Gun control in
Great Britain now proceeds on two fronts. When a
sensational crime takes place, proposals for gun
confiscations and for major new restrictions on the
licensing system are introduced. During more tranquil
times, fees are raised and increased controls are
applied to relatively smaller issues.
of tranquil-period control was the Firearms Act of 1982,
which introduced restrictive licensing for imitation
firearms that could be converted to fire live ammunition.
The original proposal had been to implement the 1973 Green
Paper's outright ban on realistic imitation or toy firearms.
The sponsor of the new law against imitation firearms
promised that it would help stem "the rising tide of crime
and terrorism," although he pointed to no crime or terrorist
act committed with a converted imitation weapon. A new
Crossbows Act outlawed purchase by persons under seventeen.
"safety" regulations regarding explosives, persons who
possess modern gunpowder or blackpowder are now subject to
unannounced, warrantless inspections of their home at any
time to make sure that the powder is properly stored. The
government, of course, promises that its inspections will
not be unreasonable, but "reasonableness" is often in the
eye of the beholder.
crime is not as common as in the United States, gun crime
incidents inevitably attract sensational media attention
that becomes the basis for further tightening of controls.
In the fall of 1989, for example, a person who had been
rejected for membership in a firearms club stole a handgun
from the locked trunk of a club member and shot a Manchester
policeman. In another case a probationary member of a
firearms club, learning that he had a fatal disease, killed
one club member, stole a gun from the club, and shot a
personal enemy. The Home Secretary, at the urging of the
Manchester police department, issued a new set of
restrictions on firearms clubs, including sharp restrictions
on bringing guests to a range to shoot a firearm.
The practical effect of the new restrictions was to reduce
the entry of new members into many firearms clubs.
decades of such restrictions aimed at restricting entry into
the shooting sports, the vast majority of the public has no
familiarity with guns, other than what media choose to let
Legal British gun owners now constitute only four percent of
with perhaps another small percentage of the population
possessing illegal, unregistered guns.
Given that many Britons have no personal acquaintance with
anyone who they know to be a sporting shooter, it is not
surprising that seventy-six percent of the population
supports banning all guns.
Thus, the people who used long guns in the field sports--who
confidently expected that whatever controls government
imposed on the rabble in the cities who wanted handguns,
genteel deer rifles and hand-made shotguns would be left
alone--have been proven disastrously wrong.
rights usually need a strong sociological foundation.
Approximately half of American homes contain a gun, and a
quarter contain a hand gun. Thus, except in a few cities
like New York where gun ownership is rare, gun bans in the
United States are nearly impossible to enact; too many
voters would be unhappy. Consequently gun prohibition in the
United States must focus on very small segments of the
gun-owning population. That is why "assault weapon" bans,
which cover only about one or two percent of the total
firearms stock, are so much easier to enact than handgun
bans. Even with "assault weapons," it is usually necessary
to exempt the Ruger Mini-14 and Mini-30 rifles since these
rifles, while functionally identical to banned guns, have
too large an ownership base.
sensational burglaries in the 1880s had created the first
calls for restrictive British gun laws. A century later,
some sensational crimes would initiate the final stages of
British gun prohibition. In-between the 1880s and the 1980s,
an initially reasonable and then gradually more restrictive
licensing system had reduced the number of gun owners so far
that they had little political clout. The gun-owners
were of much less political significance than the media,
which had become venomously anti-gun.
On the morning of
August 19, 1987, a licensed gun owner named Michael Ryan
dressed up like Sylvester Stallone's "Rambo" character
and shot a woman thirteen times with a handgun.
After shooting at a filling station attendant, he drove
to his home in the small market town of Hungerford,
where he killed his mother and his dog. In the next
hour, he went into town and slaughtered fourteen more
people with his handgun and his Chinese-made Kalashnikov
rifle. Ryan disappeared for a few hours, reappeared at 4
p.m. in a school, and killed himself three hours later.
A few days later, a double murder was perpetrated at
Bristol, this one with a shotgun.
media's reaction, especially the print media's, was intense.
The tabloid press ran editorials instructing the public how
to spot potential mass murderers--advising suspicion of
anyone who lived alone or was generally a "loner," who lived
with his mother, or who was a bit quiet.
The tabloid press and the respectable press both pushed
heavily for more stringent gun laws.
Pressure also mounted for tighter censorship of violent
Hungerford atrocity was the only instance in which a
self-loading rifle had been used in a British homicide.
