Asylum: may a bogus Christian “convert” be returned to Iran?: MR

In MR v Secretary of State for the Home Department [2020] UKAITUR PA124772018, the anonymous appellant had left Iran illegally and had claimed asylum in 2011 on the basis of his conversion to Christianity. He had attended a Roman Catholic church on a few occasions in 2011, then attended the Victory Christian Centre – an Assemblies of God congregation – weekly from June 2017 until December 2018 (up to the date of the appeal hearing at the First-tier Tribunal). He had also attended its bible classes. He had been baptised at the Victory Christian Centre in August 2017; however, it was found as fact that he was not a genuine Christian convert and that his attendance at church and his baptism “were not in good faith but undertaken to substantiate his manufactured claim for asylum” and he would not proselytise on return to Iran [16].

It was submitted on his behalf that the Assemblies of God was abhorrent to the Iranian regime because it was linked with the house church movement in Iran – which constituted an increased risk factor in line with PS (Christianity – risk) Iran [2020] UKUT 46 (IAC). There was, therefore, “a real risk that the appellant would be subject to a prolonged detention increasing the likelihood of him being submitted to serious harm” [21].

Upper Tribunal Judge Owens concluded that the appellant was not a genuine Christian convert and been attending church and been baptised “in order to bolster a fabricated claim for asylum” [25]. Nevertheless, he faced a real risk of persecution on his return to Iran regardless of whether he was a genuine convert or not [26]. Further:

“It is agreed that this appellant is a failed asylum seeker who left Iran illegally and that he will be questioned by the Iranian authorities at the “pinch point” of his arrival in Iran. It is also accepted that like PS, he will not be expected to lie and it will come to light that he claimed asylum on the basis that he has converted to Christianity and been baptised and will be transferred to second-line questioning. It is also agreed that this appellant, like PS, will inform the Iranian authorities that his claim to a Christian convert was fabricated and that he is prepared to sign the necessary undertaking” [27].

Judge Owens found that the appellant’s situation was different from that of PS because he had attended the services and Bible classes at the Victory Christian Centre: those facts were “likely to come to light during questioning by the Iranian authorities. I find that in the case of this appellant there is a much longer history of association with Christian movements than is the case with PS [28]. He concluded that because of the appellant’s individual circumstances – including his association with the Assemblies of God – there was a real risk that he would suffer ill-treatment if returned to Iran, “despite revealing that his claim for asylum was fabricated and [offering] to sign the renunciation” [50].

The appeal was remade and allowed on asylum and Article 3 ECHR grounds [52].

Which led Elijah Z Granet (to whom I am obliged for drawing the judgment to my attention) to comment:

“this might have had to be the correct decision to protect the Art 3 rights of Applicant, but It has the bizarre result that there are now certain denominations to which a fake conversion entitles claimants to asylum, while other denominations provide no such protection.”

Cite this article as: Frank Cranmer, "Asylum: may a bogus Christian “convert” be returned to Iran?: MR" in Law & Religion UK, 17 August 2020,

One thought on “Asylum: may a bogus Christian “convert” be returned to Iran?: MR

  1. The result is bizarre only because the facts are bizarre. Ostensibly, the doctrine of Islam condemns all apostasy, the leaving of Islam, equally, regardless of which alternative religion or non-religion one embraces instead. The facts found were that notwithstanding this doctrine, apostasy might be more or less tolerable in this particular quarter, depending upon which alternative belief system the apostate had purported to embrace, whether sincerely or not, nuanced upon subtleties of churchmanship that few in the secular, post-Christian west pay great attention to nowadays.

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