higher Education (BIHE); Michael Karlberg, “Constructive Resilience: The Bahá’í Response to Oppression,” Peace & Change 35, no. 2 (2010): 222–257; Mina Yazdani (2015).

[36] Baháʼí International Community; Human Rights Watch, The Boot on My Neck.

[37] U.K. House of Commons Library, Land Rights for Religious Minorities Including Bahá’ís in Iran; Human Rights Watch, The Boot on My Neck; U.S. Department of State, 2023 International Religious Freedom Report.

[38] Human Rights Watch, The Boot on My Neck (2024); USCIRF, Annual Report 2025; Javaid Rehman, A/HRC/52/67; FIDH, Discrimination against Religious Minorities in Iran.

[39] U.K. House of Commons Library, Land Rights for Religious Minorities Including Baha’is in Iran; Reuters, “Khamenei Controls Massive Financial Empire Built on Property Seizures.”

[40] Javaid Rehman, Report of the UN Special Rapporteur; U.K. House of Commons Library.

[41] Pierre Nora, Realms of Memory; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran; Bahá’í International Community, The Bahá’í Question (2008).

[42] Javaid Rehman, UN Special Rapporteur; Human Rights Watch (2024); USCIRF (2025); U.S. Department of State (2023).

[43] Bahá’í International Community, Inciting Hatred (2011); Human Rights Watch (2024); FIDH (2003).

[44] Washington Institute report, The Baha’is of Iran and Contact with Foreign Nations; FIDH and LDDHI, Discrimination against Religious Minorities in Iran, 44–47.

[45] Human Rights Watch (2024); U.K. House of Commons Library (2021); Islamic Republic of Iran, Fourth Periodic Report under the ICCPR, CCPR/C/IRN/4 (2021).

[46] See also Human Rights Watch, The Boot on My Neck; Javaid Rehman; USCIRF (2025); Minority Rights Group International.

[47] FIDH (2003); Human Rights Watch (2024); Nazila Ghanea (2002).

[48] Human Rights Watch, The Boot on My Neck: Iranian Authorities’ Crime of Persecution Against Bahá’ís in Iran (New York: Human Rights Watch, 2024); Human Rights Watch, “Iran,” in World Report 2019: Events of 2018 (New York: Human Rights Watch, 2019).

[49] Constitution of the Islamic Republic of Iran, arts. 12–13; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (Paris, 2003), 44–47.

[50] Touraj Daryaee, Sasanian Persia: The Rise and Fall of an Empire (London: I.B. Tauris, 2009); Richard Foltz, Religions of Iran (London: Oneworld, 2013); Jenny Rose, Zoroastrianism: An Introduction (London: I.B. Tauris, 2011).

[51] Jenny Rose, Zoroastrianism: An Introduction; Minority Rights Group International, Iran: Zoroastrians; United States Commission on International Religious Freedom (USCIRF), Annual Reports on Iran; Human Rights Watch, reports concerning religious minorities in Iran.

[52] Constitution of the Islamic Republic of Iran, arts. 13 and 14; Constitution of the Islamic Republic of Iran, arts. 12–14; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (2003); United Nations Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran, latest reports on freedom of religion or belief.

[53] Constitution of the Islamic Republic of Iran, art. 64; Majles official records regarding reserved minority representation.

[54] FIDH and LDDHI, Discrimination against Religious Minorities in Iran, 44–47.

[55] Constitution of the Islamic Republic of Iran; Javaid Rehman, Report of the Special Rapporteur on Iran; CHRI, “Suspended Zoroastrian Member of Yazd City Council” (2017).

[56] “Iran Suspends Zoroastrian Member of Yazd City Council,” The New York Times, October 9, 2017; Constitution of the Islamic Republic of Iran, art. 64; The New York Times, “Iran Suspends Zoroastrian Council Member over Religious Status,” October 9, 2017.

