JUDGMENT : MURALI PURUSHOTHAMAN, J. 1. The 1 st petitioner in W.P.(C) No. 19708/2022 is an association of farmers, and petitioners 2 and 3 are its members. Petitioners 2 and 3 and the petitioners in other writ petitions have submitted individual applications for firearms licence. The applications were either rejected or not considered by the licensing authority, as the applicants failed to produce training certificates issued by Accredited Trainers or Master Accredited Trainers. It is stated that the Government of Kerala has not, so far, formally approved or licensed any person as an “Accredited Trainer” or “Master Accredited Trainer” under Rule 39(1) of the Arms Rules, 2016 (hereinafter referred to as ‘Rules’ for short) as the mandatory policy guidelines contemplated under the provisos to Rule 39(1) and (2) are yet to be issued by the Ministry of Home Affairs, Government of India. It is contended that, although the Government of India had issued an advisory permitting weapon handling training through State Police armourers and issuance of certificates in Form S-1 through a State established mechanism, pending guidelines under Rule 39, the Government of Kerala, despite issuing a detailed procedure outlining the syllabus and venue for such training, later suspended it. It is in these circumstances that these writ petitions are filed. 2. Section 3 of the Arms Act, 1959 (hereinafter referred to as the ‘Act’ for short) mandates that no person may acquire, possess, or carry any firearm or ammunition without a valid license. Section 13 of the Act deals with the grant of licence for firearms and provides that an application shall be made to the licensing authority in the prescribed form, with the required details and fees, and that the licensing authority, after conducting such inquiry as it considers necessary and after considering the police report, shall, subject to the other provisions of Chapter III, decide by a written order whether to grant or refuse the licence. Section 14 deals with refusal of licences and Section 15 deals with duration and renewal of licence. Section 14 deals with refusal of licences and Section 15 deals with duration and renewal of licence. Rule 10 of the Rules deals with the safe use and storage of firearms and Sub- Rule (1) thereof provides that every applicant applying for a licence shall be required to complete arms and ammunition safety training course which shall include – (a) basic arms and ammunition safety practices, including safe handling and carry procedures; (b) firing techniques and procedures; (c) care of arms and ammunition; (d) safe storage and transportation of arms and ammunition; (e) reasonable working knowledge of important provisions of the Act and these rules; and (f) responsibilities of the arms owner or user, particularly in relation to children. Sub-Rule (2) of Rule 10 provides that the safety training course under sub-rule (1) shall be conducted by the accredited trainer or master accredited trainer having licence under Rule 39, who shall issue a certificate in Form S- 1, to the applicant, on successful completion of the said course. Sub-Rule (3) of Rule 10 provides that the effective date and duration of the safety training course as laid down in sub-rule (1) shall be notified by the Central Government by issuing a general or special order in this regard. Rule 39 deals with licence for accredited trainers and reads as follows: “39. Licence for accredited trainers.— (1) Any person applying for a licence to be an accredited trainer shall be required to clear the eligibility test and undergo training before being granted a licence under this rule: Provided that the policy guidelines containing syllabus and conduct of examination for accredited trainers may be specified by the Central Government by passing a general or special order in this regard. (2) Any person applying for grant of a licence to be a master accredited trainer shall be required to possess the technical knowledge and expertise in handling various types of small arms and submit the documentary evidence to the satisfaction of the licensing authority in this regard: Provided that the policy guidelines for grant of licences to master accredited trainers may be specified by the Central Government by passing a general or special order in this regard: Provided further that master accredited trainers shall be entitled to impart training to the accredited trainers referred to in sub-rule (1). (3) Master accredited trainers and accredited trainers, having been granted a licence under this rule shall be eligible to - (i) impart training as specified in rule 10 to the applicants and licensees under these rules; and (ii) issue training certificates to different types of trainees on the successful completion of the stipulated training programme. (4) The norms for making available the shooting ranges for imparting training to accredited trainers may be specified by the Central Government by passing a general or special order in this regard. (5) The shooting ranges as referred to in sub-rule (4) shall include the Government shooting ranges owned or operated by Defence Forces, Central Armed Police Forces, State police departments; and the private shooting ranges owned and operated by shooting clubs or associations having been granted a licence in Form V of these rules. Explanation - For the purposes of this rule, master accredited trainers refer to small arm experts having worked in Defence Forces, Central Armed Police Forces, State Police Forces; and international medalists and renowned shooters as defined under the Explanation to rule 40.” 