When Zhino Babamiri gets a call from Urmieh Central Prison in Iran, she stops everything to pick up the phone. Her father is on the other end, and she doesn’t know when he will be able to contact her again.
“I just drop everything and take the call because sometimes when it doesn't go through, it could take a couple more weeks,” the 26-year-old told The National from her home in Norway. Sometimes there have been weekly calls of five or 10 minutes. “But sometimes it has been weeks until he has managed to do another one.”
The father, Rezgar Beigzadeh Babamiri, 48, was arrested in April 2023 and accused of providing medical assistance to demonstrators in the Women, Life, Freedom movement. The protests had erupted the previous year after 22-year-old Jina Mahsa Amini died in police custody, having been arrested for allegedly violating hijab rules.
Mr Babamiri was handed three death sentences after being tortured during interrogation. He was subjected to mock executions, waterboarding and electrocutions, according to a letter he wrote from prison last year. The phone calls are a lifeline for Zhino, who was not able to speak to him for more than two years following his detention.
“Some weeks he's very good. He's very hopeful,” said Zhino, a Kurdish-Iranian Norwegian citizen. “He spends most of the time right now reading, but sometimes he's very stressed as well because the vibe of the prison gets so intense. When someone gets executed, they all lose hope.”
Mr Babamiri’s death sentences are currently being reviewed following a Supreme Court order for a retrial. But his case is just one example of thousands of people who have suffered at the hands of the Iranian state for their involvement in anti-government protests.
Hundreds of people were killed and tens of thousands arrested during the Women, Life, Freedom movement, according to campaigners. Like Mr Babamiri, some remain in prison to this day, and Iran continues to issue death sentences for demonstrators: two men, Mehrab Abdollahzade and Aref Khoshkar, were executed this year over their involvement.
Barriers to accountability
Amnesty International says Iranian officials should be investigated for crimes against humanity during the protests, including murder, torture, enforced disappearances and rape.
The UN’s Fact Finding Mission on Iran said recently that Iranian security personnel had also committed crimes against humanity when suppressing protests in January 2026. Activists outside Iran say the death toll was at least 8,000, and the unrest represented the largest popular challenge to Iran’s clerical leadership since the 1979 revolution that brought it to power.
Amnesty International Iran researcher
But activists trying to bring the perpetrators to justice face several barriers, top lawyers told The National.
They include bureaucracy, a push by US President Donald Trump to weaken the International Criminal Court, and a lack of political will and resources. That is the case even among European nations that advocate for human rights and whose own laws allow for crimes committed abroad to be investigated, the interviewees said.
“We live in an age where the rules-based international order seems to be in the gutter,” Kaveh Moussavi, a human rights lawyer in the UK, told The National in a rare interview.
Mr Moussavi prepared the criminal complaint that led to the arrest in 2019 of Hamid Nouri, a former Iranian prison official who had travelled to Sweden. He was later found guilty of war crimes in connection with mass executions of political prisoners in Iran in 1988, and sentenced to life in prison, but was returned to Iran in a prisoner swap deal in 2024.
“I think there is certainly a case for arraigning, indicting, arresting and putting on trial the culprits,” Mr Moussavi said of the January violence. “But after Hamid Nouri, they don't travel any more.”
That does not have to be a barrier to starting investigations, but foreign prosecutors still appear reluctant to open files on Iran.
Requests for investigation rejected
In February, Germany's prosecutor general turned down a request filed under the principle of universal jurisdiction from lawyers at the European Centre for Constitutional and Human Rights for an investigation into the recent unrest in Iran.
Universal jurisdiction allows countries to open investigations into the most serious crimes regardless of where they were committed. Some states, such as Germany and Sweden, allow for a “structural investigation” that does not require a suspect to be present but looks into patterns of wrongdoing and identifies chains of command – essentially laying the groundwork for future criminal investigations.
