In the first part of this report, the pattern of repression targeting independent lawyers and the most significant cases involving prosecuted attorneys were examined. The second part analyzed the role of Article 48 and other mechanisms used to restrict the right to defense.
The consequences of these policies became most visible in cases related to the nationwide protests of 2025. As the number of detainees increased, restrictions imposed on lawyers intensified. The exclusion of independent lawyers from security-related cases, limitations on access to clients and case files, pressure on the Bar Association, and growing international concern collectively provided a clear picture of how the mechanism for controlling legal defense operates in Iran.
This third part examines that critical stage; the point at which the “engineering of the right to defense” moved beyond a legal and institutional framework and revealed its practical consequences in the cases of thousands of detainees.
Chapter Four: The Bar Association; From an Independent Institution to the Last Bastion of Legal Independence
Alongside the arrest and prosecution of independent lawyers, one of the most significant dimensions of pressure on Iran’s legal community has been the gradual erosion of the independence of Bar Associations. This process has not targeted only individual lawyers or isolated cases; it has increasingly affected the institutional foundations of the legal profession itself.
Under the 1954 Law on the Independence of the Bar Association, Bar Associations are recognized as independent institutions, and lawyers are expected to carry out their professional duties free from government interference. In recent years, however, a series of legal, administrative, and security-related measures has significantly restricted that independence.
Among the most significant developments has been the growing role of the judiciary in overseeing the issuance and renewal of law licenses, as well as the expansion of parallel legal service structures. According to many legal experts, these developments have weakened the independence of the legal profession and increased its dependence on judicial authorities.
Pressure has not been limited to legislation and regulations. In recent years, members of Bar Association boards, prominent lawyers, and professional advocates have also faced summonses, judicial prosecution, and security-related pressure. In some cases, even defending the independence of the Bar Association has been treated as a security issue.
The significance of this trend extends far beyond the legal profession itself. The independence of lawyers and Bar Associations constitutes a fundamental prerequisite for a fair trial. The more this independence is restricted, the less access citizens have to effective legal representation.
For this reason, many legal scholars view pressure on Bar Associations and pressure on independent lawyers as two dimensions of a single policy; one aimed at limiting the capacity for independent legal defense against security and judicial institutions.
Under these circumstances, the Bar Association has become one of the last independent legal institutions in Iran; an institution whose future is directly linked to citizens’ ability to access independent legal counsel and enjoy fair trial guarantees.
Chapter Five: The 2025 Nationwide Protests; Where the Engineering of the Right to Defense Became Visible
If the arrest of independent lawyers, Article 48, and pressure on the Bar Association can be understood as separate indicators of a broader policy, then the cases arising from the nationwide protests of 2025 represent the point at which all these elements converge and reveal how that policy operates in practice.
The nationwide protests of 2025 were accompanied by a wave of mass arrests. Under such circumstances, the families of detainees needed independent legal representation more than ever. Yet information gathered from cases arising during this period indicates that unprecedented restrictions were imposed on lawyers precisely when demand for legal defense was at its highest.
5.1. Lawyers Who Were Never Allowed to Enter the Case
According to information received from multiple cities, no independent lawyers have thus far been able to formally represent individuals accused in so-called security-related cases connected to the nationwide protests and arrests that followed.
This issue is significant for several reasons.
In many previous political cases, authorities sought to restrict the choice of legal counsel but did not entirely deny the presence of lawyers. In cases linked to the 2025 protests, reports indicate that in numerous instances even the initial entry of independent lawyers into proceedings was prevented.
In other words, the issue extended beyond the selection of counsel; access to independent legal representation itself became obstructed.
Some lawyers reported that when attempting to accept representation or inquire about their clients’ status, they encountered degrading treatment, insults, threats, or pressure from prosecutors’ offices and Revolutionary Courts. In certain cases, lawyers were effectively excluded from proceedings before they could begin providing legal defense.
5.2. The 2025 Protests and Intensified Restrictions on Access to Counsel
The nationwide protests of 2025 not only increased the number of detainees but also intensified existing restrictions on access to legal representation. Reports from protest-related cases indicate that many detainees were denied prompt and effective access to lawyers of their choosing, while judicial proceedings unfolded in an intensely securitized environment.
Independent estimates place the number of individuals detained during the nationwide protests at more than 50,000. At the same time, United Nations experts and human rights mechanisms expressed concern regarding widespread arbitrary arrests, denial of access to legal counsel, prolonged detention in security facilities, and reports of enforced disappearances. They warned that, in many cases, families remained unaware of detainees’ whereabouts and that effective access to lawyers or independent oversight of detention and interrogation procedures was absent.