Punishing every owner of an object because one person
misused the object might seem unfair, but two factors worked
in favor of prohibition. First, the cabinet leadership
observed that the number of owners of self-loading rifles
was relatively small, so no important number of voters would
be offended. Second, shotgun owners, who are by far the
largest group of gun owners, generally decided that they did
not care what the government did to someone else's rifles.
responded. Semi-automatic centerfire rifles, which had been
legally owned for nearly a century, were banned.
Pump-action rifles were banned as well, since it was argued
that these guns could be substituted for semi-automatics.
Practical Rifle Shooting, the fastest-growing sport in
Britain, vanished temporarily, although participants
eventually switched to bolt-action rifles.
shotgunners, however, made a disastrous error. The
Association of Chiefs of Police had long been pushing to
bring shotguns into the restrictive "Section 1" of the
Firearms Act, which strictly controlled rifles and pistols.
The ACPO worked out a deal with the Thatcher administration
to take a major step in the ACPO's direction. As part of the
legislation responding to a crime with a rifle, controls on
shotguns were made significantly more stringent. There was
little criminological rationale for the extra restrictions
on shotguns; indeed, the extra police personnel required to
administer the licenses would have to be diverted from other
tasks. A Home Office Research Study written the year before
Hungerford had concluded:
shotguns subject to the same controls as pistols ...
would have considerable resource implications for
the police .... Nor is there any real optimism that
anything would be achieved by such a move since
pistols ... are already subject to the very strict
controls and yet ... are used in more cases of armed
crime than shotguns.
As a result of the
1988 law, shotguns that can hold more than two shells at
once now require a Firearms Certificate, the same as
rifles and handguns.
Moreover, all shotguns must now be registered. Shotgun
sales between private parties must be reported to the
police. Buyers of shot shells must produce a shotgun
certificate. Applicants for a shotgun certificate must
obtain a countersignature by a person who has known the
applicant for two years and is "a member of Parliament,
justice of the peace, minister of religion, doctor,
lawyer, established civil servant, bank officer or
person of similar standing."
importantly, the law specified that an applicant for a
Shotgun Certificate, which was required for shotguns capable
of holding only one or two shells, could be denied if the
applicant did not have a "good reason" for wanting to own
shotgun. Although the statute placed the burden on proof on
the police, to show that there was not a good reason, police
practice immediately shifted the burden back to the
applicant to show that she did have a good reason.
Self-defense, of course, was deemed not to be good reason.
Persons who were active members of shooting clubs,
recreational hunters, and farmers engaged in pest control
were all deemed by the police to have demonstrated good
reason, but a person who merely wanted to retain legal
possession of a family heirloom was not considered by the
police to have a good reason.
By the time two cycles of renewals for the Shotgun
Certificates, which were only valid for three years, had
been completed, the number of legal owners of shotguns had
fallen by a quarter. This sharply reversed the steady growth
of gun ownership in the previous two decades.
relatively liberal pre-1988 shotgun system had allowed
significant growth in the number of legal shotgun owners,
the greater police discretion over rifles and pistol
licenses had allowed police to reduce continually the number
of legal owners of rifles or pistols. The 256,000 holders of
Firearms Certificates in 1968 had been cut to 173,000 by
Approximately one-third of the group of Firearms Certificate
holders owned handguns.
important remaining difference between Firearms Certificates
for rifles and pistols and Shotgun Certificates was that
holders of the latter did not need police permission for
every new acquisition. Once a person was granted as Shotgun
Certificate, he could still acquire as many shotguns as he
wanted, although he had to report each acquisition to the
government. In contrast, Firearms Certificate holders have
been required, ever since the original Firearms Act of 1920,
to receive a police-granted "variance" for each new
acquisition. Generally speaking, the police are skeptical
about claims that Firearms Certificate holders have a "good
reason" for wanting additional guns. Consequently, if a
target shooter has one rifle in the .308 caliber, he will
not be allowed to acquire a second rifle in the same
To bring all shotguns under Section one of the Firearms Act,
a step which has not yet been taken, would have huge
implications for shotgun acquisition. A person who legally
owned one 12-gauge shotgun would not be allowed to own more
Secretary Douglas Hurd told an audience that most the
provisions in the 1988 Firearm Act had been prepared long
before Hungerford, and the government had simply been
waiting for the right moment to push them.
cycle was repeated in 1996 when a pederast
named Thomas Hamilton used handguns to murder sixteen
children and a teacher in Dunblane, Scotland. The man
was well known as mentally unstable.