Alexander Schwarz, an ECCHR director for international crimes and accountability, said the German prosecutor told the applicants that an investigation into Iran "is currently not considered necessary." The prosecutor's reasoning, Mr Schwarz said, was the lack of a concrete link to Germany, limited access to evidence, and the fact that the UN or others could collect evidence without opening formal proceedings.
The prosecutor’s arguments were “not convincing,” Mr Schwarz told The National. He said German prosecutors had a “distinct responsibility” to secure evidence and reconstruct the chain of command.
“Waiting until a suspected perpetrator enters Germany risks losing evidence that could and should be secured now,” he said. The German prosecutor general's office did not respond to a request for comment.
Amnesty International’s recent report, Architects of Atrocities, added to the voices calling for foreign investigations into Iran, as has been done for other countries.
“This is something that has been done for Syria and Ukraine in Germany, and there is no clear explanation as to why it hasn't yet been done for Iran,” Raha Bahreini, an Amnesty researcher on Iran, told The National. She said there could be hundreds of witnesses and survivors living in Europe.
Countries that call for accountability in UN meetings need to go “beyond toothless statements and find a pathway for that accountability to come,” she added.
Amnesty has identified 87 Iranian officials it would like to see investigated over the women's rights movement. This would have to happen abroad because the Iranian judiciary is part of the regime and has no interest in accountability, it said.
Among Amnesty's demands are posthumous investigations into the late Iranian supreme leader Ayatollah Ali Khamenei and former military chief Mohammad Bagheri, both killed in Israeli strikes. They also include Ahmed Vahidi, who was interior minister in 2022 and has since been promoted to lead the Islamic Revolutionary Guard Corps. The list also includes provincial IRGC and police commanders and governors. That includes West Azerbaijan province, where Mr Babamiri was arrested; he says he was tortured.
Human rights lawyers believe prosecutors in Europe would have enough evidence to act. The Berlin organisation Mnemonic is preserving 1.3 million pieces of digital information related to the 2022 protests in the hope of supporting investigations.
This evidence “can be a very valuable source of information for war crimes units in different countries and the prosecutors there,” Gissou Nia, a lawyer focused on international criminal and human rights law, told The National.
There are human witnesses too. “Certainly, there's enough Iranian victims, both of the Women, Life, Freedom movement and of other spates of violence in the country, to open up a structural investigation in Germany,” Ms Nia said.
The benefit of this type of investigation is that it would prepare the ground so that if a suspect does enter German territory, an arrest warrant could quickly be issued, she added.
Yet another hurdle stands in the way of arresting Iranian officials abroad. Iran’s willingness to seize foreign nationals as retaliation leads to caution among European attorneys general considering an arrest warrant, Mr Moussavi said. An attorney general is a government’s top legal adviser and a political appointee.
“With the possible exception of Switzerland, I cannot conceive of any circumstances in which any European country would permit the prosecutors to go ahead with arresting a travelling peripatetic itinerant Iranian official, because they would seize immediate hostages in Iran,” Mr Moussavi said.
In the case of Hamid Nouri, Sweden handed the convict back to Iran in a prisoner swap with Swedish nationals Johan Floderus and Saeed Azizi, who had been detained in 2022 and 2023 respectively.
In an email to The National, Reena Devgun, team leader for Sweden’s war crimes prosecutors, declined to comment on whether the Swedish Prosecution Authority had opened any investigations following Amnesty International’s plea.
“We can still in such matters assist in order to help other national prosecutions or UN fact-finding missions if they identify a link to Sweden in their investigations,” she added.
Zhino Babamiri believes countries that attempt to remain neutral on Iran are missing the point. “I don't think this would be neutral if you close your eyes on humans dying,” she said. Countries that are “all about human rights and equality” must act.
“I really love living in Norway, but I really hope these countries do not stay silent and hold each of these people who make these decisions accountable.”
Norwegian public prosecutor Marit Formo told The National in an email that the country had not opened any investigations into the situation in Iran. “We are currently prioritising other continuing investigations into international crimes, where the suspects are residing in Norway,” Ms Formo said.
