His return could represent a move by hard-liners to challenge the moderate Shiite clerics who now dominate Iraq.
As a moderate cleric who preached patience to the faithful, Ayatollah Hakim has been a key factor in keeping Shiites behind the United States effort.
The moderate clerics believe that the fastest antidote for radicalism is providing security, jobs and electricity, which they say will sway Shiites away from extremism.
In orthodox Iran, a relatively moderate cleric who preaches tolerance and studies Kant and de Tocqueville has been elected President.
Karim Bourti was charged with assault after beating a moderate Muslim cleric in an attempt to extort funds from him.
But an alliance of moderate Muslim clerics, women's advocates, civil court judges and divorce lawyers endorsed the reforms.
And another court issued an arrest warrant for a popular moderate cleric who was accused of insulting Islam because he attended a recent conference in Berlin on democracy.
The Parliament speaker, Mehdi Karoubi, is a moderate mid-ranking cleric who had previously avoided confrontation with hard-liners.
His mosque, which is located in al Qassim Province, is known among more moderate clerics as a "terrorist factory."
Even the moderate Shiite clerics were shaky on these issues and now their standing appears to have been weakened by the current surge of anti-Americanism.