He had been refused membership in several gun
clubs. Citizens had written to the police asking them to
revoke the man's gun license. Under Great Britain's
already restrictive gun laws, the police could easily
have taken away this man's guns. Indeed, the police had
already investigated him seven times, but had done
tabloid press went wild with angry stories about gun-owners,
portraying anyone who would own a gun as sexually inadequate
and mentally ill. The Labour Party immediately called for a
ban on all handguns over .22 calibre, using the same
rationale that had been employed in earlier gun bans: "We
can think of no good reason why a larger calibre handgun
should ever lawfully be held for sporting purposes."
The fact that at least 40,000 Britons engaged in target
shooting with guns over .22 caliber apparently did not
qualify as a "good reason."
Thus, "good reason" continued its metamorphosis. In 1921,
"good reason" had meant "the applicant has no nefarious
purpose." In 1996, "good reason" meant "no reason can be
good enough, if the gun is a handgun."
government, headed by John Major, convened a Dunblane Public
Enquiry. The Enquiry received presentations on firearms
policy from groups and experts on all sides of the gun
issue. The most powerful submission, however, based on what
the report concluded, came from the British Home Office. The
Home Office presented a report citing claims from two
international studies that high gun ownership rates--even
legal, regulated gun ownership--caused high rates of
criminal violence. These claims were seriously flawed; in
Great Britain, within the United States, within Australia,
and within continental Europe, the regions with the highest
rates of legal gun ownership (such as rural England, the
Rocky Mountain states, Queensland, and Switzerland) tend to
have the lowest violence rates.
But the Dunblane Commission, misled by the Home Office, came
back with a report that recommended dozens of ways to
tighten the already-restrictive gun licensing system, and
impose more controls on licensed gun owners.
Office's deception of the Dunblane Enquiry highlights
another condition that may increase slippery slope risks:
the government's ability to produce "data" that "prove" the
need for more government power. Deliberately misleading data
from the government was hardly unique to the Dunblane
Enquiry. In the United States, we have J. Edgar Hoover's
production of false data about interstate car theft to boost
deceptive anti-gun research created by the federal Centers
for Disease Control,
and a breathtaking variety of lies in support of the "War on
to name just a few. Television, of course, can also
be deceptive. In 1993, NBC News was caught red-handed
rigging pickup trucks to explode and burn in order to
support a news program.
Since the term "assault weapon" came into the media
vocabulary, the technique of showing footage of machine guns
firing in fully-automatic mode while the voice-over
discusses other types of firearms has become routine. This
practice continues even after the station acknowledges that
the image is false or the result of outright fakery.
Dunblane Enquiry did recommend many new controls, the
Enquiry did not recommend banning all handguns.
Prime Minister John Major's Conservative government had
decided to accept what it knew would be the Cullen
recommendations, tightening the licensing system still more,
but not banning handguns. However, then Labour Party leaders
brought Dunblane spokesperson Anne Pearston to a rally, and,
in effect, denounced opponents of a handgun ban as
accomplices in the murder of school children. Prime Minister
Major, who was already doing badly in the polls, crumbled.
He promptly announced that the Conservative government would
ban handguns above .22 caliber, and .22 caliber handguns
would have to be stored at shooting clubs, not in homes.
months later, Labour Party leader Tony Blair was swept into
office in a landslide. One of his first acts was to complete
the handgun ban by removing the exemption for .22s.
The Home Office was unable to produce any statistics
regarding the use of .22 pistols in crime.
Prior data showed that the Firearms Certificate system
worked about as well as any human system could to keep
criminals from lawfully acquiring guns, or from stealing
them from lawful owners. A study by the London Metropolitan
Police Inspector of 657 armed robberies in the London area
from January 1988 to June 1991 found that half the robberies
were perpetrated with imitation firearms. Of the remaining
328 real weapons, only one involved a gun which had ever
been within the Firearms Certificate system.
Dunblane was the only British mass murder in this century
with a lawfully registered pistol. But gun ownership in
general, and pistols in particular, had become rare, and
consequently anathematized, once a few generations had
grown up under the regime created by the Firearms Act
of 1920. A two-to-one majority in Parliament found it
commonsense that the crime of one person should lead to the
collective punishment of 57,000 others.
