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. Insofar as related to non-ethnic Christians, this decision is replaced by the country guidance decision in PS (Christianity - risk) Iran CG [2020] UKUT 00046 (IAC).
Heard at Field House on 30 June 2008. The country guidance in AB and DM (Risk Categories Reviewed Tutsis Added) DRC CG [2005] UKAIT 00118 is confirmed subject to adding that members of the Hema tribe are likely to be treated by the authorities in the DRC in the same way as Tutsis and Rwandans and may be at risk of persecution on return to the Ituri region.