Comparative Study of Criminal Responsibility of AI in the Legal Framework of Iran and Saudi Arabia

Meghdadi, Zahra; Pourcheriki, Mahdi

doi:10.48308/jicse.2025.239843.1076

Comparative Study of Criminal Responsibility of AI in the Legal Framework of Iran and Saudi Arabia

Document Type : Original Article

Authors

Zahra Meghdadi ¹

Mahdi Pourcheriki ²

¹ Faculty of Law Shahid Beheshti University Tehran, Iran

² Faculty of Law and Political Science University of Tehran Tehran, Iran

https://doi.org/10.48308/jicse.2025.239843.1076

Abstract

I. Abstract— This paper examines the legal frameworks governing the criminal liability of artificial intelligence (AI) in Iran and Saudi Arabia, focusing on how both countries address the evolving role of AI in criminal acts. With the rapid advancement of AI technologies—from narrow (weak) AI, which performs specific tasks, to general (strong) AI, capable of autonomous decision-making—complex legal and ethical questions have emerged. Specifically, this paper examines the applicability of three theoretical models of AI criminal liability: Perpetration-By-Another Liability, Natural-Probable-Consequence Liability, and Direct Liability.

II. The comparative analysis highlights that despite differences in legal traditions and societal contexts, both Iran and Saudi Arabia recognize that AI itself cannot bear criminal responsibility, and instead, liability is attributed to human actors, such as developers, users, and operators. The findings suggest that integrating technological progress with ethical and legal safeguards, grounded in Islamic jurisprudence, is essential for addressing the challenges posed by AI-related crimes in both jurisdictions.

Keywords

Keywords—artificial intelligence

criminal liability

AI ethics principles

Saudi Arabia

Iran

Subjects