Under such circumstances, the issue of independent lawyers was not merely a professional or occupational concern. In cases involving tens of thousands of detainees, allegations of torture, forced confessions, arbitrary detention, and possible enforced disappearances, access to independent legal counsel became one of the most important safeguards for the protection of fundamental rights. It was precisely during this period that pressure on lawyers, restrictions on access to case files, and the exclusion of independent counsel from judicial proceedings intensified.
A review of cases from this period demonstrates that restrictions stemming from Article 48, pressure on independent lawyers, and barriers to accessing case files operated simultaneously and reinforced one another. As a result, many families found themselves confronting Revolutionary Courts and security institutions while deprived of meaningful access to independent legal defense.
From a human rights perspective, this situation is particularly significant. Allegations of torture, forced confessions, prolonged detention, and violations of defendants’ rights often arise precisely during periods when access to legal counsel is most critical. Yet available evidence indicates that restrictions on lawyers have intensified at exactly this stage.
For this reason, the repression of lawyers and restrictions on access to counsel cannot be viewed merely as a byproduct of the protests. Rather, they formed part of a broader mechanism that reduced independent oversight of detention, interrogation, and judicial proceedings.
In practice, the protests of 2025 became the point at which all components of the legal-defense control mechanism were simultaneously visible; from the exclusion of independent lawyers and the application of Article 48 to restrictions on case files and the conduct of trials within a security-dominated environment.
Mashhad: Even Article 48 Lawyers Faced Restrictions
One of the most significant findings concerning protest-related cases emerged from Mashhad.
According to available information, even some lawyers approved under Article 48 encountered serious obstacles in accessing case files and accepting representation.
This finding is significant because Article 48 was originally designed to restrict defendants’ choice of counsel and replace independent lawyers with a judiciary-approved list. Yet in some protest-related cases, restrictions extended even beyond that framework.
If even approved lawyers are unable to effectively participate in proceedings, an important question arises:
What is the true purpose of these restrictions?
Is the issue merely the selection of counsel, or is the presence of any meaningful legal defense in sensitive security-related cases being restricted?
Tehran: A Lawyer Exists, but the Case File Is Not Accessible
Similar information emerged from Tehran.
According to available reports, some Article 48 lawyers involved in protest-related cases were denied full access to all documents and evidence contained in case files.
This represents one of the least discussed dimensions of the violation of defense rights in Iran.
Many legal debates focus on the right to choose counsel. Yet access to case files is an inseparable component of effective legal defense. A lawyer who lacks access to the full contents of a file, investigative reports, evidence supporting the charges, and related documentation is effectively deprived of the ability to provide comprehensive representation.
Under such circumstances, the presence of legal counsel risks becoming symbolic rather than substantive.
Trials Conducted in a Security-Dominated Environment
A review of causes related to the nationwide protests of 2025 indicates that many proceedings were conducted in a heavily securitized atmosphere. Families and lawyers reported a lack of transparency, difficulty obtaining information about cases, restrictions on communication with defendants, and uncertainty surrounding judicial procedures.
In such an environment, the right to defense, which should serve as one of the principal guarantees of a fair trial, is gradually weakened. A defendant who cannot freely choose a lawyer, a lawyer who cannot enter the case, and a lawyer who lacks access to the full case file are all components of the same chain.
From the Repression of Protesters to the Repression of Their Defenders
One defining characteristic of the 2025 nationwide protests was that pressure extended beyond detainees themselves. As arrests increased, pressure also intensified against those capable of defending them.
The arrest of independent lawyers, restrictions on access to clients, implementation of Article 48, and limitations on access to case files collectively formed a mechanism that reduced independent oversight of detention, interrogation, and judicial proceedings.
For this reason, the protests of 2025 can be viewed as the most significant test of the right to defense in recent years; a period in which every component of the legal-defense control mechanism, from the exclusion of independent lawyers to restrictions on access to case files, became simultaneously visible.
Chapter Six: Responses from the Legal Community and International Organizations
The repression of independent lawyers in Iran has not gone unnoticed internationally. In recent years, the United Nations, international legal organizations, and professional bar associations have repeatedly expressed concern regarding the arrests, prosecutions, and restrictions imposed on lawyers in Iran.
