Boris Johnson is under attack for referring to a British/Iranian woman under jail sentence in Iran as having been training journalists there on behalf of her employer, the Thomson Reuters Foundation. It may be notable, though, that the papers are putting inverted commas around the word ‘mistake’.

Whatever the truth of the matter, if you’re a dual citizen then when you’re in the other country the UK’s access to you will depend entirely upon the law or practice in that country. Plenty of countries don’t recognise dual citizenship and in such cases if citizens want to be a citizen of another country they have to give up their first citizenship.

There are good reasons for this in many cases – such as African states not wanting to be ruled by citizens of their former imperial masters. Here’s an article on the citizenship situation in Iran – it’s highly political and people clearly take on personal risk if they choose to keep two passports in this context.

The harsh reality is that it isn’t hard to breach anti-spying rules, especially in countries like Iran, so employers and governments have to be very careful what they ask people to do. If you’re a dual citizen who meets with a conduit to your host government before you leave for a visit to your ‘old’ country, then report back on what you’ve seen and heard – even if it’s just talking about activities in your neighbourhood in your ‘old’ country – then if you’re arrested it’s VERY hard for the UK to argue that you weren’t spying.

In this case, with Iran not recognising dual nationality and the woman in question not having cancelled her Iranian one, in theory and practice she’s simply an Iranian citizen carrying out activities which the Iran government says are against the interests of her own country.

Throw in the fact she works for a news-gathering organisation and may have attended protests outside the Iranian embassy (at which, if true, she will have been photographed by the Embassy staff) and it’s all looking a bit tricksy to say the least.

My own instinct is that the FCO is probably right to go softly and wait for an exchange opportunity, rather than tell the Iranians they’re out of order. Why? Because it’s certain we do spy in Iran and they in the UK, and with good fortune an exchange opportunity will likely come along.

It’s not impossible, although of course we simply can’t tell right now, that Johnson and the FCO (Johnson was using an FCO brief) are signalling to the Iranians the UK government’s acceptance that the woman man in question may have, inadvertently or otherwise, crossed a boundary. This might be a prerequisite to the Iranians doing a deal on her release. In the meantime, calls in the media for Johnson to apologise could very well be deeply counter-productive.

The Thomson Reuters Foundation needs to reflect, though. Even if Johnson is wrong and the woman in question wasn’t working in Iran, then as an Iranian national training people in the UK how to get around Iranian censorship – if that bit is true – she had still opened herself to considerable risk should she ever travel home. I do wonder if her employer bears some responsibility for the whole mess.

In any case, it’s a terrible situation for Mrs Zagharai-Ratcliffe and her family and I hope she’s home to the UK soon. At which point, it’d be a good idea to bin the Iranian passport.