Reddendo Singula Singulis

The reddendo singula singulis principle concerns the use of words distributively. Where a
complex sentence has more than one subject, and more than one object, it may be the right
construction to render each to each, by reading the provision distributively and applying each
object to its appropriate subject. A similar principle applies to verbs and their subjects, and to
other parts of speech. A typical application of this principle is where a testator says 'I devise and
bequeath all my real and personal property to B'. The term devise is appropriate only to real
property. The term bequeath is appropriate only to personal property. Accordingly, by the
application of the principle reddendo singula singulis, the testamentary disposition is read as if it
were worded 'I devise all my real property, and bequeath all my personal property, to B'.
This rule has been applied in the case of Koteshwar Vittal Kamat vs K Rangappa Baliga, AIR
1969, in the construction of the Proviso to Article 304 of the Constitution which reads, "Provided
that no bill or amendment for the purpose of clause (b), shall be introduced or moved in the
legislature of a state without the previous sanction of the President". It was held that the word
introduced applies to bill and moved applies to amendment.

A variation of the doctrine of last antecedent is the rule of reddendo singula singulis. The maxim
means referring each to each; referring each phrase or expression to its appropriate object, or let
each be put in its proper place, that is, the words should be taken distributively. (People v.
Tamani) As a rule of statutory construction, reddendo singula singulis requires that the
antecedents and consequences should be read distributively to the effect that each word is to be
applied to the subject to which it appears by context most appropriately related and to which it is
most applicable.
People v. Tamani illustrates the application of reddendo singula singulis. One of the questions
raised in this case is when to count the 15-day period within which to appeal a judgment of
conviction in a criminal action whether from the date of promulgation of judgment or from the
date of receipt of the notice of judgment. Section 6, Rule 122 of the Rules of Court provides that
an appeal must be taken within 15 days from promulgation or notice of the judgment or order
appealed from. In holding that the 15-day period should be counted from the promulgation and

not from receipt of copy of the judgment, the court said: The word 'promulgation' in section 6
should be construed as referring to 'judgment;' while the word 'notice' should be construed as
referring to 'order.' That construction is sanctioned by the rule of reddendo singula singulis. In
another case, which involves the question as to whether a Chinese holding a non-control position
in a retail establishment, which is a wholly nationalized business, comes within the prohibition
against aliens intervening in the management, operation, administration or control thereof,
whether as an officer, employee or laborer therein, the court ruled that the words management,
operation, administration or control, followed by the phrase whether as an officer, employee or
laborer therein signify, following the rule of reddendo singula singulis, that the entire scope of
personel activity, including that of laborers, is covered by the prohibition against the employment
of aliens. It added that by reading the words management, operation, administration or control,
in connection with the positions therein enumerated, one cannot draw any other conclusion.
Reddendo Singula Singulis and Doctrine of Last Antecedent
These two maxims, or doctrines, are taken together because they share a common essential
notion. The notion is that in situations where the text reveals multiple possible antecedents for a
word or phrase (an antecedent is a noun or substantive to which the word or phrase could be
connected), that word or phrase should be applied to the antecedents to which it is most properly
related by virtue of the rules of grammar, the text, and the context. That is, the term in question
should be related back either to each proper antecedent (reddendo singula singulis- refer each to
each, one at a time). Or to its most proximate subject (last antecedent). Reddendo and last
antecedent are often used together in the decoding of texts that are inartfully drafted (e.g., flawed
by confused or vague structure, sloppy syntax, poor punctuation, or goofy grammar).
Reddendo says that you should seek a determination of meaning by referring each word or
phrase to its most appropriate object (that antecedent to which it is most reasonably connected).
Last antecedent says that a qualifying word or phrase should be applied to the word or phrase
immediately preceding it, and not extended to other, more remote antecedents. These two
maxims may seem at odds.
A statute typically contains certain kinds of provisions (e.g., title, preamble, definitions,
exemptions), some or all of which may disclose the intention of the legislature and the meaning

of the portion in dispute. Often, the definitions stated in the statute are critical to the analysis and
provide the key to the decision of meaning (however, the definitions themselves may be unclear)
The most common analytical tools for extracting meaning from a text are known by their Latin
names:
Noscitur a sociis- the meaning of a word may be known from its associated words.
The rule of noscitur a sociis states that words of a statute are to be construed in the light of their
context. It may be translated as "a thing is known by its associates". The Latin maxim Noscitur a
sociis contemplates that a statutory term is recognised by its associated words. The Latin word
sociis means society. Therefore, when general words are juxtaposed with specific words,
general words cannot be read in isolation. Their colour and their contents are to be derived from
their context.
In the English case of Bourne v Norwich Crematorium Ltd, Stamp J explained the rule as
follows:
"English words derive colour from those which surround them. Sentences are not mere
collections of words to be taken out of the sentence, defined separately by reference to the
dictionary or decided cases, and then put back again into the sentence with the meaning which
you have assigned to them as separate words, so as to give the sentence or phrase and meaning
which as a sentence or phrase it cannot bear without distortion of the English language."

