A Comparative Study of Criminal Protection of Children Against Discrimination in the Legal Systems of Iran and the United Kingdom

Children, by virtue of their inherent physical, psychological, and social vulnerabilities, represent one of the most sensitive segments of society and are thus entitled to enhanced legal protections - particularly in the face of discrimination. Discrimination not only violates the fundamental human dignity of the child but also impedes their holistic development and long-term well-being. This study seeks to conduct a comparative analysis of the criminal protection of children against discrimination within two distinct legal systems: Iran and the United Kingdom. The main objective is to identify legal strengths and shortcomings in both systems and to formulate constructive recommendations for improving the protective legal framework in Iran. Employing a comparative approach and utilizing a descriptive-analytical methodology, the research examines legislative structures, explicitly or implicitly criminalized forms of discriminatory behavior, enforcement mechanisms, and the roles of competent institutions in each jurisdiction. The study focuses on domestic legal instruments such as the Islamic Penal Code and the Law on the Protection of Children and Adolescents in Iran, alongside the Equality Act ۲۰۱۰ and the Children Act ۱۹۸۹ in the UK. International legal standards, particularly the Convention on the Rights of the Child, are also referenced to assess alignment with global norms. Findings suggest that while the UK legal system provides a comprehensive and unified civil framework to combat discrimination - including that against children - through the Equality Act ۲۰۱۰, the Iranian system lacks a direct and explicit criminal provision addressing child-specific discrimination. Instead, it relies on general criminal norms. Both systems face challenges, including evidentiary difficulties and socio-cultural barriers, but their roots

کلیدواژه ها:

Children ، Criminal Protection ، Discrimination ، Legal Systems ، Iran ، United Kingdom