3. A statement dated 22.09.2025 has been placed on record in W.P.(C) No.23086/2025 by the learned Senior Government Pleader on behalf of the State of Kerala which has been adopted in other cases by an adoption memo. It is stated that, the guidelines containing syllabus and conduct of examination for accredited trainers and the policy guidelines for grant of licences to master accredited trainers under Rule 39 are under the consideration of Government of India. It is further stated that the Government of India, Ministry of Home Affairs as per Advisory F No: V- 11019/34/2017-Arms dated 17.01.2018 (Annexure R1(a)) decided that till guidelines are circulated, the licensing authorities (sic) are allowed to get the weapon handling training from the armour employed with the State Police Department and the certificate in prescribed proforma S-1 be issued by a committee/mechanism established by the State Government concerned for such purpose. The State Governments were further directed that no additional requirements of furnishing of documents or eligibility norms be levied on applicants apart from conditions and norms specified in the Arms Rules. Based on this, the State Police Chief as per order No. D6- 150760/2021/PHQ dated 23/03/2022 fixed the syllabus, schedule of classes, venue for preliminary lessons of firing training and training fees. Based on this, the State Police Chief as per order No. D6- 150760/2021/PHQ dated 23/03/2022 fixed the syllabus, schedule of classes, venue for preliminary lessons of firing training and training fees. W.P(C) No. 19708/2022 is filed seeking, inter alia, a direction not to conduct any training course as per the said order. This Court, as per order dated 29.07.2022 therein, observed as follows: “I find prima facie force in the submission that, on the strength of a mere communication, the applicants, cannot be compelled to have training at the venues decided by the State Police Chief, since the requirement under Rule 10(3) is that the Central Government should bring out a notification specifying the venues and syllabus for Arms training.” In the said circumstances, the training programme was suspended. It is stated that the Government of India in pursuance of Sub-rule (3) of Rule 10 of the Rules issued Annexure R1(c) notification dated 18.02.2025 prescribing the duration and syllabus for safety training courses. The Statement concludes by stating that the Government of Kerala is awaiting notifications under Rule 39, which are expected to resolve all issues relating to safety training. 4. A Statement on similar lines has been placed on record on behalf of the Union of India in W.P. (C) No. 37696 of 2025 by the learned Central Government Counsel. 5. It is pertinent to note that, after the training programme was suspended pursuant to the order dated 29.07.2022 in W.P.(C) No. 19708/2022, a memo dated 22.03.2023 was filed by the learned Senior Government Pleader in the said writ petition, producing a communication dated 08.03.2023 from the Additional Chief Secretary (Home) addressed to the Additional Director General of Prosecution (Ext.P6 in W.P. (C) No. 37696 of 2025), stating that the Government had decided to accept arms licence applications accompanied by training certificates issued by Accredited Trainers or Master Accredited Trainers. 6. As stated in the statements filed by the Union of India and the Government of Kerala, the Government of India, in pursuance of sub-rule (3) of Rule 10 of the Rules has issued Notification F. No. V- 11026/77/2023 dated 18.02.2025 (Annexure R1(c)), prescribing the duration and syllabus for safety training courses. However, the guidelines containing syllabus and conduct of examination for accredited trainers and the policy guidelines for grant of licences to master accredited trainers under Rule 39 have not yet been issued. 7. However, the guidelines containing syllabus and conduct of examination for accredited trainers and the policy guidelines for grant of licences to master accredited trainers under Rule 39 have not yet been issued. 7. In W.P. (C) No. 37696 of 2025, the petitioner has produced a copy of the list dated 25-11-2023 (Ext. P7) issued by the State Police Chief, Kerala, addressed to the Additional Chief Secretary, Home Department, showing that the State Police Chief has vetted and prepared a list of Accredited Trainers/Master Accredited Trainers in the State pursuant to Ext. P6 communication dated 08.03.2023 of the Additional Chief Secretary, Home Department. The petitioner therein has also produced Ext. P8, evidencing a list of 24 new firearms licences issued by the accredited trainers referred to in Ext. P7 list. Accordingly, this Court on 25.11.2025, passed an order in these writ petitions which reads as follows: “1. There will be a direction to the second respondent to file an affidavit as to whether the persons mentioned in Exts.P7 and P8, as accredited trainers in W.P.