Deaths in custody are among the most sensitive issues in international human rights law and one of the most significant indicators for assessing a state’s commitment to the rule of law. When an individual is deprived of liberty, the state assumes not only the authority to restrict that person’s freedom but also the direct responsibility to protect their life, health, and human dignity. Accordingly, every death that occurs in custody is not merely a medical or criminal matter; it raises the fundamental question of whether the state took all necessary measures to prevent the death and, once it occurred, whether an independent investigation was conducted in accordance with international standards.

Drawing upon the International Covenant on Civil and Political Rights (ICCPR), General Comment No. 36 of the Human Rights Committee, the Minnesota Protocol on the Investigation of Potentially Unlawful Death, and other instruments of international law, this article examines the legal framework governing state responsibility for deaths in custody. It then applies these standards to four prominent cases in Iran—Zahra Kazemi, Sattar Beheshti, Baktash Abtin, and Mahsa (Jina) Amini—to evaluate the extent to which mechanisms for prevention, investigation, and accountability comply with international standards.

The article further draws on documented reports concerning conditions in Iranian prisons, particularly the report “Death in Prison or Execution During Wartime,” to demonstrate that deaths in custody cannot be understood merely as a series of isolated cases. Reports of denial of medical treatment, shortages of food and medicine, forced transfers, restrictions on communication with family members, inadequate detention conditions, and the absence of effective mechanisms for protecting detainees suggest that some of the existing risks may stem from structural deficiencies within the detention system itself.

The findings of this study indicate that, under international law, a state’s responsibility extends beyond merely refraining from the arbitrary deprivation of life. It also encompasses positive obligations to prevent avoidable deaths, conduct independent investigations, ensure accountability, provide effective remedies and reparation, and reform the institutional structures that create the conditions for the recurrence of such incidents. From this perspective, deaths in custody should be regarded not simply as criminal cases but as a benchmark for evaluating states’ commitment to human dignity, the rule of law, and their international obligations.

Introduction

The right to life is the most fundamental of all human rights and the foundation upon which all other fundamental rights and freedoms rest. For this reason, the principal international human rights instruments—from the Universal Declaration of Human Rights to the International Covenant on Civil and Political Rights (ICCPR)—place its protection at the center of their legal framework. The significance of this right becomes even greater when an individual is deprived of liberty, because from the moment of detention, they are no longer able to make independent decisions regarding the most basic aspects of their own life. They cannot freely seek medical care, leave a dangerous environment, or make decisions to protect their own life. These responsibilities are transferred to the state, which assumes not only the exercise of public authority but also the duty to safeguard the life of a person under its control.

For this reason, deaths in custody occupy a distinct position in international law compared with other cases of death. If an individual dies while living freely in society, the state is obliged to investigate the cause of death and prosecute those responsible. However, if that same individual dies while in custody, the state must do more than fulfill these duties; it must also explain how a person who was entirely under its control came to lose their life. In such cases, the state is not merely the investigating authority—it is itself the subject of investigation.

Over recent decades, developments in international law have significantly expanded this responsibility. Today, the right to life is understood as more than a prohibition against arbitrary killing. States are required to prevent avoidable deaths, reduce foreseeable risks, conduct independent investigations into every suspicious death, and implement structural reforms to prevent recurrence. This evolution has made the concept of the state’s positive obligations one of the central pillars of international human rights law.

In Iran, over the past two decades, cases such as the deaths of Zahra Kazemi, Sattar Beheshti, Baktash Abtin, and Mahsa (Jina) Amini, together with numerous reports concerning prison conditions, have made deaths in custody one of the country’s most significant human rights issues. Despite their differences, these cases raise common questions: Did the state take the necessary measures to protect the lives of those in its custody? Were the investigations sufficiently independent, transparent, and effective? And have existing mechanisms been capable of preventing the recurrence of such incidents?

