The Toronto Revolver Club (TRC), the last shooting range in Toronto, has successfully challenged the authority of Ontario’s chief firearms officer (CFO) in a recent court ruling. The case was brought to Ontario’s Superior Court of Justice following a 2024 inspection by the CFO, who imposed conditions on the club’s shooting range approval.

During the inspection, the CFO mandated the closure of two of the TRC’s ten firing lanes, citing safety concerns. However, Justice Shaun Nakatsuru ruled that the CFO does not have the authority to impose such conditions on shooting range approvals. This decision was issued on August 25.

The court noted that under the Canada Firearms Act, the CFO can revoke the TRC’s approval entirely, which would effectively shut down the shooting range. However, the CFO lacks the power to attach conditions to the approval. The CFO argued that the law implied a need for conditions to ensure public safety, stating that it was "practically necessary to achieve" the act's purpose.

The CFO's legal team contended that courts should not overly restrict regulatory authorities. They argued that the ability to impose conditions should be inferred to fulfill the regulatory objectives. However, Justice Nakatsuru disagreed, referencing a precedent from New Brunswick’s Springfield Sports Club Inc. case, where the court found that the CFO had no authority to impose conditions on shooting range approvals.

Justice Nakatsuru emphasized that the Firearms Act does not grant the CFO the power to attach conditions, stating, "The CFO’s jurisdiction is limited to ensuring the key information in the application is accurate and that the shooting range complies with the regulation."

The judge acknowledged that while the CFO has limited authority, he can revoke the entire shooting range approval if safety concerns are not addressed. This interpretation, according to Nakatsuru, protects public safety while allowing the shooting range to operate.

Both parties in the case agreed that there is no explicit provision in the law allowing the CFO to impose conditions. The judge pointed out that the Firearms Act specifically limits the CFO’s authority regarding shooting range approvals.

In his ruling, Nakatsuru warned against allowing conditional approvals, stating that it could lead to arbitrary decisions by the CFO. He noted that such discretion could result in conditions that are only loosely related to the act's objectives.

The judge ordered the CFO to cover the TRC’s legal costs, amounting to $7,500. TRC President Graham Brown declined to comment on the case, citing the possibility of an appeal. The CFO's office did not respond to requests for comment.

Founded in 1905, the Toronto Revolver Club claims to be the oldest handgun club in Canada. It has operated its current range for over 70 years and has hosted thousands of members, including competitive athletes.