Section 28 of the Arms Act, 1959: Use of Firearm or Imitation Firearm to Resist Lawful Arrest

Section 28 of the Arms Act, 1959 creates a specific offence where a person uses or attempts to use a firearm or an imitation firearm with the intention of resisting or preventing the lawful arrest or detention of himself or another person. The punishment may extend to seven years of imprisonment and fine.

Key point: Section 28 is concerned with the purpose for which the firearm or imitation firearm is used or attempted to be used. The prosecution must establish the required intent to resist or prevent a lawful arrest or detention.

Section 28: Punishment for use and possession of firearms or imitation firearms in certain cases

Whoever makes or attempts to make any use whatsoever of a firearm or an imitation firearm with intent to resist or prevent the lawful arrest or detention of himself or any other person is punishable with imprisonment for a term which may extend to seven years and with fine.

Explanation: For Section 28, the expression "imitation firearm" has the same meaning as in Section 6 of the Arms Act, 1959.

Essential ingredients of an offence under Section 28

For Section 28 to apply, the alleged conduct must involve a firearm or an imitation firearm, and there must be use or attempted use of that object. The provision is not limited to an actual discharge of a firearm because it expressly covers an attempt to make any use whatsoever.

The required mental element is also specific. The use or attempted use must be accompanied by an intention to resist or prevent an arrest or detention. Further, the arrest or detention being resisted or prevented must be lawful.

A mere possession allegation does not, by itself, reproduce every ingredient stated in Section 28. The statutory language focuses on use or attempted use together with the specified intention connected to lawful arrest or detention.

What is an "imitation firearm"?

Section 28 adopts the definition contained in Section 6. Under that explanation, an imitation firearm means anything which has the appearance of being a firearm, whether it is capable of discharging any shot, bullet or other missile or not.

Accordingly, for purposes of Section 28, an object may fall within the statutory expression even though it is not capable of actually firing a projectile, provided it has the appearance of a firearm.

How Section 6 is connected with Section 28

Section 6 deals with a licence for shortening the barrel of a firearm or converting an imitation firearm into a firearm. Its explanation supplies the meaning of "imitation firearm" used by Section 28.

The definition is therefore important when determining whether an object that merely resembles a firearm can still fall within Section 28.

1983 amendment to the punishment

The punishment wording in Section 28 was amended by the Arms (Amendment) Act, 1983. The earlier phrase permitting imprisonment, fine, or both was replaced so that the section now provides imprisonment for a term which may extend to seven years and fine.

The substitution took effect on 22 June 1983.

Official legal sources

The consolidated Arms Act, 1959 is available through the India Code Arms Act, 1959 page. An official copy is also available from the Ministry of Home Affairs.

This article is intended as a legal information resource. In an individual criminal case, the applicable charge, ingredients, evidence, defences, procedural provisions and punishment depend on the facts and the law applicable on the date of the alleged offence.