Accordingly, the central research question of this article is:

What obligations do states have under international law to prevent deaths in custody, conduct independent investigations, and ensure accountability, and to what extent do the cases of deaths in custody in Iran comply with these international standards?

To answer this question, the article first examines the legal framework governing state responsibility, then outlines the international standards for independent investigations, subsequently provides a comparative analysis of four prominent Iranian cases, and finally assesses the state’s structural performance in light of its international obligations through an examination of reports concerning prison conditions.

The Legal Framework of State Responsibility for Deaths in Custody

Deaths in custody constitute one of the most significant areas of state responsibility under international human rights law because, unlike many other situations, the deceased lost their life at a time when their liberty had been restricted by a decision of the state and every essential aspect of their life was under the direct or effective control of public authorities. Consequently, international law draws a fundamental distinction between the death of a person living freely and the death of a person in custody. In the former situation, the state’s primary obligation is to investigate the crime and prosecute those responsible. In the latter, however, the state must not only fulfill those duties but also explain how a person whose life it was obligated to protect came to die while under its custody.

This understanding is the product of a significant evolution in the concept of the right to life over the past half-century. During the early years of the international human rights system, the right to life was understood primarily as imposing a negative obligation upon the state—that is, the state must refrain from arbitrarily depriving individuals of life. While this represented an important limitation on governmental power, it proved insufficient to address many forms of human rights violations in practice. The experience of countries where individuals died not from the bullets of state agents but as a result of torture, denial of medical care, inhuman prison conditions, or deliberate neglect demonstrated that limiting state responsibility to cases of direct killing ignored a substantial part of the reality.

For this reason, international law gradually developed the concept of the state’s positive obligations. Under this approach, the state is not merely required to refrain from killing; it must actively protect human life, reduce foreseeable risks, and prevent avoidable deaths. This development is clearly reflected in General Comment No. 36 of the United Nations Human Rights Committee on Article 6 of the International Covenant on Civil and Political Rights. The Committee emphasizes that the right to life requires states to take all necessary measures to protect the lives of individuals, particularly those who are under their custody or control. This obligation includes preventing violence, prohibiting torture, ensuring access to adequate medical care, and conducting effective investigations into every suspicious death.

The importance of this development becomes even more apparent when an individual has been deprived of liberty. Detention is not merely a restriction on freedom of movement; it transfers a substantial portion of an individual’s responsibility for their own life to the state. A person living freely may choose a physician when ill, leave a dangerous environment, or make decisions to protect their own life. A detainee, however, is deprived of all these options. They cannot choose where they are held, access medical services freely, or leave if danger arises. Under such circumstances, the state not only possesses the authority to impose restrictions but also assumes responsibility for protecting the detainee’s life and health.

From this principle emerges the concept of effective state control, which today constitutes one of the fundamental principles of international law governing deaths in custody. The greater the state’s control over an individual’s life, the greater its responsibility. When a person dies in prison, a police detention facility, a security detention center, or any other place under state authority, the first question posed by international law is not what evidence the victim’s family possesses against the state; rather, it is how the state fulfilled its duty to protect the life of a person who was entirely under its control.

For this reason, in many cases involving deaths in custody, the burden of explanation effectively rests with the state. The state must demonstrate the individual’s condition upon admission to detention, the medical care they received, the officials responsible for their custody, the cause of death, and the measures taken to prevent it. If official accounts are contradictory, evidence has disappeared, access to information by the family or legal counsel is restricted, or the investigation is conducted by the same institution accused of wrongdoing, the credibility of that investigation may be seriously called into question under international law.

In this context, the right to life is inseparably linked with the prohibition of torture and the principle of human dignity. Today, torture is no longer understood solely as physical assault or violence. The deliberate denial of medical treatment, prolonged detention under inhuman conditions, extended solitary confinement, deprivation of adequate food or safe drinking water, the infliction of severe physical or psychological suffering, and even the conscious disregard of a detainee’s medical condition may, under certain circumstances, constitute inhuman treatment or torture. Where such conduct ultimately results in the death of a detainee, the state’s responsibility arises not only under the prohibition of torture but also for violating the right to life.

