Changes to the Firearms Legislation with the introduction of the Criminal Justice (Miscellaneous Provisions) Act 2009 placed a cap on the licensing of Centre Fire short firearms (pistols) essentially individuals who had licences prior to November 2008 were permitted to maintain their licence for centre fire pistols.

Since 2009 it became practice by AGS to refuse applications for substitution for Centre Fire short firearms.

Prior to the Firearms Consultative Panel meeting on 20th April 2017 the NASRPC sough and were granted the opportunity to make a submission on the basis that there was no prohibition in the legislation on the substitution of this class of firearm. We circulated this submission as it was presented to all clubs immediately after the meeting.

The submission from the NASRPC had been made following convincing legal opinion that supported the view of the NASRPC that there was no legitimate reason whereby a substitution could be or should be refused.

On the 16th of August 2017 the NASRPC received a communication from the Department of Justice and Equality with a number of reasons why substitutions could not be permitted. This was circulated to clubs immediately after receipt.

The NASRPC immediately sent this communication to our legal advisor who further informed us that the reasoning would not support such a position as taken by the DOJ.

The NASRPC being part of the Sports Coalition sought support, the Sports Coalition articulated the view to the DOJ that their position of 16th August was not in line with strong legal advice and seeking to avoid any potential for a necessary legal challenge to be lodged requested the DOJ to reconsider their advices.

I am very pleased to advise that as of today after correspondence received (copy attached) from the Department of Justice & Equality, I can confirm that substitutions for centrefire short firearms are lawful under Section 11 of the Firearms Acts 1925 to 2009.

This is very good news for our members who can now proceed with replacing their centre fire pistols that they use for the purpose of Target Shooting, the news is even better because it is a testimony to the importance placed on dialogue and cooperation, cooperation of the NASRPC with the Sports Coalition and positive dialogue that showed the importance of twoway discussion with the Department of
Justice. This also shows the importance of appropriate representation from knowledgeable individuals who are part of the NASRPC and the Sports Coalition.

Please see below recent correspondence from the Department of Justice & Equality

  • Dear members,  At the last meeting of the FCP on 20 April 2017, the NASRPC made a
    submission proposing that the substitution of restricted short firearms was
    allowed for under firearms legislation. The Department agreed to consider
    the matter and revert. We subsequently sought legal advice on the matter
    and would like to share with you the main points of legal advice received
    as follows:· Although a contrary argument can be made, our legal advice is that,
    on balance, a Court is likely to find that section 3D(1) of the
    Firearms Act 1925 as amended, does not act as a bar to a substitution
    of a restricted short firearm under section 11 of the Firearms Act
    194, as amended.· The advice is that a Court is likely to find that restricted handguns
    may be substituted during the currency of an existing firearm
    certificate, following which the certificate will apply to the
    substituted firearm.

    · However, once the firearm certificate for the substituted firearm
    expires, section 3D(1) of the Firearms Act 1925, as amended, applies
    and the new  substituted restricted handgun is no longer licensable
    (as it was not licensed prior to November 2008).

    · The power of a Chief Superintendent under section 11 of the Firearms
    Act 1964, as amended, to substitute a restricted firearm is
    discretionary: it is a “may” rather than “shall” provision.

    · This discretion provided for with regard to substitution, as with all
    statutory powers of discretion, must be exercised in a manner that is
    reasonable and is not in accordance with a fixed policy.

    · Both restricted handguns (old and new) involved in a substitution
    cannot be licensed simultaneously.

    Kind regards

    Marion Walsh
    Firearms, Explosives and Private Security Policy Division
    Department of Justice & Equality

You may be aware that this is my last year on the committee of the NASRPC, I am delighted that we have some news that is positive to target shooting and emphasises the importance of being part of a larger lobby within the Sports Coalition, it also shows how positive cooperative dialogue with the Department of Justice & Equality has the effect of avoiding the unnecessary expense of taking issues thorough the

Personally, I would like to thank the NASRPC committee for their support over the two years that I have been on the committee, I would like to thank the constituent members of the Sports Coalition for their enlightened views and their support in concluding this matter positively.

Finally, I would like to thank our legal advisor William Egan, for without his expert opinion and tenacious nature we would not be enjoying the benefits of target shooting with certain classes of firearms.


Declan Keogh

National Development and Training Officer

National Association of Sporting Rifle and Pistol Clubs.

(NASRPC FCP Representative)

22nd December 2017