20 Harv. Hum. Rts. J. 227 (2007)
With Revolutionary Rage and Rancor: A Preliminary Report on the 1988 Massacre of Iran's Political Prisoners ; Shahrooz, Kaveh

handle is hein.journals/hhrj20 and id is 229 raw text is: With Revolutionary Rage and Rancor:
A Preliminary Report on the 1988 Massacre
of Iran's Political Prisoners
Kaveh Shahrooz*
We must establish incredible events by credible evidence.,
- Justice Robert Jackson
INTRODUCTION
In December 2005, Human Rights Watch (HRW) released a fifteen-
page Briefing Paper alleging that Mustafa Pour-Mohammadi, Iran's newest
Minister of Interior, played a central role in the 1988 (1367 in the Iranian
calendar) massacre of political prisoners in Iran.2 Without much elabora-
tion, HRW's publication further alleged that the executions constitute a
crime against humanity under international law.3 This HRW statement
and the creation of new human rights organizations focusing exclusively on
the Iranian government's human rights record4 are hopeful signs of a bur-
geoning interest in a thorough investigation of the 1988 prison massacre.
This paper attempts to contribute to such a project by compiling key infor-
mation about the mass killing and providing preliminary legal analysis.
This essay also highlights some of the problems that human rights activists
will face in pursuing the case.
* J.D., Harvard Law School, 2006. A version of this Article was presented at the 2006 Iran Future
Prospects Conference at Stanford University. I thank the conference participants and organizers, particu-
larly Dr. Abbas Milani, for their insight. The encouragement I have received from Catherine Skulan,
Amy Chen, Orkideh Behrouzan, Pouria Lotfi, Payam Akhavan, Shahrzad Mojab, and Ryan Goodman
helped me to recognize the urgency of this research and the importance of publishing the final product.
For providing editorial suggestions that improved this piece immeasurably, I thank Amanda Perwin,
Brandon Weiss, Stacy Humes-Schulz, and the staff of the Harvard Human Rights Journal. As always, I
owe endless gratitude to Maral Nadjafi. All errors herein are mine alone.
This Article is dedicated to the memory of Mehrdad Ashtari, who was executed at the age of 28 at
Gohar-Dasht prison, presumably on August 6, 1988.
1. JUSTICE ROBERT JACKSON, REPORT TO THE PRESIDENT ON ATROCITIES AND WAR CRIMES, June
7, 1945, available at http://www.yale.edu/lawweb/avalon/imt/jackOl.htm.
2. HUMAN RIGHTS WATCH, MINISTERS OF MURDER: IRAN'S NEW SECURITY CABINET 3 (2005),
available at http://hrw.org/backgrounder/mena/iran1205/iran1205.pdf (hereinafter MINISTERS OF
MURDER].
3. Id.
4. See, e.g., Arielle Levin Becker, Thinking of Home and Human Rights, N.Y. TIMES, Jan. 9, 2005, at
14CN (describing the establishment of the New Haven-based Iran Human Rights Documentation
Center).

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