IN THE HIGH COURT OF MADHYA PRADESH AT GWALIOR BEFORE HON'BLE SHRI JUSTICE AMIT SETH WRIT PETITION No. 33181 of 2025 KRISHNA MISHRA MINOR THROUGH NATURAL GUARDIAN BOBBY MISHRA AND ANOTHER Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Upendra Yadav - Advocate for the petitioners.

Shri Rajendra Jain - Govt. Advocate for respondents/State.

Reserved on : 10/02/2026 Delivered on : 18/02/2026 ORDER With the consent of parties, the matter is heard finally.

1. The instant writ petition filed under Article 226 of the Constitution of India seeks the following reliefs:​

"(a) That, the order (Annexure-P/1) may kindly be quashed.

(b) That, respondents may kindly be directed to grant the arms license to the petitioners for the purpose of training.

(c) Any other relief which this Hon'ble Court deems fit in the facts and circumstances of the case may also kindly be granted."

2. Brief facts leading to filing of the present writ petition are as under:

2.1 The petitioners, both under 21 years of age and above 12 years of age, being declared as renowned shooters by the National Rifle Association of India and participated in various rifle and pistol shooting tournaments conducted by the Association, moved separate applications under Rule 36 of the Arms Rules, 2016 (hereinafter referred to as Rules of 2016) seeking grant of arms license for training and target practice in prescribed statutory FORM-III, i.e., Licence for the acquisition, possession, carrying and use of arms or ammunition for sport/target practice/protection/display of categories I(B), I(C), III, V, VI of Schedule I.

2.2 The said applications submitted by the petitioners have been rejected by respondent No.2 vide separate orders dated 23.07.2025 (Annexure-P/1) on the ground that since the petitioners are under 21 years of age, therefore, in terms of Rule 36(1) of the Arms Rules, 2016, they are not eligible for grant of pistol/revolver license in FORM-III. However, the petitioners have been granted liberty to move an application for grant of license in FORM-III-A, i.e., license for possession and carrying by a retainer of an exemptee of arms or ammunition for the purpose of sport/protection/display.

3. Learned counsel appearing for the petitioners submits that respondent No.2 had erred in law in holding that the petitioners are ineligible for grant of arms license for training and target practice in terms of FORM- III and Rule 36(1) of the Rules of 2016, as the petitioners are less than 21 years of age and thereby granting liberty to the petitioners to apply for the license in FORM-III-A.

4. He submits that the reason assigned by respondent No.2 for rejecting the applications preferred by the petitioners in the impugned orders is in utter misreading of the very provision and object of Rule 36 of the Rules of 2016. He submits that the petitioners may be also eligible to apply for grant of license in FORM-III-A, but they cannot be held to be ineligible for grant of the arms license applied in FORM-III.

5​ . By referring to I.A. No.1405/2026 filed by the petitioners for taking documents on record, counsel appearing for the petitioners submits that during the pendency of the present writ petition, the petitioners have applied for and they have been issued a certificate in Form-S-1, certifying that the petitioners have completed Arms and Ammunition Safety Training Course, indicating their eligibility for safe usage and storage of firearms in terms of Rule 10 of the Rules of 2016.

6. Counsel for the petitioner submitted that although at the relevant time when the petitioners applied for an arms license in FORM-III, they were not in possession of the certificate issued in terms of Rule 10 of the Rules of 2016, but subsequently, the petitioners have been issued the said certificate as well. However, the fact remains that the rejection of the application submitted by the petitioners by respondent No.2 is not on the ground that they did not possess the Form-S-1 certificate issued under Rule

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