1921, all lawfully-owned handguns in Great Britain are
registered with the government, so handgun owners have
little choice but to surrender their guns in exchange for
payment according to government schedule. Gun registration
has laid a foundation for confiscation not only in Great
Britain, but also in New York City, where the 1967
registration system for long guns was used in the early
1990s to confiscate lawfully owned semiautomatic rifles.
Nevertheless, United States gun control advocates continue
to insist that the United States gun rights advocates are
"paranoid" for resisting registration because it might lead
to confiscation. The gun control advocates reason that they
do not intend to confiscate registered guns. However, the
gun control advocates fail to consider what their successors
might advocate. The British Parliament who created the gun
registration system in 1920 had no intention of banning
handguns. But that 1920 Parliament failed to foresee the
danger that a registration system, even if created with the
best intentions, could later be used for confiscation. Thus,
it is eminently sensible for civil liberties advocates in
the United States to resist registration of persons who
exercise constitutional rights, not because registration is
excessively burdensome in itself, but because registration
amounts to greasing the slippery slope.
The handgun ban by
no means has satiated the anti-gun appetite in Great
Britain. When Scottish handgun owners dutifully
surrendered their handguns many of them applied for
permits to own rifles or antique handguns that remained
legal. The Scottish Home Affairs Minister announced that
he wanted "to send a very powerful message" against
acquisition of alternative "weapons [that] are currently
legal." He announced that the Scottish government would
begin considering whether to tighten controls on
Consequently, while British gun owners gracefully gave
away the right to own guns for protection, they are now
finding their privilege to own guns for sport is under
greater attack than ever. Britain's leading anti-hunting
group, the League Against Cruel Sports, points to the
"hundreds" of people killed by guns and "thousands" of
guns used in robberies and demands a ban on all guns.
The Blair government has announced plans to study
should be brought into the gun licensing system,
and whether the age limit on gun possession
should be raised, which would prevent most teenagers
from using firearms, even under adult supervision. A ban
on all rifles above .22 caliber except for deer hunting
is expected, along with a requirement that shotgun
owners receive government permission each time they
acquire a shotgun, as rifle owners currently must.
A ban on
all real guns will probably not suffice, however. Many
British gun owners now own deactivated "replica" guns that
cannot be fired. The guns are merely decorative pieces, and
are less dangerous than a cricket bat. For some gun owners,
deactivation was the only way they could retain possession
of a prized semiautomatic. Other gun owners simply found the
hassles of the police licensing system too much to overcome,
and had their family heirloom guns deactivated into
non-firing ex-weapons. With deactivation, at least, the
family could retain the gun without need to spend vast sums
on police security requirements. This last "loophole,"
however, in the British gun laws may be closed in a few
years, as the police are now lobbying to require that owners
of deactivated or replica guns get the same license that
would be required for guns which can fire ammunition.
these controls and abusive enforcement of controls actually
made Britain safer? Armed crime in Britain is higher than it
has been in at least two centuries. Armed crime is literally
one hundred times more common than at the turn of the
century when Britain had no weapons controls. Crime
victimization surveys show that, per capita, assault in
England and Wales occurs between two and three times more
often than in the United States. These same surveys
demonstrate that robbery occurs 1.4 times more, and burglary
occurs 1.7 times more.
In contrast to criminologists in the United States, British
criminologists have displayed little interest in studying
whether their nation's gun laws do any good. Accordingly,
definitive statements about cause and effect should be
avoided. One can, however, say that as British gun laws have
grown more severe, the country has grown more dangerous.
- TURN TO PART
 Some Britons favor putting all bows under a
licensing system identical to that for guns. The
crossbow, which has historically associated with
highwaymen, will likely be controlled first, since long
bows, which have been associated with English military
valor at Agincourt and other medieval battles, have a
 In the United States, Handgun Control, Inc.,
has proposed "Brady II" legislation that would make many
American gun-owning homes subject to four unannounced
warrantless inspections per year.
 See Home Office, Gun Clubs: Home
Secretary Plans New Controls (press release), November
 Persons who hold a Firearms Certificate do not
need government permission in order to form a private
club and shoot together at a target range they build,
but government approval is necessary if club members
wish to be able to shoot each others' rifles at the
range, or occasionally to invite guests who do not have
a Firearms Certificate. Cadmus, Abuse of Authority,
36 Guns Rev. 25, 25 (1996).
 See generally, e.g. Pat Kane, We
Have to Be Careful Out There, Sun.
