Hours after 50 worshippers were killed at two mosques in Christchurch, New Zealand, Prime Minister Jacinda Ardern was already promising to tighten up the country’s gun laws. It’s a stark contrast to Donald Trump’s reaction to mass shootings, a written-by-numbers offer of “thoughts and prayers”, then a twiddle of his thumbs until the next atrocity. New Zealand’s response seems to have more in common with Scotland where the massacre at Dunblane primary school in 1996 led to a ban on all handguns.

There are some pronounced differences between the two countries. New Zealand’s gun laws are lax; the UK’s gun laws had already been tightened and semi-automatic centrefire rifles banned in the wake of the Hungerford massacre in 1987. But what Scotland and New Zealand share is little previous experience of spree shootings, a visceral shock at the scale of their country’s loss and a determination to prevent it happening again.

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After it emerged that Thomas Hamilton had killed 16 young children and their teacher with legally owned handguns in Dunblane, there was huge public demand for action to be taken. With the country grieving, it wasn’t difficult for the Snowdrop campaign to drum up willing signatories to its petition calling for a handgun ban; by the time it was handed to parliament, more than 750,000 people had added their names. Dunblane’s political connections were also powerful. The town was in the constituency of the then secretary of state for Scotland, Michael Forsyth (who had a majority of only 703), and home to the shadow secretary of state for Scotland, George Robertson, who had previous dealings with Hamilton.

Despite all this, instituting a handgun ban was not straightforward; there were many in the gun lobby who opposed it with arguments not dissimilar to those made by America’s National Rifle Association (NRA). Some Tory backbenchers were reluctant to take this on and a decision was postponed until the Cullen inquiry report was published. In the meantime, however, the Labour party came up with a publicity coup: they invited Ann Pearston – the Conservative-voting co-founder of the Snowdrop campaign – to speak at their party conference. With delegates reduced to tears, the pressure was irresistible.

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In the end, John Major’s government brought in the Firearms (Amendment) Act 1997, which banned higher-calibre handguns. When Labour swept into power later that year, Tony Blair’s government extended the law to include .22 calibre handguns.

Ardern’s cabinet has said it will push for a ban on all semi-automatic weapons. But in a country with a strong hunting tradition, her government is likely to face similar opposition. Three previous attempts to tighten up the firearms laws – in 2005, 2012 and 2017 – failed due to the efforts of the gun lobby. There will also be logistical obstacles: for example, in the UK, legally owned handguns were registered so the police knew how many there were and where to find them. In New Zealand, once an individual has been granted a gun licence they can buy most types of guns without registering them, which means the police don’t know exactly how many are owned and by whom.

Facebook Twitter Pinterest A memorial near the Masjid Al Noor mosque for victims of the shooting in Christchurch on 15 March. Photograph: Vincent Yu/AP

Despite these reservations, the signs so far are positive. On Monday, it emerged some gun owners had already handed in their weapons. Retail group Hunting & Fishing New Zealand also pulled “military-style” semi-automatic firearms from sale and the country’s largest auction website, Trade Me, announced it was removing all listings for semi-automatic guns and parts from its website. Deputy Prime Minister Winston Peters, whose NZ First party had previously opposed recommendations to restrict gun laws, intimated a willingness to compromise. “Our world changed forever and so will some of our laws,” he said.

It is almost impossible to imagine this happening in the US. After 20 children and six staff members were murdered at Sandy Hook in 2012, the then US president Barack Obama wept and promised a ban on assault weapons, but, blocked by Congress, he managed only a handful of smaller changes such as limiting magazine size. The US’s intractability is partly cultural: the right to bear arms is enshrined both in the US constitution and its psyche. It is partly logistical: with an estimated 101 guns for every 100 citizens, how could legislators begin to make an impact? But it is mostly financial: the NRA is such a potent organisation because it donates large sums of money to the Republican party.

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In the past, the US has used New Zealand to demonstrate that lax gun laws do not necessarily lead to gun deaths. Though gun ownership in New Zealand is high (there are at least 1.5m legally owned weapons), the gun-related homicide rate is relatively low. Ipso facto, “guns don’t kill people, people kill people”, as the NRA would put it. Now that argument has evaporated and New Zealand post-Christchurch, like the UK post-Dunblane, is showing how a country invested in the safety of its citizens ought to respond.

Though the British ban on handguns did not stop another shooting spree taking place in Cumbria in 2010, it did result in a “slight, but significant” drop in gun crime and sent out a message about the kind of country we wanted to be: a country different from the US where the best solution the current president can come up with is to arm more civilians.

As for the tweets pledging “thoughts and prayers”, they’re an insult to the dead. If the Republican party really cared, it would follow the example set by the UK and (it seems likely) New Zealand; it would get off its knees and tell the NRA it is no longer in thrall to its millions of dollars.

• Dani Garavelli is a freelance journalist and columnist for Scotland on Sunday