48 Unnamed Suspects in Iran’s Bloody Winter of Dey in the HRA Dossier S. Rouzbeh ۲۰۲۶/۰۹/۱۲ An examination of HRA’s dossier on the crackdown on the Dey protests, the 48 identified suspects, and efforts to pursue the responsibility of perpetrators and commanders through Germany’s Federal Public Prosecutor General. Who are the 48 people named in the 109-page dossier on the suppression of Iran’s Bloody Winter of Dey? Could those who gave orders, coordinated operations or played a part in the chain of killings and repression against the people one day be forced to answer for their actions beyond the borders of the Islamic Republic? For now, we do not know the names of these 48 people. But perhaps the significance of the dossier that the Human Rights Activists in Iran organisation, known by the acronym HRA, has submitted to Germany’s Federal Public Prosecutor General—with legal support from UpRights and in cooperation with German lawyers—lies not simply in revealing these names. Its principal importance lies in the path the investigation has taken: moving beyond scattered images of shootings and arrests in the streets to reach the individuals, institutions and structures that may have been behind the crackdown. On 3 September 2026, HRA announced that it had submitted a dossier of nearly 109 pages to Germany’s Federal Public Prosecutor’s Office concerning the suppression of the protests of December 2025 and January 2026, and had called for a ‘structural investigation’ into possible crimes against humanity. According to the dossier’s official summary, the original request was submitted on 1 September 2026 and made public two days later. The dossier is the result of several months of investigation. It draws on more than 60 interviews with victims, witnesses and family members inside Iran, in Turkey, Europe and North America, as well as a substantial body of digital and other evidence. HRA says the investigation also examined the types of weapons used, injuries, institutions involved, suspects and command structures. According to the published public summary, the investigation identified 48 people as suspects and examined their positions, organisational affiliations, areas of geographical responsibility, links to specific events and positions within command structures. This matters because it changes the question. For years, people in Iran have seen images of forces firing shots, dragging a young person along the ground or putting a detainee into a vehicle. Some wear uniforms; others are in plain clothes. Many remain unknown to the public. But if the person on the ground is unidentified, must the structure in which they operate remain unidentified too? The HRA dossier has sought to move beyond this point. Which units were involved? Which institution did the individuals belong to? In what area were they responsible? What connection was there between a specific incident and a senior official, and where did that person sit within the chain of command? According to the dossier summary, the 48 suspects were not selected solely from among forces present in the streets. Commanders of the Islamic Revolutionary Guard Corps, the Basij and the FARAJA, officials in intelligence agencies, provincial governors, prison officials, and prosecutorial and judicial authorities are also among the groups whose members’ possible roles have been examined. This means the investigation has gone beyond the simple question, ‘Who fired the shot?’ and raised others: Who gave the order? Who directed or coordinated the operation? Who had the authority to prevent it? Where were detainees taken? And which institutions continued the repression after the streets? HRA itself describes the purpose of a structural investigation as the systematic collection and preservation of evidence, the identification of responsible structures and individuals, and the preparation of the ground for future individual cases—even if, when the investigation begins, no specific suspect is available to the German judicial authorities. What is HRA? HRA is not a court, prosecutor’s office or international police force, and it has no authority to arrest people, issue indictments or convict them. Human Rights Activists in Iran is a non-governmental human rights organisation whose work began in 2006. It works to document and report human rights violations, collect and preserve information, provide education and legal support, and pursue accountability for human rights violators. The Human Rights Activists News Agency, HRANA, is also one of its affiliated organisations. For this dossier, HRA has worked with UpRights, a legal organisation based in The Hague that works on international criminal law and accountability for serious human rights violations. The 48 people identified in the new dossier are therefore not yet ‘defendants in a German court’, and no court has found them guilty. They are suspects about whom HRA has provided information to the German judicial authorities for examination on the basis of its investigations. This distinction may seem small, but it is very important to the credibility of the dossier. Justice, too, must follow what we expect of a court: evidence, investigation and proof—not condemning people in advance. HRA had previously