CAT/C/65/D/691/2015 8.2 The complainant submits that the fact that she did not apply for asylum until her husband declared his concerns about their relationship does not make her need for protection less viable or sincere. There was no need for her to seek protection until her husband threatened her. The complainant also submits that she was also living in a very threatening situation, in which her application for asylum would risk setting off her husband and placing her in even greater danger. This is corroborated by the fact that she sought and was afforded protection from her husband at a women’s shelter. 8.3 The complainant further submits that her accounts have changed somewhat over time due to her changing situation and the escalation in the threats she received. Her story was also perhaps not as detailed or consistent as it might have been due to her stressful living situation and her fear of her husband and his family. However, regardless of her story and the State party’s evaluation of it, the complainant stresses that the fact that she is divorced and has been granted protection from her ex-husband at a women’s shelter, together with the relevant country information, must serve as the basis for the Committee’s final assessment of the merits of the case. 8.4 The complainant rejects the State party’s argument that she has submitted no evidence or reasoning in support of her allegations that her ex-husband accused her of infidelity and promiscuity and that he intended to disseminate intimate pictures of her to authorities in the Islamic Republic of Iran. She notes that it is far from unreasonable or even illogical that an abusive ex-husband, if he felt betrayed by his wife, would use his advantageous position to try to hurt her in various ways, as cases of abuse and manipulation of women in these types of situations are well documented. The complainant further notes that the same could be said about her risk of being subjected to ill-treatment due to her political affiliation. The State party’s submission does not contribute anything new in this respect, apart from reiterating the conclusions of the domestic authorities, which did not necessarily provide a correct assessment. 8.5 The complainant concludes that there are several different factors in her situation that, when considered and assessed in conjunction, together with the dire situation that women and politically active Kurds today face in the Islamic Republic of Iran, ultimately must lead to the conclusion that she faces a personal, foreseeable and real risk of being subjected to torture in the Islamic Republic of Iran, and that her expulsion would therefore amount to a breach of article 3 of the Convention. Issues and proceedings before the Committee Consideration of the merits 9.1 The Committee has considered the communication in the light of all the information made available to it by the parties, in accordance with article 22 (4) of the Convention. 9.2 In the present case, the issue before the Committee is whether the removal of the complainant to the Islamic Republic of Iran would constitute a violation of the State party’s obligation under article 3 of the Convention not to expel or to return a person to another State where there are substantial grounds for believing that he or she would be in danger of being subjected to torture (refoulement). This includes torture or other ill-treatment at the hands of non-State entities, including groups that are unlawfully exercising actions that inflict severe pain or suffering for purposes prohibited by the Convention and over which the receiving State has no or only partial de facto control, or whose acts it is unable to prevent or whose impunity it is unable to counter. 23 9.3 The Committee must evaluate whether there are substantial grounds for believing that the complainant would be personally in danger of being subjected to torture upon return to the Islamic Republic of Iran. In assessing that risk, the Committee must take into account all relevant considerations, including the existence of a consistent pattern of gross, flagrant or mass violations of human rights in the Islamic Republic of Iran. However, the Committee recalls that the aim of such determination is to establish whether the individual 23 10 Committee against Torture, general comment No. 4 (2017) on the implementation of article 3 in the context of article 22, para. 30.