This decision replaces AR (Christians - risk in Kabul) Afghanistan [2005] UKAIT 00035 only in so far as it deals with Muslims who have converted to Christianity.
The case summary in English has been prepared in the framework of the Knowledge-Based Harmonisation of European Asylum Practices Project (2010-2012), co-financed by the European Refugee Fund.
Conditions for Christians in Iran have not deteriorated sufficiently to necessitate a change in the guidance in FS and Others (Iran - Christian Converts) Iran CG [2004] UKIAT 00303 Iran. For some converts to sacrament-based churches the conditions may be such that they could not reasonably be expected to return and their cases must be considered on HJ (Homosexuality: Reasonably Tolerating Living Discreetly) Iran [2008] UKAIT 00044 grounds.
It remains to be seen whether the proposed inclusion of apostasy in the amended criminal code will make a material difference. The amendments to the code are part of a wholesale change in the criminal law and not solely aimed at converts. The proposals are still before Parliament.
'Proselytising' and 'evangelising' are not terms of art and distinctions should not be drawn between them.
This determination supersedes the following Country Guidance cases:
- MM (Ahmadi - Internal Relocation) Pakistan v. Secretary of State for the Home Department CG [2002] UKIAT 05714; and
- AZ (Risk - Ahmadi) Pakistan v. Secretary of State for the Home Department CG [2002] UKIAT 02642.
