From Coppet to Stockholm, via Buenos Aires: The Long Quest for Justice for Iranian Victims
OPINION. Three examples of Iranian quests for justice demonstrate that civil society can effectively mobilize international law when states prove unable to protect victims of crimes, writes lawyer Alain Werner.
A key regional power and a major actor on the international stage, Iran sits at the center of global geopolitics. Recent events offer a striking illustration: the U.S. strikes almost certainly meet the definition of acts of aggression under international law.
Like what happened in Venezuela, this military intervention took place in a country whose regime has, for many years, committed serious human rights violations against its own population. And, as in the Venezuelan case, victims have sought justice beyond their national borders for crimes committed by Iranians against other Iranians. These efforts shed light on the opportunities offered by international law, but also on the obstacles that arise when people try to obtain elsewhere what they cannot hope to achieve at home: criminal convictions for mass crimes committed by their own government.
The murder of Kazem Rajavi in Coppet, 24 April 1990
Iran signed the Rome Statute establishing the International Criminal Court (ICC), but never ratified it. As a result, the Court cannot currently investigate or prosecute crimes committed in Iran by the regime since 2002. This is the case even though Iran has joined other international legal instruments, such as the Genocide Convention and the 1949 Geneva Conventions. This limitation is all the more striking given that the United Nations determined in 2024 that certain acts committed by the regime beginning in late 2022 amounted to crimes against humanity. In February, the European Parliament also concluded that the wave of repression unleashed against the population starting at the end of 2025 could also qualify as crimes against humanity.
For a long time, Iranian victims have understood that justice for the crimes they suffered would not come from international courts. As a result, many have turned to proceedings before foreign national courts.
This has happened in Switzerland. On 24 April 1990, in Coppet, Kazem Rajavi, a prominent figure in the Iranian resistance, was shot dead by a commando unit. Because the crime took place on Swiss territory, prosecutors in the canton of Vaud opened an investigation and issued an arrest warrant against Iran’s former Minister of Intelligence, Ali Fallahian. Thirty years after the killing, however, the Prosecutor’s Office in Vaud sought to close the case on the grounds that the statute of limitations had expired. Rajavi’s family appealed, arguing that this was not an isolated murder but rather part of a broader campaign aimed at systematically eliminating political opposition. In 2021, the Swiss Federal Criminal Court ruled in the favor of Rajavi’s family. It ordered federal prosecutors to reopen the investigation and examine the facts as acts that could constitute genocide or crimes against humanity. This means that if Mr. Fallahian were ever to leave Iran, he could face arrest under a Swiss warrant.
Arbitrary detention as a tool of pressure
The most spectacular example of extraterritorial justice involving Iran also took place in Europe—in Sweden—with the arrest of Hamid Nouri in Stockholm in November 2019. A former member of an execution committee inside an Iranian prison in 1988, he was implicated in waves of mass killings targeting prisoners loyal to the Mojahedin’s movement. Lured to Sweden through promises that were in fact a ruse designed to draw him there, Mr. Nouri was arrested upon arrival at the airport. A survivor of the 1988 massacres had played an active role in bringing about this operation. In July 2022, Nouri was sentenced to life imprisonment, a verdict upheld on appeal in December 2023. The trial was historically significant: for the first time, a member of the Iranian regime was personally tried and convicted for international crimes. However, on 15 June 2024, the Swedish government authorized his return to Iran as part of an exchange for two Swedish nationals who had been arbitrarily detained by the Iranian authorities. The decision caused outrage among the victims involved in the proceedings and was condemned by international organizations. It also raised fears that other states might resort to the arbitrary detention of foreign nationals as a tool of pressure—turning them into bargaining chips in response to judicial proceedings for international crimes.
Because jurisdictional links—such as the location where the crime was committed (as in the Swiss case) or the presence of the accused on national territory (as in the Swedish case)—are rare in situations involving Iran, some Iranian women have recently explored a new legal avenue. In December 2025, they filed a complaint in Argentina alleging crimes against humanity related to the events of 2022. Argentina does not require a jurisdictional link in order to prosecute international crimes. The country also has an important judicial precedent involving Iran. In 2024, Argentina’s Court of Cassation ruled that Iran was responsible for the 1994 bombing of a Jewish community center in Buenos Aires, which killed 85 people and injured hundreds of others, and classified the attack as a crime against humanity.
Given the current limitations of international courts, extraterritorial proceedings before the national courts of other countries will likely remain, for a long time, the preferred avenue for many victims—and their best chance of obtaining justice. These Iranian quests for justice show that civil society can effectively mobilize international law when the international community as a whole proves incapable of protecting victims or bringing perpetrators of crimes to justice. Yet these efforts require remarkable dedication and courage—and they are never entirely without risk.
The article first appeared in French on Le Temps on the 9th of March 2026
Image: Demonstrators protest outside the U.S. Embassy in London as part of a worldwide series of protests in solidarity with Iranian women. Credit: Alisdare Hickson / Flickr (CC BY-NC-SA 2.0)