[57] The Times of Israel, “Iran overturns ban on minority politicians, confirms Jews can hold office,” July 22, 2018; U.S. Department of State, Country Reports on Human Rights Practices: Iran, 2018; Center for Human Rights in Iran, reporting on the Niknam case, 2018.

[58] IRB (Immigration and Refugee Board of Canada), Iran: Zoroastrianism... (2022); Abdolkarim Lahiji, FIDH reports; Javaid Rehman.

[59] United Nations Special Rapporteur on the Situation of Human Rights in Iran; Constitution of the Islamic Republic of Iran; Minority Rights Group International and Centre for Supporters of Human Rights, Protests, Discrimination and the Future of Minorities in Iran (London: MRG, November 2022).

[60] Constitution of the Islamic Republic of Iran; Civil Code of Iran; FIDH, Discrimination against Religious Minorities in Iran.

[61] Nazila Ghanea and Binesh Hass, Seeking Justice and an End to Neglect: Iran’s Minorities Today (London: Minority Rights Group International, 2011); U.S. Department of State, 2023 International Religious Freedom Report: Iran.

[62] Mary Boyce; John R. Hinnells; Jenny Rose; Malcolm Deboo; Mary Boyce; Tehran Times (2022); IRB Canada (2022); Javaid Rehman.

[63] Javaid Rehman, Report of the UN Special Rapporteur on Iran; Nazila Ghanea, “Driving While Bahá’í: A Typology of Religious Discrimination,” The Equal Rights Review 8 (2012); Minority Rights Group International (2022)

[64] Mary Boyce, Zoroastrians: Their Religious Beliefs and Practices; Javaid Rehman, Situation of Human Rights in the Islamic Republic of Iran: Report of the Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran, UN Doc. A/HRC/46/50 (11 January 2021).

[65] Mary Boyce, Zoroastrians: Their Religious Beliefs and Practices.

[66] Richard Foltz, Religions of Iran (Oneworld, 2013); GAMAAN, Iranians’ Attitudes Toward Religion (2020; 2023 update); Jenny Rose, Zoroastrianism: An Introduction; Pejman Abdolmohammadi, The Revival of Nationalism and Secularism in Modern Iran (LSE, 2015); GAMAAN (2020).

[67] Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?”; The Conversation, discussion of religious nationalism and contemporary Zoroastrian identity. Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran, 7–12.

[68] GAMAAN (Group for Analyzing and Measuring Attitudes in Iran), Iranians’ Attitudes toward Religion: A 2020 Survey; Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?,” Middle East Journal 65, no. 1 (2011): 73–84.

[69] Nazila Ghanea-Hercock, Human Rights, the UN and the Bahá’ís in Iran (The Hague: Martinus Nijhoff Publishers, 2002); GAMAAN (2020); Richard Foltz; Pejman Abdolmohammadi (2015); IRB Canada (2022)

[70] IranWire, interviews with Katayoun Shahrokhi, Farzaneh Misteri, and Cyrus Niknam regarding interfaith marriage and Zoroastrian communal continuity,
September 28, 2020; John R. Hinnells (ed.), The Zoroastrian Diaspora: Religion and Migration; UN Special Rapporteur on Freedom of Religion or Belief, reports on Iran; Minority Rights Group International, World Directory of Minorities and Indigenous Peoples: Iran – Zoroastrians.

[71] UNFPA Iran, National Population and Housing Census; Kourosh Niknam, demographic statements on migration and declining birth rates; Malcolm Deboo, “The Zoroastrian Community Post-Religious Persecution.”; Malcolm Deboo; UNFPA Iran; IRB Canada; Richard Foltz.

[72] Malcolm Deboo, The Zoroastrian Community: Post-Religious Persecution and Demographic Challenges; Kourosh Niknam, statements on the demographic situation of Iran’s Zoroastrian community, September 28, 2020; UNFPA Iran, National Population and Housing Census; IranWire, interviews on intermarriage and demographic decline within the Zoroastrian community; Malcolm Deboo; Richard Foltz; UNFPA Iran; GAMAAN.