(C) No.37696 of 2025, can issue training certificates while considering the applications under the provisions of the Arms Act and Rules. 2. The affidavit shall be filed within three weeks from today. Post on 15.12.2025." Based on the above, an affidavit was filed by the Additional Chief Secretary (Home) Department on 07.01.2026. This Court, by order dated 14.01.2026, observed that the affidavit filed does not answer the query posed by this Court in the order dated 25.11.2025, namely, whether the persons mentioned in Exts.P7 and P8, as Accredited Trainers in WP(C) No.37696 of 2025, can issue Training Certificates while considering the applications under the provisions of the Arms Act and Rules. Accordingly, this Court directed the Additional Chief Secretary to file an appropriate affidavit explaining as to how the statements were made in the affidavit filed before this Court, overlooking Ext.P6 as well as Ext.P13 dated 18.12.2023 and also the stand of the Government on the issue in question. 8. Pursuant thereto, the Additional Chief Secretary has filed an affidavit dated 02.02.2026 which reads as follows: “2…..It is submitted that the Government maintains a proactive and applicant- friendly approach, as previously indicated in Ext.P6, where it was decided in principle to consider training certificates issued by accredited trainers. However, it must be strictly governed by the statutory framework of the Arms Act and Rules. 3. However, it must be strictly governed by the statutory framework of the Arms Act and Rules. 3. It is submitted that Ext.P7 is a letter from the State Police Chief which contains a list of persons merely identified or selected by the Police Department for the purpose of future accreditation. This document is a preliminary internal identification and does not amount to formal approval. 4. It is submitted that the factual position is that the Government of Kerala has not formally approved or licensed any person as an “Accredited Trainer” or “Master Accredited Trainer” under Rule 39(1) so far. This lack of formal approval is due to the fact that the mandatory policy guidelines for granting such licenses under the Proviso to Rule 39(2) are still pending issuance by the Ministry of Home Affairs (MHA), Government of India. Since the matter is currently under the consideration of the Government of India, the State is legally unable to finalize the status of these trainers at this moment. It is submitted that as soon as the Central Government issues the necessary orders, the State will issue the approvals. Furthermore, as per the notification issued vide File No:V-11026/77/2023 dated 14.02.2025, in pursuance of Sub-rule (3) of Rule 10 of the Arms Rules, 2016, the Central Government has notified that the safety training course, as specified in Sub-rule (1) of Rule 10, Shall be for a duration of not less than 270 minutes, comprising six sessions as per the prescribed syllabus. In the light of this, all identified trainers will be required to strictly follow the training syllabus yet to be notified. The State is committed to ensuring that once the Gol guidelines regarding trainers/master trainers are notified, the Government will issue valid certificates in compliance with the standards.” 9. Not being satisfied with the additional affidavit, this Court, on 03.02.2026, passed an order observing that there was no mention in the affidavit as to whether the persons referred to in Exts. P7 and P8 as accredited trainers were authorised to issue training certificates for the purpose of considering applications under the provisions of the Arms Act and the Rules. The said order reads thus: “......... 5. P7 and P8 as accredited trainers were authorised to issue training certificates for the purpose of considering applications under the provisions of the Arms Act and the Rules. The said order reads thus: “......... 5. In the above circumstances, there will be an interim order in all these cases provisionally permitting the accredited trainers in Exts.P7 and P8 in W.P.(C) No.37696 of 2025 to issue training certificates, based on which the applications under the provisions of the Arms Act and Rules can be considered. 6. It is made clear that the above order is passed in the circumstances mentioned above. This order is provisional and subject to further orders to be passed in these writ petitions.” 10. The time granted by this Court in the order dated 03.02.2026 was extended by one month on 26.02.2026 and this Court directed the District Collectors/Additional District Magistrates concerned to pass orders as directed on 03.02.2026 and report compliance by the next posting date. 11. In the meantime, the Government of Kerala, issued G.O.(Rt)No.397/2026/HOME dated 02.02.2026 (Ext. P16 in WP(C) No.37696 of 2025) to resume the training in line with Annexure R1(c) ’Arms and Ammunition Safety Training Course Syllabus’ notified by the Ministry of Home Affairs, Government of India. Arms and Ammunition Safety Training Course Syllabus has been appended to the said Government order as Annexure-I and list of individuals provisionally authorized to impart training and to issue S-1 certificate is appended as Annexure-II. The relevant portion of the Government order reads as follows: “......... 