The situation faced by Christian converts in Iran has deteriorated significantly since the previous country guidance decisions issued in FS and Others (Iran – Christian Converts) CG [2004] and SZ and JM (Christians – FS confirmed) Iran CG [2008]. In so far as they relate to non-ethnic Christians, they are replaced by the current decision as follows:

• An “ordinary” Christian convert “seeking to openly practice that faith in Iran would face a real risk of persecution” (para. 143). A claimant in this position choosing to conceal their faith because of their fear of such persecution is entitled to international protection. By contrast, where a claimant would choose to conceal their conversion to Christianity for any other reasons, such as family pressure, societal disapproval of the religion or a personal preference, their asylum application should be refused. This is because, generally, solitary worship within the privacy of one’s home does not entail a real risk of persecution.

• Iranian citizens who claimed asylum as converts but who do not hold a genuine belief in Christianity do not face a real risk of persecution within Iran. Nevertheless, decision-makers must consider the risk of harm arising from the detention and interrogation that all failed asylum seekers face upon arrival. There is a risk of ill treatment where a detention becomes prolonged. Factors leading to prolonged detention include “previous adverse contact with the Iranian security services, connection to persons of interest to the Iranian authorities, attendance at a church with perceived connection to Iranian house churches” and having promoted Christianity on social media. (para. 144)

In light of the Country Guidance (CG) findings, the appellant’s case was dismissed. The Upper Tribunal concluded that PS was likely to be interrogated by the authorities on arrival and to be required “to sign an undertaking promising that he would not undertake any Christian activities” in Iran, and would be released thereafter. (para. 151) He did not present any aggravating factors that would lead to a prolonged detention. As such, PS did not face a risk of serious harm on return to Iran either on account of his false conversion-based asylum claim or on account of his church attendance and baptism in the UK.