[73] Javaid Rehman, Report of the UN Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran; FIDH, Discrimination against Religious Minorities in Iran; USCIRF 2025

[74] Constitution of the Islamic Republic of Iran, arts. 13 and 64; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran; Javaid Rehman, Report of the UN Special Rapporteur on the Situation of Human Rights in the Islamic Republic of Iran.

[75] Javaid Rehman, Situation of Human Rights in the Islamic Republic of Iran (latest report); Nazila Ghanea, Human Rights, the UN and the Bahá’ís in Iran. Janet Afary, “Civil Liberties and the Making of Iran’s First Constitution,” Comparative Studies of South Asia, Africa and the Middle East 25, no. 2 (2005): 341–359; Janet Afary, “The Place of Shi‘i Clerics in the First Iranian Constitution,” Critical Research on Religion 1, no. 3 (2013): 327–346; Amnesty International, Iran: Submission to the UN Universal Periodic Review, 48th Session of the UPR Working Group (London: Amnesty International, 2024).

[76] Constitution of the Islamic Republic of Iran, arts. 12–14; International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (Paris: FIDH, 2003), 44–47; Javaid Rehman, Situation of Human Rights in the Islamic Republic of Iran, UN Doc. A/HRC/46/50 (2021).

[77] Human Rights Watch, The Boot on My Neck: Iranian Authorities’ Crime of Persecution Against Bahá’ís in Iran (2024); Nazila Ghanea-Hercock, Human Rights, the UN and the Bahá’ís in Iran (The Hague: Martinus Nijhoff, 2002).

[78] Constitution of the Islamic Republic of Iran, art. 13; FIDH and LDDHI, Discrimination against Religious Minorities in Iran, 44–47.

[79] Constitution of the Islamic Republic of Iran, arts. 13, 64; Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?,” Middle East Journal 65, no. 1 (2011): 73–84.

[80] Iran Suspends Zoroastrian Member of Yazd City Council, The New York Times, October 9, 2017; CHRI, Suspended Zoroastrian Member of Yazd City Council Facing Uncertain Future (2017); Constitution of the Islamic Republic of Iran, art. 64.

[81] Constitution of the Islamic Republic of Iran, arts. 4, 12, and 13; Ruhollah Khomeini, Islamic Government (Hokumat-e Islami); Javaid Rehman, UN Special Rapporteur Report; Ran Hirschl, Constitutional Theocracy.

[82] Mary Boyce, Zoroastrians: Their Religious Beliefs and Practices; Jenny Rose, Zoroastrianism: An Introduction; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran (2022); Richard Foltz, Religions of Iran.

[83] Abdullahi Ahmed An-Na’im, Islam and the Secular State (Harvard University Press, 2008); Ran Hirschl, Constitutional Theocracy (Harvard University Press, 2010); Constitution of the Islamic Republic of Iran; Abdullahi Ahmed An-Na’im, Islam and the Secular State.

[84] Richard Foltz, “Zoroastrians in Iran”; Nazila Ghanea-Hercock, Human Rights, the UN and the Bahá’ís in Iran; Human Rights Watch, The Boot on My Neck; Richard Foltz; Nazila Ghanea; Javaid Rehman; Human Rights Watch.

[85] T. H. Marshall, Citizenship and Social Class (Cambridge University Press, 1950); Will Kymlicka, Multicultural Citizenship (Oxford University Press, 1995); Bhikhu Parekh, Rethinking Multiculturalism (Harvard University Press, 2000).

[86] Ran Hirschl, Constitutional Theocracy (Harvard University Press, 2010); Will Kymlicka, Multicultural Citizenship (Oxford University Press, 1995); T. H. Marshall, Citizenship and Social Class.