Ejusdem generis- where specified things are listed and followed by general words suggesting a
class of things, the general words cover only things of like kind.
The Supreme Court in Maharashtra University of Health and others v. Satchikitsa Prasarak
Mandal & Others has examined and explained the meaning of 'Ejusdem Generis' as a rule of
interpretation of statutes in our legal system.
While examining the doctrine, the Supreme Court held as under;
The Latin expression ejusdem generis which means of the same kind or nature is a principle
of construction, meaning thereby when general words in a statutory text are flanked by restricted

words, the meaning of the general words are taken to be restricted by implication with the
meaning of restricted words. This is a principle which arises from the linguistic implication by
which words having literally a wide meaning (when taken in isolation) are treated as reduced in
scope by the verbal context. It may be regarded as an instance of ellipsis, or reliance on
implication. This principle is presumed to apply unless there is some contrary indication.

Expressio unius est exclusio alterius- where only a specific thing is expressed (no general or
class words), other things are excluded (even if of like kind).
The rule of expressio unius est exclusio alterius translates to the expression of one thing is to the
exclusion of another. Though the rule is more often cited in cases of statutory interpretation, it
applies to contract actions as well. The rule may be used to decide whether a contract that
contains a list of specific terms should be read to encompass anything broader than that
specifically listed.

Reddendo singula singulis- where the word at issue could be related to more than one possible
antecedent, the word should be connected to that antecedent which it is most properly related by
the rules of grammar, or to the antecedent closest to it in the text.
When common, technical, legal or trade words are used in a statute, the general rule is that they
will be given their common, technical, legal or trade meaning. These principles aren't substantive
law, but are guides, aids or tools used to clarify the meaning of words in a particular factual
situation. Each has its limitations, and none will be allowed to prevail over a clear expression of
contrary legislative intent.

The rule may be stated from an Irish case in the following words: where there are general words
of description, following an enumeration of particular things such general words are to be
construed distributively, reddendo singula singulis; and if the general words will apply to some
things and not to others, the general words are to be applied to those things to which they will,
and not to those to which they will not apply; that rule is beyond all controversy. Thus, in the

sentence: 'If any one shall draw or load any sword or gun' the word 'draw' is applied to 'sword'
only and the word 'load' to 'gun' only, because it is impossible to load a sword or draw a gun.
An example of the application of the rule is furnished in the construction of section 59(1) of the
Local Government Act, 1933 which reads: 'A person shall be disqualified for being elected or
being a member of a local authority if he has within five years before the day of election or since
his election been convicted of any offence and ordered to be imprisoned for a period of not less
than three months without the option of fine' in the case of Bishop v. Deakin. The section
provides for two disqualifications: first, conviction within five years before the day of election;
and secondly, conviction since election. It is obvious that the second disqualification mentioned
does not fit the second case, and the second case only. It is also obvious that the first
disqualification mentioned fits the first case, and it does not seem at all apt to fit the second case.
It was, therefore held that a conviction prior to election although a disqualification for the
election was not a disqualification for continuing to be a member and if the election was not
challenged by election petition within the time limited therefor, the member did not vacate his
seat.

According to the principles contained in the maxim, for correct interpretation of statutes
arrangements of words also should be taken into account. When the arrangement of words is
clear and unambiguous there is no necessity to look into interpretation. The words in part of a
statutory provision or other statutes are to be respectively applied to their appropriate objects in
another part. The words should be read distributively. Where the words 'respectively'; or 'as
aplicable' or 'as the case may be' are used in a statute then this rule will be applicable.
Lord Crawford points out that if statutes are read without brakes and stops they would not be
clear. The words belonging to any particular branch of a sentence must be collected from the
context and read distributively according to the principle 'reddendo singula singulis'.
In Nagpur Electric Co. V. Sreepathi Rao, it was held that the words 'whose names and ticket
numbers are included in the departmental muster in the standing orders should be read as a
whose names and ticket numbers if any, are included in the departmental muster based on the
principle of 'reddendo singula singulis'.

Words of Rank
When words descriptive of persons or things are used in an order descending by rank, general
words at the end of the list do not include (although, standing alone, they would) persons or
things of a higher rank than the highest named, if there be any lower species to which they can
apply. In such a case, the general word is not taken as generic, but as including only what is
lower in the genus than the lowest specified.
Thus section 3 of the Disabling Statute, which avoided conveyances by masters and fellows of
colleges, deans and chapters of cathedrals, parsons, vicars, and others having any spiritual or
ecclesiastical living was held not to include bishops.
The imposition of duties under the general head of metals, upon copper, brass, pewter, and
tin, and on all other metals not enumerated would not include the precious metals of gold and
silver.
The statute of Westminster II, which prohibited salmon-fishing from Lady-day to St. Martin's, in
the waters of the Humber, Ouse, Trent... and all other waters wherein salmons be taken was
considered as including, in the final general expression, only rivers inferior to those enumerated,
and therefore as not comprising the Thames. It does not appear whether the rivers specified were
named in order of descending importance.
And a statute which punished cruelty to any horse, mare, gelding, mule, ass, ox, cow, heifer,
steer, sheep, or other cattle was held not to include a bull.
When words descriptive of the rank of persons or things are used in a descending order
according to rank, the general words superadded to them do not include (though standing alone
they would do so) persons or things of a higher rank or importance than the highest named, if
there be any lower species to which they can apply. In such a case, the general word is taken not
as generic, but as including only what is lower in the genus than the lowest specified.
The Game Act, 1670 which empowered the lords of manors and other royalties to grant a
deputation to a game-keeper, was limited to the lords of such royalties as are inferior to manors,
for if a royalty of a higher nature had been meant, it would have preceded the term manor.