5. In compliance to the Hon'ble High Court order, the training program has been suspended. Meanwhile, as per the decision taken in the Minutes of the Meeting held on 06/02/2023 read as 5th paper above, it has been brought to the attention of the Hon'ble High Court that the Government is willing to accept arms licence applications with training certificates issued by Accredited Trainers/Master Accredited Trainers. The State Police Chief has also been directed to furnish a list of eligible persons to be designated as Accredited Trainers. Accordingly, as per the letters read as 6th paper above, the State Police Chief submitted a list of 11 individuals who possess the required qualifications, except for the eligibility test clearance and the training mandated under Rule 39 of the Arms Rules, for which detailed guidelines are yet to be notified by the Ministry of Home Affairs . 6. Accordingly, as per the letters read as 6th paper above, the State Police Chief submitted a list of 11 individuals who possess the required qualifications, except for the eligibility test clearance and the training mandated under Rule 39 of the Arms Rules, for which detailed guidelines are yet to be notified by the Ministry of Home Affairs . 6. The Ministry of Home Affairs, Government of India, as per the letter referred to as the 7th paper above, and in continuation of the advisory cited as the 1st paper above, has furnished the notification issued pursuant to Sub-rule (3) of Rule 10 of the Arms Rules, 2016. The notification prescribes the Arms and Ammunition Safety Training Course, which includes a syllabus comprising six sessions totaling 270 minutes. This course is mandatory and must be followed by the State Licensing Authority for issuing the certificate in Proforma S-1 to applicants for an arms licence. 7. In the above circumstances, in line with the directions of the Ministry of Home Affairs, Government of India, Government are pleased to order that, concurrently, the State Police Chief shall restart the suspended training course in alignment with the 'Arms and Ammunition Safety Training Course Syllabus' notified by the Ministry of Home Affairs, Government of India, restructuring the course and fees accordingly for the issuance of the S-1 certificate. It is also ordered that, in line with the interim mandate of the Ministry of Home Affairs, Government of India vide letter read as 1st paper above, the selected individuals who possess the required qualifications as per the report from State Police Chief (as identified in Annexure-II), are hereby provisionally authorized to impart training as per the prescribed safety training syllabus by collecting a nominal fee, for the issuance of the S-1 Certificate, pending the notification of detailed guidelines by the Central Government under Rule 39 of the Arms Rules, 2016. The Arms and Ammunition Safety Training Course Syllabus is appended as Annexure-I. 8. The above orders are issued in line with the directions of the Ministry of Home Affairs, Government of India, as per the letters read as 1st and 7th paper above and shall remain in effect until comprehensive policy guidelines regarding training and accreditation of trainers are issued by the Ministry of Home Affairs in this regard.” 12. The above orders are issued in line with the directions of the Ministry of Home Affairs, Government of India, as per the letters read as 1st and 7th paper above and shall remain in effect until comprehensive policy guidelines regarding training and accreditation of trainers are issued by the Ministry of Home Affairs in this regard.” 12. In the light of G.O.(Rt)No.397/2026/HOME dated 02.02.2026, and the order of this Court dated 03.02.2026, these writ petitions are disposed of permitting the accredited trainers mentioned in Exts.P7 and P8 in W.P.(C) No.37696/2025 as well as those listed in Annexure-II of the said Government Order to issue training Certificates to the petitioners. Based on such certificates, the applications of the petitioners for firearms licences shall be considered, subject to other provisions of the Act and Rules. The applications for firearms licence of the petitioners already accompanied by training certificates issued by accredited trainers in Exts.P7 and P8 in W.P.(C) No.37696/2025 as well as those in Annexure-II, shall also be considered in accordance with the provisions of the Act and Rules. This direction shall also apply to all pending applications of the petitioners for firearms licence as well as the applications of petitioners that were dismissed for want of training certificates issued by accredited trainers. The District Collectors/ Additional District Magistrates concerned shall pass orders as directed above within two months from the date of receipt of a copy of this judgment. 13. All applications for firearms licences submitted after the issuance of G.O.(Rt) No. 397/2026/HOME dated 02.02.2026 shall be disposed of in accordance with the said Government Order, until notifications under Rule 39 of the Arms Rules are issued by the Union of India. The writ petitions are allowed accordingly.