Times, May 22, 1994 ("a fascination with guns
around the darker fringes of the male psyche ... men of
this generation are so fundamentally insecure about
their personal power that guns could seem a ready
option"); Lynne Truss, The Times,
May 24, 1994 ("It's the chaps who fire relentlessly
at targets that it's hard to understand, who seem most
creepy and dangerous."); Dressed to Kill--Just for
Thrills, The Observer, Sept.
 See Martin Killias, Gun Ownership
and Violent Crime: The Swiss Experience, 1 Sec.
J. 171 (1990).
 See Kopel, supra
2, at 89-90 (using gun seizure, gun surrender,
and gun registration data to estimate size of illegal
gun supply and gun ownership in Great Britain).
 See Gallup Poll from 1988, discussed
in R.A.I. Munday, On Liberty (unpublished essay).
 See Memorandum from S.C. Helsley,
Assistant Director, Investigation and Enforcement
Branch, California Department of Justice, to G.W.
Clemons, Director, Division of Law Enforcement,
California Department of Justice 1 (Feb. 13, 1991)
(on file with authors). See generally Bruce H.
Kobayashi & Joseph E. Olson, In Re 101 California
Street: A Legal and Economic Analysis of Strict
Liability for the Manufacture and Sale of "Assault
Weapons," 8 Stan. L. & Pol'y Rev.
 It was not surprising that a murderous
psychopath would choose to dress up like "Rambo," the
machine-gun spraying character popularized by Sylvester
Stallone. Ironically, Stallone, who now lives in Great
Britain, touts gun prohibition and criticizes gun
policies in the United States for being uncivilized.
Perhaps before demanding a government crack down on
law-abiding American gun owners, Mr. Stallone ought to
apologize for his own role in spurring mass murders by
the mentally deranged, including at Hungerford.
 See Malcolm P.I. Weller, The Anatomy
of Violence--Part I, New L.J.
Sept. 11, 1987, at 858.
 See Tony Jackson,
Legitimate Pursuit 48 (1988).
 See Woody Haut, Hysteria, the Free
Market, and the Hungerford Massacre, Rolling
Stock No. 14 (1987), at 15.
 See Jackson,
134, at 92, 99 (quoting Daily Telegraph, Daily
Mirror, Daily Express, Yorkshire Evening Press).
 See Cadmus, Section Five, 33 Guns
Rev. 42 (1993).
 Opponents of the ban had argued for a special
exemption for disabled people, since semiautomatics have
low recoil, and are hence easier to shoot for persons
with less upper body strength. One pro-control Lord
replied that a handicapped person "would probably have a
harder job to hold on to the rifle than an able bodied
person if someone wanted to steal it." Lord Atlee
worried about the possibility of "a disabled person who
was also mentally unstable." House of Lords, Official
Report, Oct. 19, 1988, at cols. 1134, 1131.
 See Capt. Bruce Breckenridge, A
Shooting Sport is Dead, Australian
Gunsports, Summer 1990, at 60.
 Home Office Research Study No. 89 of 1986,
quoted in Jersey Pistol Club News,
Jan.-Mar. 1991, at 5.
Firearms (Amendment) Act, 1988, ch. 16, § 2(1)(2)
 See Sandys-Winch,
98, at 29 (citation omitted). See also
George Wallace, Counter signatory Rears Ugly Head,
Shooting Times & Country Magazine, Oct. 12-18,
1989, at 8. A somewhat weaker countersignature
requirement had already been in force for shotguns.
See Fiddick, supra note
67, at 10. That requirement had been imposed by
the police without statutory authority. A 1984
Police/Home Office working group had found the
countersignature useless, and advised abolition. See
Cadmus, Conspiracy to Disarm, 31 Guns
Rev. 926 (1991).
 See Cadmus, Good Reason Abuse, 29 Guns
Review 862 (1989).
A police decision regarding
good reason will not be overturned by the courts unless
it is arbitrary and capricious. See Hutcgusib
v. Chief Constable of Grampian, 1977 S.L.T. 98 (Sheriff
Home Office guidance states
that the good reason language for shotguns "does NOT
require the applicant to make out a good case for being
granted a certificate but rather extends the chief
officer's ground for refusing one." Firearms
Law--Guidance to Police, ¶ 7.6, quoted in Lorton, supra
43, at 72.