At this point, one of the most significant distinctions between international law and certain domestic criminal justice systems becomes evident. In many domestic legal systems, responsibility is generally assessed on the basis of a positive act; it must be proven that a state official committed an act that directly caused the death. International law, however, also recognizes omission as a basis of responsibility. If officials fail to transfer an ill prisoner to a hospital despite knowing of the prisoner’s condition; detain individuals in circumstances where the risk of death is foreseeable; fail to adopt measures to protect detainees during military attacks or fires; or ignore complaints of torture and ill-treatment, such failures may themselves give rise to the state’s international responsibility.

Accordingly, the concept of death in custody under international law is far broader than a criminal or medical event. It encompasses a comprehensive set of state obligations that begin from the moment of detention and continue until the individual’s release or the completion of an independent investigation into their death. The state is required to protect the lives of those under its authority, ensure humane conditions of detention, provide appropriate medical care, reduce foreseeable risks, and, where a death occurs, conduct an independent, prompt, effective, and transparent investigation.

It was this doctrinal evolution that led to the development of the United Nations’ principal specialized instrument in this field—the Minnesota Protocol on the Investigation of Potentially Unlawful Death—which today serves as the primary international standard for evaluating the quality of investigations into deaths in custody.

Independent Investigation: The Most Important Safeguard for the Right to Life

If the state’s obligation to protect human life constitutes the first pillar of the international system for safeguarding the right to life, then an independent and effective investigation constitutes its second. International law requires states not only to prevent avoidable deaths but also, when a death occurs, to establish the truth, ensure accountability, and eliminate the conditions that make similar incidents possible. For this reason, an investigation into a death in custody is not merely a component of the criminal justice process; it is one of the most important guarantees of the effective protection of the right to life.

Experience over recent decades has shown that many deaths in custody have remained unresolved not because criminal laws were lacking, but because of the absence of independent investigations, the destruction of evidence, pressure on witnesses, restrictions on families’ access to information, and the dependence of investigative bodies on the very institutions implicated in the alleged violations. These experiences prompted the international community to develop common standards for investigating suspicious deaths.

The principal international instrument in this field is the Minnesota Protocol on the Investigation of Potentially Unlawful Death, which was revised and published in 2016 with the support of the Office of the United Nations High Commissioner for Human Rights. The Protocol does not create new criminal offenses; rather, it establishes the professional, medical, and legal standards required for conducting effective investigations and is now regarded as the leading international standard in this area.

The starting point of the Minnesota Protocol is a fundamental principle: whenever a person dies under circumstances in which the state exercised authority, control, or responsibility, the death should be treated as potentially unlawful until an independent investigation demonstrates otherwise. This principle is of particular importance in cases of deaths in custody, since the individual was entirely under state control at the time of death and had no ability to protect themselves.

Accordingly, the first requirement of a credible investigation is independence. Independence means more than the impartiality of a judge or prosecutor; it requires that the investigating body be institutionally, administratively, and operationally independent of any institution that may have been involved in the death. If members of a security or law enforcement agency are implicated, an investigation conducted by the same agency—or by authorities subordinate to it—will undermine public confidence, even if carried out in good faith.

The second principle is impartiality. Independence is necessary but not sufficient. An investigation must begin without preconceived conclusions and without seeking to validate the official account. All possible hypotheses, including the potential responsibility of state officials, must be examined equally, and no individual or institution should be excluded from scrutiny solely because of its official position.

The Minnesota Protocol also places particular emphasis on promptness. In cases of deaths in custody, time is one of the most critical factors in preserving the truth. Evidence of physical injuries, biological samples, surveillance footage, witness testimony, and the condition of the scene may all disappear or change within a short period. Consequently, any unnecessary delay in initiating an investigation may diminish the state’s ability to establish the truth and may itself constitute evidence of a breach of its international obligations.