[87] U.S. Commission on International Religious Freedom (USCIRF), 2025 Annual Report (Washington, DC: USCIRF, 2025), Iran chapter, 24–27; U.S. Department of State, 2023 Report on International Religious Freedom: Iran; Amnesty International, Iran: Submission to the Universal Periodic Review (2024).

[88] USCIRF, 2025 Annual Report; Javaid Rehman, Situation of Human Rights in the Islamic Republic of Iran, UN Doc. A/HRC/46/50; Nazila Ghanea, Human Rights, the UN and the Bahá’ís in Iran.

[89] Human Rights Watch, The Boot on My Neck: Iranian Authorities’ Crime of Persecution Against Bahá’ís in Iran (2024); Human Rights Watch (2024); Javaid Rehman; UN Human Rights Council.

[90] International Federation for Human Rights (FIDH) and Iranian League for the Defence of Human Rights (LDDHI), Discrimination against Religious Minorities in Iran (2003), 44–47; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran (2022); Amnesty International (2024)

[91] Human Rights Watch, The Boot on My Neck (2024); USCIRF, 2025 Annual Report; USCIRF; U.S. Department of State; Javaid Rehman.

[92] Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?,” Middle East Journal 65, no. 1 (2011): 73–84; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran (2022); Jenny Rose.

[93] Constitution of the Islamic Republic of Iran, arts. 4, 12–14; FIDH and LDDHI, Discrimination against Religious Minorities in Iran; Javaid Rehman, UN Special Rapporteur Report; Abdullahi Ahmed An-Na’im, Islam and the Secular State.

[94] Thomas Carothers, Aiding Democracy Abroad (Carnegie Endowment, 1999); Ran Hirschl, Constitutional Theocracy (Harvard University Press, 2010); Abdullahi Ahmed An-Na’im, Islam and the Secular State (Harvard University Press, 2008); Will Kymlicka, Multicultural Citizenship (Oxford University Press, 1995).

[95] Constitution of the Islamic Republic of Iran, arts. 4, 12–14; Ruhollah Khomeini, Islamic Government (Hokumat-e Islami); Ran Hirschl, Constitutional Theocracy (Cambridge, MA: Harvard University Press, 2010).

[96] Human Rights Watch, The Boot on My Neck (2024); U.S. Commission on International Religious Freedom (USCIRF), 2025 Annual Report, Iran chapter.

[97] Nazila Ghanea-Hercock, Human Rights, the UN and the Bahá’ís in Iran (The Hague: Martinus Nijhoff, 2002); Javaid Rehman, Situation of Human Rights in the Islamic Republic of Iran, UN Doc. A/HRC/46/50.

[98] Constitution of the Islamic Republic of Iran, arts. 13 and 64; Richard Foltz, “Zoroastrians in Iran: What Future in the Homeland?,” Middle East Journal 65, no. 1 (2011): 73–84.

[99] Will Kymlicka, Multicultural Citizenship (Oxford: Oxford University Press, 1995); T. H. Marshall, Citizenship and Social Class (Cambridge University Press, 1950).

[100] Ran Hirschl, Constitutional Theocracy; Abdullahi Ahmed An-Na’im, Islam and the Secular State (Cambridge, MA: Harvard University Press, 2008).

[101] Susan T. Fiske, Social Beings: A Core Motives Approach to Social Psychology (John Wiley & Sons, 2004).

[102] Mary Boyce, Zoroastrians: Their Religious Beliefs and Practices; Minority Rights Group International, Protests, Discrimination and the Future of Minorities in Iran (2022).

[103] Rob Nixon, Slow Violence and the Environmentalism of the Poor (Cambridge, MA: Harvard University Press, 2011).

[104] U.S. Commission on International Religious Freedom, 2025 Annual Report; Human Rights Watch, The Boot on My Neck (2024).

[105] U.S. Department of State, 2023 Report on International Religious Freedom: Iran; USCIRF, 2025 Annual Report.

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