 In 1969, there were 701,562 Shotgun
Certificates. By 1988, the number had risen to 971,102.
By 1994, the number had declined to 740,441.See
Cadmus, The Villains, 35 Guns Rev.
925 (1995) (citing data from the Home Office).
 See id.
 See Cadmus, The Dangerously Ugly,
33 Guns Rev. 926 (1993).
 See Richard Law, Shooters Rights, Guns
& Shooting, Sept. 1993, at 54 (discussing
Hurd's speech to students at St. Edwards, Oxford).
 SeeCullen, supra
99, at ch. 5-6.
 See Saray Lyall, Scottish School
Killer Had Stormy Past, N.Y. Times,
Mar. 15, 1996, at A6.
 George Robertson & Jack Straw, Control of
Guns: The Labour Party's Evidence to the Cullen Inquiry
(May 1996), available at <http://www.cybersurf.co.uk/~johnny/dunblane/labour.html>.
 See Office of Legislative Affairs,
Lord Cullen's Inquiry into the Circumstances Leading up
to and Surrounding Events at Dunblane Primary School on
Wednesday, 13 March 1996, at 11.
 See R.A.I. Munday, Does the Level of
Firearms Ownership Affect Levels of Violence? (Submitted
to the Dunblane Enquiry 1996); Peter H. Jackson
et al., Was the Dunblane Inquiry Misled? (Nov. 9, 1996),
 See David Barnham,
Above the Law 86-87 (1996).
 See, e.g., Don B. Kates et al,
Guns and Public Health: Epidemic of Violence or Pandemic
of Propaganda? 62 Tenn. L. Rev.
 See, e.g., Lynn Simner &
John P. Morgan, Marijuana Myths, Marijuana Facts: A
Review of the Scientific Evidence (1997).
 See Brian Dylan, After the Blowup, U.S.A.
Today, Feb. 11, 1993, at 1.
 See Scott Baltic, Bang Bang! You're
Wrong!, Colum. Journalism Rev.,
Feb. 1994, at 11 (criticizing the media for gross
inaccuracy in the assault weapon debate). See also
Wound Ballistics Expert Exposes Media AK Fakery, Gun
Week, May 5, 1989, at 1 (describing phony
footage of AK-47 assault rifles staged for television
news program); Joseph Tartaro,
Great Assault Weapons Hoax, 20 U.
Dayton L. Rev. 619 (1995).
 See The Hon. Lord
Cullen, The Public Inquiry into the Shootings at
Dunblane Primary School, Mar. 1996, at 13 <http://www.official-documents.co.uk/document/scottish/dunblane/dunblane.htm>.
 See Norman Cooper, Time to Remove
the Gloves, 37 Guns Rev. 56
(1997) (Sir Patrick Lawrence, former Chair of the
Conservative Party, told Cooper that the Anne Pearston
rally caused Major's switch). The ban was implemented by
Firearms (Amendment) Act 1997, 1997, ch. 5 (Eng.).
Firearms (Amendment) (no. 2) Act, 1997, ch. 64
(Eng.). Labour's original proposal to the Cullen
Inquiry was that single-shot .22s, which need to be
reloaded after each shot, should remain legal, but the
Party's aggressive use of focus groups and polling had
apparently convinced Blair to go further.
 See Dominic Grieve,
Hansard, June 11, 1997, at pt. 43, col. 1232.
 See Hawkins,
Hansard, June 11, 1997, at pt. 39, col. 1212.
 But see
Lamont v. Postmaster General, 381 U.S. 301 (1965)
(holding that postal regulations requiring those who
receive "foreign Communist propaganda" by mail to
complete a short registration form is an excessive
burden on the exercise of First Amendment rights).
 James Rougrie, Shotguns Review on Cards,
Says McLeish, The Scotsman,
Nov. 4, 1997, at 6, quoted at <http://www.cybersurf.co.uk/~johnny/dunblane/scot4nov.html>.
Tony Jackson, Legitimate
Pursuit: The Case for the Sporting Gun 94 (1988).
 Airguns are powered by compressed air, rather
than by gunpowder and they fire a small pellet or a BB.
 See Jason Bennetto, Purge on Rifles
and Shotguns, The Independent,
July 17, 1997, at 1.
 See Patrick A. Langan &
David P. Farrington,
Crime and Justice in the United States and in England
and Wales, 1981-96 (1998)