on the switch theyre are efuses to prevent downgrade but it may be possible to use a hardmod to downgrade as on specific firmwares the same number of efuses are activated like on 2.0 - 2.3 this info is taken from the switch brew wikik
http://switchbrew.org/index.php?title=Fuse_registers#Anti-downgrade
http://switchbrew.org/index.php?title=Fuse_registers#Anti-downgrade