M. HASSAN ROHANI

Complaint against M. HASSAN ROHANI

At the request of :

1) Mr. Ali Mehrsai
        Born on September 14, 1950 in Bushehr (Iran)
        Current address: STORHAGEN 25
        6100 VOLDA (NORWAY)
        Citizen of Norway

2) Mr Masoud MARANDI
        Born on September 6, 1976
        Current address: 56 UXBRIDGE ROAD
        LONDON W 12 8 LP (the U.K.)

3) Mrs Sakineh KARAMI MOTAGHI
        Born on October 6, 1962 in BAHAR (IRAN)
        Current address: STEINDAMM 56
        25337 ELMSHORN (GERMANY)

Have the honor of stating to you that:
The applicants of Iranian nationality, left their country of origine and took refuge in various European countries. They come to learn that Mr. Hassan ROHANI, the person in charge in Iran for repression of opponents thru assassination and torture, was residing in France.

Mr. Hassan ROHANI, who is currently in PARIS, is the direct collaborator of Ayatollah Ali KHAMANEI and President Akbar Hashani RAFSANJANI with whom he directs the National Security Council which decides assassinations, acts of terrorism to foreigners and orders the guards of the Revolution who carry out acts of torture on their opponents.

The terrorist structure in which Hassan ROHANI takes part, thus decided, planned and organized the assassination of more than one hundred political opponents, among the most important of which, it is possible to quote the assassinations of:

• October 1991, Dr. Cyrus Elahi, former vice-minister of education, assassinated in Paris.

• December 1992, Captain Abbas GOLIZADEH, assassinated in Istanbul.

• September 1993, three Iranian Kurds were assassinated in Berlin at the Mykonos restaurant.

• August 1991, former Prime Minister Shapour Bakhtiar was assassinated in France.

• May 1996, Dr. Reza Mazlouman, former vice-minister of education was assassinated in Paris.

In addition to these assassinations which are directly ascribable to Hassan ROHANI, he directs the repression of the opponents who are arrested and tortured.

In a report of 58 pages, established on November 8, 1993 by the United Nations Human Rights special rapporteur, it is indicated that torture is used in a regular manner in the Iranian prisons "to obtain consents or to prepare evidence to accuse people who obviously have no knowledge of the charges selected". The report is supported by another report dated November 1998 which states that:

"The prisoners are usually tortured after their arrest, they can be subjected to torture constantly during their detention in IRAN. One estimates the number of victims of torture to be more than 100.000.

"The most common methods of torture used, are suspensions for long periods in an up-side down position, keeping them up for long periods, cigarette burns and most frequently repeated and violent blows with cables and other instruments on the back and the plant of the feet."

The applicants have all been victims of the of Hassan ROHANI.



1) Complaint of Mr. Ali MEHRSAI

Mr. Ali MEHRSAI residing in Norway since 1992, active member of the organisation of Fedayins of the people of IRAN, was arrested and held in prison of BUSHEHR (IRAN) on December 26, 1981.

He was forced to stretch out on a bench, on which he was bound and underwent the torment known as "wet rag", - dirty part of clothing inserted in the mouth - and was whipped 74 times with an electric cable on the plant of his feet by several torturers taking turns, by order of the judiciary.

During the first two months, he received several blows, on the face and the nape of the neck, kicks to his stomach and in the back, which resulted in an ulcer. At the end of two months, at the time of his "trial" he had to deny belonging to his organization, under the threat of execution the same day. Therefore, he was condemned to 10 years of prison, with the sentence reduced by 5 years.

The conditions of his detention were particularly painful from June 1982 to March 1983 when he was deprived of all medical care and family visits in spite of his ulcer and an infection of the skin. On December 11, 1983, he was transferred to KARAAJ (100 km NW of Teheran) where he was blackmailed to "cooperate" with authorities in exchange for care.

With his stubborn refusal he was deprived of any medical treatment and placed in isolation, enduring psychological tortures until August 11, 1985. He was transferred again to several prisons and torture centers, ADELABAD and BUSHEHR where as a consequence of the various daily abuses he underwent, his nose and its teeth were broken. He was finally released on December 26, 1986 and succeeded in leaving Iran to find refuge in Norway.


2) Complaint of Mr. Massoud MARANDI

Massoud MARANDI was arrested when he was a student at the university of SHIRAZ AZAD where he was studying engineering. He was imprisoned and beaten with an electric wire, hung by the hands and beaten with a whip 130 times. He had to sign a document renouncing any suspect activity. He was then brought to an isolated and backward region of Iran by car with his eyes blindfolded and he was abandoned after he was thrown out of the car. He succeeded in escaping from Iran and he found refuge in England where he currently resides.


3) Complaint of Mrs Sakineh KARAMI MOTAGHI

The plaintiff was arrested in 1982 and 1984 for being part of the People’s Mojahedeen. In 1999, she was arrested again and put in detention from July to December. In prison, she was interrogated under torture, in order to find out to which group she belonged. To collect this information she was tortured with electrical shocks on the chest and the head and was burned with cigarettes. She was struck with electric wire and raped with a bottle. Her body still carries the traces and the scars of the wounds she received.



Pertaining to Legal Rights:

The Supreme court of appeal has ruled (Cass Crim October 23, 2002) that articles 689 - 1 and 689 - 2 of the Code of Penal Procedure give competence to the French jurisdictions to continue and judge any person who, out of the territory of the Republic has been found guilty of committing acts of torture.

Moreover, according to article 689 of the Code of Penal Procedure, the French law is applicable each time the French courts are qualified.

As a result of this, in cases where the French criminal law has the means to be applied because of the jurisdiction of the transgression, the law finds a way to apply each time that the judicial competence is applied.

The plaintiffs, who will be joined by many others, have the honor to present you a case for crime against humanity, facts envisaged and repressed by article 212-1 and following the Penal code.

Here you find in your hands the amount of the fee that you would like to impose.