Another fundamental requirement of the Protocol is the preservation of evidence. The state is obligated to preserve, without alteration, all relevant documents, photographs, medical records, detention records, surveillance footage, guards’ reports, and other related evidence. The destruction or tampering of such material not only impedes the search for the truth but may also call the credibility of the entire investigation into question.

Independent forensic examination is also of particular importance in cases of deaths in custody. An autopsy is conducted not only to determine the medical cause of death but also to answer critical legal questions, including whether there are signs of torture or ill-treatment, whether the timing and cause of death are consistent with the official account, and whether denial of medical care or delays in treatment contributed to the individual’s death. For this reason, the Minnesota Protocol emphasizes that forensic experts must enjoy complete professional independence and that their findings must not be influenced by political or security considerations.

One of the most significant developments in international law in recent years has been the recognition of the family’s right to know the truth. The victim’s family is not merely a private complainant; it holds an independent right to know what happened to their loved one, who was responsible, and how the investigation is progressing. This right, now commonly referred to as the “right to truth,” forms part of the broader right of access to justice. A state cannot disregard this right by classifying information as confidential or by restricting the family’s access to the case file.

The Minnesota Protocol also extends its focus beyond individual responsibility to include structural factors. The purpose of an investigation is not solely to identify the official who may have been directly responsible for the death; it must also determine whether managerial failures, institutional policies, inadequate medical facilities, insufficient oversight, or a culture of impunity contributed to the incident. This approach reflects the understanding that justice is not achieved merely by punishing a single individual but also requires reforming the structures that allow such violations to recur.

These same standards provide the basis for assessing deaths in custody in Iran. The central question is not simply whether an investigation was conducted, but whether that investigation was independent, impartial, transparent, and effective, and whether it succeeded in establishing the truth, ensuring accountability, and preventing similar incidents from recurring. Answering this question requires an examination of specific cases, which is undertaken in the following comparative analysis of four prominent deaths in custody in Iran.

A Comparative Study of Deaths in Custody in Iran in Light of International Human Rights Standards

Assessing a state’s compliance with its obligations under the right to life cannot be achieved solely through an examination of legal texts. The true test of any legal system lies in how it responds to actual cases. For this reason, international law consistently links legal principles with the practical conduct of states. Deaths in custody, particularly where the individual was entirely under state control at the time of the incident, constitute one of the most important benchmarks for evaluating that conduct.

Over the past two decades, numerous cases involving deaths in custody have emerged in Iran. Although these cases differ in terms of timing, the alleged cause of death, the detaining authority, and the surrounding political context, they can all be evaluated under international law using the same criteria: prevention, protection of life, independence of investigations, transparency, accountability, and structural reform.

The cases of Zahra Kazemi, Sattar Beheshti, Baktash Abtin, and Mahsa (Jina) Amini are among the most significant examples to have attracted attention both within Iran and internationally.

1. The Case of Zahra Kazemi: The First Major Test of an Independent Investigation

The death of Zahra Kazemi in July 2003 (Tir 1382) may be regarded as the first case that brought deaths in custody to the forefront of human rights discourse in Iran and within the international community. She was arrested while photographing outside Evin Prison and died several days later while still in the custody of Iran’s security and judicial authorities.

From the outset, official accounts of the cause of death were inconsistent. At various times, authorities referred to a stroke, a fall, impact with a hard object, and ultimately a skull fracture. These shifting explanations gave rise to the first fundamental legal question: was the state able to provide a single, documented, and verifiable account of the death of a person who had been entirely under its control?

Under the Minnesota Protocol, in such circumstances the state is required not only to establish the medical cause of death but also to clarify every aspect of the individual’s detention, interrogation, transfer, medical treatment, and final hours. Furthermore, the investigation must be conducted by a body independent of those institutions involved in the arrest or interrogation.

