Part 1 Clause 4(3)(b) pg 6 – parts relating to a prohibited firearm are defined as now
including a butt, stock, silencer or sight. At Part 1 Clause 2C pg 7 a “prohibited part
means – (a) a part of a prohibited firearm” – we believe there are three possible
interpretations to the effect of clause 2C on clause 4(3)(b)
o The first is what we believe is the intent of the draft to prohibit parts “born as”
an MSSA part. An example would be a gas block or operating rod. However, it
would also include an extractor spring and possession of it would carry a more
serious penalty than assault.
o Then there are the parts that would fit both restricted firearms and standard
firearms. Such as a scope or other sight, a silencer or a stock. We query what
would happen if a person had possession of a prohibited part fitted to a standard
firearm?
o
The most concerning interpretation being that any one of the now prohibited
firearm parts can be a prohibited part in its own right. The unintended
consequence is that every firearm has a stock and a sight so this could mean that
a firearm that is not a prohibited firearm may be classed prohibited because it
uses a prohibited part effectively making every firearm in the country a
prohibited firearm held without permit. We do not believe this is the intent of
the bill and request clarity on this aspect.
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