The significance of this research lies in examining the extent to which administrative decisions issued by the Holy Shrines are subject to judicial review, given the unique nature of these religious institutions and their growing role in service provision and development within Islamic societies. The study addresses a legal ambiguity and complexity regarding the legal nature of these decisions: specifically, whether they are issued by independent sovereign entities exempt from oversight, or by public institutions subject to the jurisdiction of administrative courts—a matter further complicated by the divergent legislative approaches in Iraq and Iran. To address this issue, the researcher analyzes relevant legislative texts and internal regulations, as well as rulings issued by Iraq’s Administrative Judiciary Court and Iran’s Court of Administrative Justice, in order to define the legal status of these Shrines and the legal characterization of their decisions. The study employs a structural and functional comparative approach to highlight research insights by identifying similarities and differences, ultimately offering a foundational perspective that balances the independence of the Shrines with the right of individuals to seek judicial redress. The research concludes that there is a disparity in how these decisions are subjected to oversight; while Iraqi law tends to broaden the scope of review to ensure legality, the Iranian system affords greater flexibility regarding the nature of these religious institutions, though both countries exhibit legislative gaps that allow certain decisions to remain shielded from judicial scrutiny. In conclusion, the practical significance of this subject lies in guiding the legislator and the judiciary toward formulating clear legal rules that ensure the protection of rights and freedoms against arbitrary actions by religious administrative bodies, while providing litigants with a secure judicial avenue to challenge decisions made by the Holy Shrines.