In Zahra Kazemi’s case, one of the principal criticisms raised by human rights organizations and the Government of Canada concerned the absence of a fully independent investigative mechanism. From the perspective of international law, even if an investigation reaches the correct conclusion, public confidence in its impartiality is undermined when the same institutional structure implicated in the allegations is also responsible for conducting the investigation.

Moreover, the judicial proceedings ultimately focused on the responsibility of a single official, while no comprehensive assessment was undertaken regarding the managerial, supervisory, or institutional responsibility of the authorities involved. International law, however, emphasizes that an investigation should not be limited to identifying the direct perpetrator; it must also examine the entire chain of decision-making and oversight.

2. The Case of Sattar Beheshti: Responsibility Arising from Torture and Failure to Act on Prior Warnings

From the perspective of international law, the case of Sattar Beheshti presents a distinct feature because, prior to his death, he had submitted written complaints alleging torture and ill-treatment. This means that the state’s responsibility extends beyond the circumstances of his death itself, demonstrating that the relevant authorities were aware of a potential risk before the fatal incident occurred.

Under international law, once state authorities become aware of a serious threat to an individual’s life or health, their positive obligation to take preventive action is triggered. Accordingly, where a formal complaint of torture or violence has been made, the state is required to arrange an immediate medical examination, initiate an independent investigation, and remove the individual from the dangerous environment.

Although one police officer was eventually convicted in connection with Sattar Beheshti’s death, this does not exhaust the state’s responsibility under international law. The more significant question is why the initial complaints failed to prompt immediate action and what institutional shortcomings allowed a foreseeable danger to result in death.

For this reason, the case provides a clear illustration of the distinction between individual responsibility and institutional responsibility. Punishing a single official may satisfy part of the requirements of criminal justice, but without reforming oversight mechanisms, the risk of similar incidents recurring remains.

3. The Case of Baktash Abtin: Expanding the Concept of Death in Custody to Include Denial of Medical Care

The case of Baktash Abtin is one of the clearest examples demonstrating that deaths in custody do not always result from direct physical violence. After contracting COVID-19 in prison, he was transferred to a hospital only after a significant delay and subsequently died.

From the standpoint of international law, this case is particularly significant because it expands the concept of state responsibility beyond torture and physical abuse to encompass medical care and prison administration.

Under international standards, prisoners cannot seek medical treatment on their own initiative. The state therefore bears direct responsibility for ensuring their access to healthcare. Any unnecessary delay in transferring a sick prisoner, refusal of medical treatment, or denial of necessary medication that results in death may constitute a violation of the right to life.

Accordingly, the legal assessment of this case is not limited to determining the medical cause of death. It must also examine whether the transfer to hospital occurred in a timely manner, whether adequate medical facilities were available, and whether administrative or security decisions contributed to the deterioration of his health.

The case of Baktash Abtin demonstrates that, under international law, omissions can give rise to state responsibility just as much as affirmative acts.

4. Mahsa (Jina) Amini: A Test of Public Confidence and Independent Investigation

From the perspective of international law, the case of Mahsa (Jina) Amini is perhaps the most significant death in custody in Iran in recent years. After being detained by the Guidance Patrol (Gasht-e Ershad), she was transferred to hospital, where she died several days later.

The case quickly attracted international attention and became the subject of scrutiny within United Nations mechanisms. This was not solely because of its political significance, but also because of the substantial discrepancy between the official account and the accounts presented by her family, medical professionals, and human rights organizations regarding the cause of death.

Under international standards, the central questions raised by this case include:

• Were all surveillance camera recordings preserved and made available?
• Did the forensic examination enjoy sufficient independence?
• Did the family have full access to the case file?
• Were all officials involved in the arrest subjected to investigation?
• Did the investigation succeed in gaining public confidence?