identified at least 67 IRGC and FARAJA commanders by name and area of responsibility in its ‘Bloody Winter’ report. That list is not necessarily the same as the 48 suspects in the German case, and examining it could be the subject of a separate research project. Why Germany? The significance of choosing Germany lies in the country’s law on international crimes. Germany’s Code of Crimes against International Law, known as the VStGB, allows cases to be brought in relation to crimes including crimes against humanity, even when the acts took place outside German territory. As a result, the fact that a crime may have taken place in Iran does not, in itself, prevent it from being examined by the German judicial system. Of course, submitting this dossier does not mean that 48 arrest warrants have been issued. At the time of writing, no independent official confirmation has been published to show that Germany’s Federal Public Prosecutor General has launched a new structural investigation on the basis of HRA’s request. What we know for now is that the dossier has been submitted and the Public Prosecutor General has been asked to consider whether to open such an investigation and potentially pursue cases against specific individuals. But this mechanism is not merely a theoretical possibility. Germany has previously used structural investigations to gather and preserve evidence relating to torture and the actions of Syria’s security apparatus. Those investigations later laid the groundwork for individual cases and led, among other things, to the trial of Anwar Raslan, a former Syrian intelligence official, in the city of Koblenz. In 2022, he was sentenced to life imprisonment for crimes against humanity. This precedent does not guarantee that the Iran dossier will follow the same course. But it shows that the path HRA has now chosen is not simply a symbolic or media gesture and could have judicial consequences if the investigation is accepted and progresses. An example of how the chain can be traced A small example shows why identifying an official, a region and a chain of command matters. In its earlier report, “Bloody Winter”, HRA named Yadollah Bouali, commander of the Fajr Corps in Fars Province, and wrote that, in his position as commander, he had operational and strategic authority over the provincial Corps forces and might be responsible for the actions of forces under his command, including the use of excessive and lethal force against protesters. The European Union later sanctioned Bouali on 16 March 2026, stating that Corps forces under his command had fired on protesters during the nationwide protests that began in December 2025, killing and injuring people. This, of course, does not prove that Yadollah Bouali is one of the 48 confidential suspects in the dossier submitted to the German Public Prosecutor General. No public document currently says so. But this example shows how one can move from an incident, a region and the forces present on the ground to the organisational unit and then to the official responsible within the chain of command. And perhaps this is where the real significance of the German case for victims’ families lies. For a mother who has lost her child, no court can bring that child back. For a family that still does not know who fired or who gave the order, a 109-page dossier is not justice in itself either. But there is a great difference between a crime being forgotten and being recorded. When a mother’s testimony, footage of a shooting, the type of weapon, the location of an incident and information about the responsible official or unit move beyond social media and individual memory and become part of a dossier placed before a judicial authority, at least a new possibility opens up: that the evidence may be preserved for a day when access to the suspect and the possibility of judicial proceedings become available. HRA itself has also stressed this point: the evidence gathered today may determine whether accountability will be possible in the future. This is not yet a court judgment. Nor is it a promise of immediate justice. But for families who may have felt for years that their loved ones were lost among the statistics and news reports, it carries another message: what happened to them has not only been witnessed, but recorded and documented; some of that evidence has now crossed Iran’s borders and reached a European judicial authority. The names of the 48 suspects have not yet been made public. Perhaps today they remain hidden behind the redactions in the public version, but the case file itself now exists; witnesses have spoken, evidence has been gathered and the structures responsible have been examined. And perhaps justice does not always begin with a verdict. Sometimes it begins when a crime is not forgotten, a testimony is preserved, a name is sought, and a family knows that what happened to their loved one has not been buried in the silence of history. The central question remains: Who gave the order, who allowed it, and who must be held accountable? Reaching an answer to this question requires the participation of all people. Source: https://srouzbeh.com/en/posts/archive-c24fcdb8-a199-e1b1-d0f1-5c7579e4023e Please credit the author and link to this edition.