A common principle underlies these concerns: lawyers should not be prosecuted or punished for carrying out their professional duties, including the representation of political prisoners, protesters, journalists, civil society activists, or justice-seeking families.
This principle is reflected in international standards governing the independence of the legal profession and in the United Nations Basic Principles on the Role of Lawyers.
6.1. The United Nations: Warning About the Erosion of Defense Rights in Iran
Between 2024 and 2026, various United Nations mechanisms repeatedly expressed concern regarding the situation of independent lawyers and access to legal counsel in Iran.
Mai Sato, the United Nations Special Rapporteur on the situation of human rights in Iran, highlighted increasing restrictions imposed on lawyers, civil society activists, and political detainees. She warned that many detainees are denied effective access to lawyers of their choosing and expressed concern regarding growing pressure on human rights defenders and individuals documenting human rights violations.
The United Nations Fact-Finding Mission also identified recurring patterns of fair-trial violations, including restrictions on access to counsel, reliance on coerced confessions, denial of family contact, and judicial proceedings that fail to meet international standards.
Likewise, the United Nations Working Group on Arbitrary Detention and other human rights mechanisms have repeatedly emphasized that prompt and unhindered access to independent legal counsel is a fundamental component of a fair trial and that depriving defendants of this right may undermine the legitimacy of the entire judicial process.
6.2. The International Legal Community: Defending the Independence of the Legal Profession
In addition to the United Nations, several respected legal and professional organizations have responded to the situation of lawyers in Iran.
The Council of Bars and Law Societies of Europe, Lawyers for Lawyers, International Bar Association, and International Commission of Jurists have repeatedly called for an end to the arrest and prosecution of independent lawyers in Iran.
These organizations have emphasized that lawyers should not face prosecution for carrying out their professional responsibilities, including representing political prisoners, protesters, journalists, civil society activists, and justice-seeking families.
A significant portion of these concerns relate to Article 48 of the Code of Criminal Procedure and the restriction of the right to freely choose legal counsel. In the view of these organizations, both the independence of the legal profession and the right to choose a lawyer are fundamental components of a fair trial, and structural restrictions on these rights undermine the balance between citizens and the judicial system.
6.3. Conflict with International Standards
Pressure on independent lawyers in Iran is not merely a professional issue. It conflicts with a range of international human rights standards, including Article 14 of the International Covenant on Civil and Political Rights and the United Nations Basic Principles on the Role of Lawyers.
Under these standards, lawyers must be able to perform their professional duties without threats, intimidation, pressure, or prosecution. Citizens must also enjoy the right to freely choose legal counsel and to have effective access to legal defense.
The cases examined in this report demonstrate a substantial gap between these international standards and the reality in Iran; a gap that became even more apparent following the nationwide protests of 2025.
Conclusion : From Excluding Lawyers to Controlling Judicial Proceedings
A review of documented cases between 2024 and 2026 demonstrates that pressure on independent lawyers in Iran cannot be understood as a collection of isolated incidents or ad hoc decisions.
The arrest of independent lawyers, security-related prosecutions, suspension or revocation of law licenses, restrictions on access to clients, the application of Article 48, limitations on access to case files, and pressure on Bar Associations all form components of a single pattern.
This pattern became particularly visible after the nationwide protests of 2025. At a time when thousands of individuals faced security-related charges and the need for independent legal defense was greater than ever, restrictions imposed on lawyers and defense rights also intensified.
The findings of this report indicate that the objective of these measures is not merely the punishment of a handful of prominent lawyers. Rather, what has occurred in practice is the restriction of society’s capacity to access independent legal defense and to maintain legal oversight of security and judicial institutions.
For this reason, the repression of independent lawyers should be understood as part of the broader architecture of political repression in Iran; an architecture in which the control of defendants, the control of information, and the control of legal defense are pursued simultaneously.
The cases of Mohammad Najafi, Taher Naghavi, Khosrow Alikordi, Mohammadreza Faghihi, Shima Ghoosheh, and dozens of other lawyers represent only a portion of this broader pattern. Collective cases in Mashhad, Rasht, Shiraz, and Yazd, together with restrictions imposed in protest-related prosecutions demonstrate that the repression of lawyers has evolved beyond the prosecution of individuals and has become a structural policy.
Ultimately, developments in Iran during recent years can be understood as an effort to engineer the right to defense; a process in which independent legal representation is not formally abolished but is progressively restricted, directed, and controlled. The consequences of such a process extend beyond lawyers themselves and affect every citizen who relies on independent legal counsel when confronting the judicial system.
