Legislative approaches and criminal responses to the phenomenon of prostitution: A comparative analysis in the Iranian legal system and European Union documents.

Rayejian Asli, Mehrdad; Asadzadeh, Saeed

doi:10.22034/jlvi.2026.2065315.1410

Legislative approaches and criminal responses to the phenomenon of prostitution: A comparative analysis in the Iranian legal system and European Union documents.

Document Type : Research/Original/Regular Article

Authors

Mehrdad Rayejian Asli ¹

saeed asadzadeh ²

¹ Associate Professor, Department of Law, Institute for Research and Development of Humanities (SAM), Tehran, Iran

² Master of Science in Juvenile and Juvenile Criminal Law, Faculty of Law and Political Science, Allameh Tabatabaei University, Tehran, Iran

10.22034/jlvi.2026.2065315.1410

Abstract

Abstract:

Prostitution, as a complex socio-legal challenge, has prompted diverse legislative and criminal approaches across global legal systems. Using a descriptive-analytical and comparative method, this study examines the criminal policies of Iran and the European Union documents regarding prostitution. The main research question is: "What differences and similarities do the legal systems of Iran and selected European Union countries (focusing on the Swedish, Dutch, and English models) have in legislative approaches and criminal responses to the phenomenon of prostitution, and what effects have these differences had on the ethical, social, and human rights challenges in each of these societies?" Findings reveal that legal systems adopt four main models based on ethical, cultural, and human rights foundations: the Swedish Model (criminalizing the purchase of sexual services), the Dutch Model (legalization with regulation), the British Model (harm reduction), and the Absolute Prohibition Model (for children). In Iranian law, while no explicit legal title addresses prostitution, it is countered through criminal labels such as adultery (zina), pimping (qiyadat), operating brothels, and public immorality. By analyzing the strengths and weaknesses of each model, this article proposes legislative strategies prioritizing human dignity and mitigating social harms.

Keywords

Prostitution

Legislate Approaches

Criminal Responses

Comparative Analysis

Iranian Legal System

European Union Documents

Subjects