These questions led the United Nations Human Rights Council to establish an independent Fact-Finding Mission on Iran. The establishment of such a mechanism does not in itself establish state responsibility; however, it does indicate that the international community had serious doubts regarding the adequacy of the domestic investigation.

Comparative Analysis

When these four cases are examined together, despite their differences in time and subject matter, several common features emerge.

First, in every case, the individual was under the effective control of the state at the time of the incident. Accordingly, the state’s obligation to protect their life had been fully engaged.

Second, each case gave rise to concerns regarding the quality of the investigation, the transparency of official information, or the scope of accountability. This suggests that the central issue was not merely determining the cause of death, but also maintaining public confidence in the investigative process itself.

Third, none of these cases can be attributed solely to the conduct of a single official. In all four instances, questions were raised concerning the performance of the responsible institutions, oversight mechanisms, the quality of medical services, the preservation of evidence, the role of senior officials, and the reforms undertaken following the incident.

The comparative study of these cases therefore demonstrates that evaluating state responsibility should not focus exclusively on the outcome of individual cases. Rather, the essential question is whether the existing institutional framework is capable of preventing similar deaths from recurring. Answering this question requires moving beyond individual cases and examining structural patterns within the detention and prison system.

From Individual Cases to Structural Patterns

Although the four cases discussed in the previous section differ in terms of chronology, cause of death, and the authorities involved, they are not, by themselves, sufficient to assess the performance of a detention system. International law seeks not only to analyze individual cases but also to identify “structural patterns”—situations in which a combination of policies, practices, or institutional deficiencies repeatedly increases the risk of human rights violations.

For this reason, evaluating state responsibility does not end with answering the question, “Who was responsible for a particular death?” The more important question is whether the existing institutional structures are designed to prevent such deaths or, conversely, create conditions that make them more likely.

Within this framework, the report Death in Prison or Execution During Wartime, which has also been relied upon in this article, is more than a record of isolated incidents. It presents a broader picture of conditions in Iranian prisons during a period of crisis. Although all of the report’s findings require independent verification, the information it contains provides a basis for legal analysis under international standards.

One of the first issues highlighted in the report is the deprivation of prisoners’ basic necessities. Reports from Greater Tehran Prison (Fashafouyeh), Evin Prison, Sheiban Prison in Ahvaz, and central prisons in Sanandaj, Urmia, Kermanshah, and several other facilities describe shortages of food, limited access to safe drinking water, the unavailability of essential medicines, and disruptions in medical services. In some instances, families were reportedly unable to deliver medication to prisoners, while transfers to medical facilities were delayed.

From the perspective of international law, these are not merely administrative or managerial shortcomings. Under international standards, individuals deprived of liberty are no longer able to secure their own basic needs, and responsibility for doing so rests entirely with the state. Consequently, shortages of food, inadequate medical care, or denial of medication that endanger a prisoner’s health or life may constitute a breach of the state’s positive obligation to protect the right to life.

A second major issue concerns the lack of preparedness to protect prisoners during emergencies. Reports relating to Greater Tehran Prison, Evin Prison, and Kachouii Prison indicate that during military attacks or major fires, some prison wards remained locked, emergency evacuation was impossible, and prisoners had virtually no means of escaping danger. Some reports even refer to prison ward doors being welded shut and prisoners being housed adjacent to sensitive military or security facilities.

International law provides a clear standard in this regard. Once the state deprives an individual of liberty, its responsibility to protect that person increases proportionately. If a prisoner is unable to save their own life because a prison ward is locked or because no evacuation plan exists, the state cannot simply argue that the primary cause of the incident was an external attack or a fire. The relevant question is whether the authorities anticipated the foreseeable risk and took reasonable measures to reduce it.

A third issue concerns the isolation of prisoners from the outside world. The report documents multiple instances of prisoners being transferred to undisclosed locations, restrictions on contact with family members, lawyers being unaware of their clients’ whereabouts, and increasing obstacles to obtaining information.

