This article examines a significant dispute concerning state liability in a public health crisis—namely, claims arising from alleged injuries caused by COVID-19 vaccination and the conflict between the court of first instance and the appellate court. The central issue is the determination of governmental liability within a vaccination program.

The trial court, relying on the Islamic jurisprudential principle of no harm (qa'idat la darar), the right to health, and the equitable distribution of social risk, held the State liable for compensation. In contrast, the appellate court, emphasizing the sovereign character of the vaccination campaign and invoking Article 20 of the Islamic Penal Code, recognized governmental immunity and denied liability.

The research adopts a doctrinal and analytical methodology, grounded in close examination of the two judgments, exploration of Iranian legal foundations—including the Civil Liability Act, Islamic doctrines of liability (daman), and relevant constitutional principles—and a comparative study of three models: the United States, Europe, and Japan. The comparative analysis demonstrates that contemporary legal systems have moved away from absolute immunity toward qualified immunity accompanied by compensation mechanisms. National vaccine injury compensation funds and specialized administrative schemes constitute integral components of vaccination policy in these jurisdictions.

The principal finding is that judicial reasoning evolved from recognition of state liability at first instance to affirmation of immunity on appeal. This shift appears inconsistent with jurisprudential foundations of liability in Islamic law, principles of restorative justice, and prevailing comparative models, as no advanced legal system accepts immunity without an accompanying compensation mechanism.

Accordingly, the article proposes establishment of a national vaccine injury compensation fund, formulation of criteria for establishing causation in vaccination-related claims, and adoption of judicial guidelines tailored to public health emergencies. Within the Iranian legal framework, reconciling the tension between state liability and governmental immunity should not be pursued through expansion of fault-based judicial liability or endorsement of absolute immunity. Rather, it is more coherently achieved through recognition of a model of compensatory liability grounded in social risk and institutionalization of administrative compensation mechanisms, a model consistent with Islamic jurisprudential doctrines, constitutional principles, and comparative experience.