Zhino’s father’s treatment at the hands of the Iranian security services compels her to keep speaking up about violations in Iran, in the hope that perpetrators will one day be brought to justice.
human rights lawyer
“There has been definitely a lot of IRGC members who have who have tortured my dad and who have treated him very bad,” she said.
When Rezgar Babamiri told Iranian judge Reza Najafzaqdeh about the torture he had experienced in detention, the response was telling of a system that human rights organisations say is designed to maintain impunity. “My father said, ‘These are the things they did to me,’” Zhino said. “He [Judge Reza Najafzadeh] just laughed and said, ‘Did you expect to be served with kebab?’”.
Investigations should instil in Iranian officials the idea that “they don't get the privilege of just going wherever they want in the world,” should the Islamic Republic one day collapse, she added.
ICC in a chokehold
Investigations in Europe become all the more important because of paralysis at the UN institutions designed to maintain peace and security.
Activists, politicians and Iranian opposition groups have urged the UN Security Council to refer Iran to the International Criminal Court. The court in The Hague tries the gravest crimes, such as genocide and crimes against humanity. A UN referral would be necessary because Iran has never ratified the ICC's founding document, the Rome Statute.
Yet any referral could be vetoed by Russia and China, which are friendlier towards Tehran. In the US, the Trump administration’s attack on the ICC is also a barrier to referring Iran to the ICC.
The US Treasury Department has imposed sanctions on judges at the ICC, which President Trump called “evil” and “a rogue institution” at the UN General Assembly. While Israel is Iran’s arch enemy, it is no friend of the ICC either, due to the international arrest warrant issued against Prime Minister Benjamin Netanyahu over the war in Gaza.
“There is more chance of a snowball surviving in the fires of hell than the UN Security Council referring the matter to the ICC on any Iranians who happen to be travelling outside Iran,” Mr Moussavi said. “That won't happen, not while Trump is there.”
Can the UN General Assembly act?
If a referral is a non-starter, Amnesty believes the UN General Assembly could act instead by setting up a special mechanism to investigate crimes against humanity in Iran.
This could happen in one of two ways, according to Raha Bahreini of Amnesty International. Countries could ask the UN Secretary General to study the options and then choose the best path. This has been done before in Cambodia, although the government there co-operated — something unlikely to happen in Iran.
Alternatively, the assembly could create a tribunal via its own resolution. “This would be unprecedented, but it doesn't mean that the UN General Assembly cannot do it,” Ms Bahreini said.
Again, political will may be lacking at the assembly. The war in Gaza and the US-Israeli campaign against Iran have lessened the willingness of some nations to take a stand against Tehran, Mr Moussavi said. Some may prefer to side with Iran against Israel, which stands widely accused of genocide in Gaza, rather than support a mechanism to hold Iran accountable.
“I cannot believe that there'll be a consensus around that topic against any Iranian officials yet – yet. Much depends on resolving the Palestine issue right now,” Mr Moussavi said.
Is there any hope?
Any route to justice depends on the will of the international community, while a failure to act could lead to further crackdowns in Iran because the perpetrators see they can get away with such actions, human rights defenders believe.
“We need governments to hear our central message that people in Iran are at real risk of further protest massacres, and impunity is a key driver of these successive cycles of protest bloodshed in Iran,” Ms Bahreini of Amnesty said.
The organisation believes that eyes glazing over at the news of more mass killings in Iran is another driver of inaction. “Our assessment is that mass protest killings in Iran have become sadly normalised,” she added.
Mr Moussavi believes the arc of history bends in the right direction, even with the current crisis facing international accountability mechanisms.
“History has an uncanny habit of calling to account people who commit these things,” he said.
And regardless of the status of formal prosecutors’ investigations, Zhino says she will continue to speak up about the plight of her own father and other Iranian prisoners and victims so that the perpetrators’ alleged crimes become infamous.
“I will do my best so that the world hears what you're doing,” she said.