Under international law, communication with family members and legal counsel is not merely a welfare benefit; it is one of the most important safeguards against torture, enforced disappearance, and deaths in custody. The less external oversight there is over detention facilities, the greater the risk of human rights violations. For this reason, both the United Nations Human Rights Committee and the Committee against Torture have repeatedly emphasized that denying detainees access to their families and lawyers, particularly during the initial stages of detention, significantly increases the risk of ill-treatment and death.

A fourth issue concerns prison healthcare and sanitary conditions. Reports describe outbreaks of disease, overcrowding, unsanitary conditions, insect infestations, inadequate medical facilities, and delays in treatment across several prisons. These concerns have become even more significant in the aftermath of the COVID-19 pandemic. International law requires states to provide prisoners with a standard of healthcare comparable to that available to the general public. Individuals should not be deprived of appropriate medical treatment simply because they have been deprived of their liberty.

The case of Baktash Abtin clearly illustrates the importance of this principle. His case demonstrated that a death in custody is not necessarily the result of direct violence but may instead result from delays in treatment or administrative decisions. Reports from other prisons raise similar concerns on a broader scale and demonstrate that the quality of healthcare is an inseparable component of the state’s obligation to protect the right to life.

Another notable issue is the continuation of executions during periods of crisis. The report indicates that even while prisons were experiencing the consequences of armed conflict, prisoner transfers, and disruptions in basic services, executions continued to be carried out. Although executions are legally distinct from deaths in custody, they nevertheless form part of the broader context in which the right to life and the state’s obligation to protect human life must be assessed. They also underscore the importance of independently reviewing decisions taken under such extraordinary circumstances.

When these reports are considered together with the cases examined earlier, several common characteristics become apparent.

First, in every instance, the risks to prisoners’ lives were foreseeable—whether arising from illness, denial of medical care, detention conditions, or emergency situations.

Second, in most cases, the state exercised complete control over the individuals concerned, leaving prisoners with no independent means of protecting themselves.

Third, concerns were raised regarding the quality of oversight, the transparency of information, and accountability, all of which affected public confidence in the investigative process.

Fourth, although these incidents occurred in different prisons, they share common elements, including inadequate medical care, restrictions on family contact, non-transparent prisoner transfers, and the absence of effective emergency management mechanisms.

From the perspective of international law, these similarities permit the issue to be examined as a potential structural pattern.

At the same time, legal methodology requires a distinction between the existence of a concerning pattern and proof of responsibility in individual cases. Existing reports cannot replace independent judicial investigations, and every allegation must be examined separately. Nevertheless, when multiple reports, individual cases, and independent sources consistently point to similar problems over an extended period, international law regards this as an indication that structural reform is necessary.

Legal Assessment and Conclusion

An examination of international legal principles, United Nations instruments, the Minnesota Protocol, and the comparative analysis of Iranian cases demonstrates that the concept of deaths in custody has undergone a fundamental transformation over recent decades. Whereas state responsibility was once understood primarily to arise when state officials directly caused the death of an individual, international law now extends that responsibility to all situations in which the state, through either action or omission, creates the conditions for the preventable death of persons under its authority.

Consequently, deaths in custody are no longer viewed merely as criminal or medical matters. They have become one of the principal indicators of a state’s commitment to the rule of law, human dignity, and its obligations under international law. Once the state deprives an individual of liberty, its responsibility to protect that person’s life increases accordingly. That responsibility begins at the moment of detention and continues until the individual is released or the truth surrounding their death has been fully established.

This study has demonstrated that state responsibility for deaths in custody rests upon three fundamental pillars: prevention, independent investigation, and accountability.

First, the state is obligated to prevent avoidable deaths. This obligation extends beyond refraining from direct violence and includes providing adequate medical care, proper nutrition, humane conditions of detention, protection against violence, effective emergency management, and the reduction of all foreseeable risks. Any failure to fulfill these duties that results in death or serious harm may give rise to the state’s international responsibility.

Second, when a death occurs, the state must conduct an independent, prompt, impartial, and effective investigation. Such an investigation must establish not only the cause of death but also all of the circumstances leading to it, including the conditions of detention, the individual’s physical condition, the conduct of officials, prison authorities, medical personnel, and the chain of command. The independence of the investigating body, preservation of evidence, professional forensic examinations, participation of the family, and access to information are indispensable components of this obligation.

Third, an investigation complies with international standards only if it results in genuine accountability. In international law, accountability means more than the punishment of a single official; it requires identifying institutional shortcomings, implementing structural reforms, and establishing safeguards to reduce the likelihood of recurrence.

The cases of Zahra Kazemi, Sattar Beheshti, Baktash Abtin, and Mahsa (Jina) Amini demonstrate that although these incidents differ in their factual background, detaining authorities, and alleged causes of death, they raise common legal questions: Were the risks foreseeable? Did the state take the necessary measures to protect the individuals’ lives? Were the investigations sufficiently independent and transparent? And, following each case, were meaningful institutional reforms introduced to prevent similar incidents?

Alongside these cases, reports concerning prison conditions in Iran indicate that deaths in custody cannot be understood solely through the lens of a few isolated incidents. Reports describing inadequate medical care, shortages of food and medication, poor detention conditions, undisclosed prisoner transfers, restrictions on family contact, and the absence of effective emergency protection measures, if confirmed through independent investigations, may point to challenges extending beyond individual events or particular prisons. From the standpoint of international law, when such patterns recur over time, the assessment moves beyond individual responsibility to encompass the state’s structural responsibility.

At the same time, this article emphasizes an important methodological principle. Human rights reports, reports issued by non-governmental organizations, and even reports produced by international bodies cannot replace independent judicial investigations. Every allegation concerning a death in custody must be evaluated on the basis of evidence, forensic examinations, witness testimony, and impartial investigations. Nevertheless, when numerous reports, cases, and independent sources consistently identify similar problems over extended periods, the state cannot rely solely on the absence of a final judicial ruling in each individual case to avoid its responsibility to undertake structural reform.

One of the principal findings of this study is that impunity itself becomes a factor contributing to the continuation of violations. If each death in custody is not followed by a thorough determination of the truth, meaningful accountability, and institutional reform, the likelihood of repetition increases. Effective prevention therefore requires more than legislative reform. It demands independent oversight institutions, guaranteed professional independence for forensic medicine, comprehensive documentation of detention procedures, immediate access to legal counsel and medical care, continued contact with family members, and meaningful oversight by independent domestic and international bodies.

Accordingly, several legal measures may be proposed to bring domestic practice closer to international standards:

• Establish an independent mechanism to investigate all deaths in custody, separate from the authorities responsible for detention or prison administration.
• Guarantee the professional independence of forensic medicine and permit autopsies to be conducted in accordance with international standards.
• Ensure the preservation of all documents, recordings, and information relating to detention and interrogation, and prevent the destruction or manipulation of evidence.
• Guarantee detainees immediate access to medical care, legal counsel, and communication with their families from the earliest stages of detention.
• Develop emergency protection plans for prisons covering situations such as fires, natural disasters, and armed conflict.
• Apply the principles and standards of the Minnesota Protocol in all investigations into suspicious deaths.
• Strengthen cooperation with United Nations human rights mechanisms and make use of their expert recommendations in reforming the detention and prison system.

In conclusion, the answer to the central question of this article may be summarized as follows: international law does not regard deaths in custody as exceptional incidents, but as a test of a state’s willingness and ability to protect human life. The greater the gap between domestic practice and international standards, the greater the likelihood of international responsibility. Conversely, a state that effectively prevents such deaths through preventive measures, independent investigations, genuine accountability, and structural reform not only fulfills its legal obligations but also strengthens public confidence in justice, the rule of law, and human dignity.