MODULE - II: PRINCIPLES OF INTERPRETATION

At the outset, it must be clarified that, it is only when the intention of the legislature as
expressed in the statute is not clear, that the Court in interpreting it will have any need for
the rules of interpretation of statutes. It may also be pointed out here that since our legal
system is, by and large, modelled on Common Law system, our rules of interpretation are
also same as that of the system. It is further to be noted, that the so called rules of
interpretation are really guidelines.

(i) Primary Rules

(a) The Primary Rule : Literal Construction

According to this rule, the words, phrases and sentences of a statute are ordinarily to be
understood in their natural, ordinary or popular and grammatical meaning unless such a
construction leads to an absurdity or the content or object of the statute suggests a different
meaning. The objectives ‘natural’, ‘ordinary’ and ‘popular’ are used interchangeably.

Interpretation should not be given which would make other provisions redundant ​(Nand
Prakash Vohra v. State of H.P., AIR 2000 HP 65).

If there is nothing to modify, alter or qualify the language which the statute contains, it must
be construed according to the ordinary and natural meaning of the words. “The safer and
more correct course of dealing with a question of construction is to take the words
themselves and arrive, if possible, at their meaning without, in the first instance, reference
to cases.”

“Whenever you have to construe a statute or document you do not construe it according to
the mere ordinary general meaning of the words, but according to the ordinary meaning of
the words as applied to the subject matter with regard to which they are used”. ​(Brett M.R.)

It is trite that construction of a statute should be done in a manner which would give effect to
all its provisions ​[Sarbajit Rick Singh v. Union of India, (2008) 2 SCC 417].

It is a corollary to the general rule of literal construction that nothing is to be added to or

taken from a statute unless there are adequate grounds to justify the inference that the
legislature intended something which it omitted to express.

A construction which would leave without effect any part of the language of a statute will
normally be rejected. Thus, where an Act plainly gave an appeal from one quarter sessions
of another, it was observed that such a provision, though extraordinary and perhaps an
oversight, could not be eliminated.

Similarly, the main part of the section must not be construed in such a way as to render a
proviso to the section redundant.
Some of the other basic principles of literal construction are:

(i) Every word in the law should be given meaning as no word is unnecessarily used.

(ii) One should not presume any omissions and if a word is not there in the Statute, it shall
not be given any meaning.

(b) The Mischief Rule or Heydon’s Rule

In ​Heydon’s Case, in 1584​, it was resolved by the Barons of the Exchequer “that for the
sure and true interpretation of all statutes in general (be they penal or beneficial, restrictive
or enlarging of the Common Law) four things are to be discerned and considered: (1) What
was the Common Law before the making of the Act; (2) What was the mischief and defect
for which the Common Law did not provide; (3) What remedy the parliament had resolved
and appointed to cure the disease of the Commonwealth; and (4) The true reason of the
remedy.

Although judges are unlikely to propound formally in their judgements the four questions in
Heydon’s Case, consideration of the “mischief” or “object” of the enactment is common and
will often provide the solution to a problem of interpretation. Therefore, when the material
words are capable of bearing two or more constructions, the most firmly established rule for
construction of such words is the rule laid down in Heydon’s case which has “now attained
the status of a classic”. The rule directs that the Courts must adopt that construction which
“shall suppress the mischief and advance the remedy”. But this does not mean that a
construction should be adopted which ignores the plain natural meaning of the words or
disregard the context and the collection in which they occur. (See ​Umed Singh v. Raj
Singh, A.I.R. 1975 S.C. 43)

The Supreme Court in ​Sodra Devi’s case, AIR 1957 S.C. 832​ has expressed the view that
the rule in Heydon’s case is applicable only when the words in question are ambiguous and
are reasonably capable of more than one meaning.

The correct principle is that after the words have been construed in their context and it is
found that the language is capable of bearing only one construction, the rule in Heydon’s
case ceases to be controlling and gives way to the plain meaning rule.

(c) Rule of Reasonable Construction i.e. Ut Res Magis Valeat Quam Pareat

Normally, the words used in a statute have to be construed in their ordinary meaning, but in
many cases, judicial approach finds that the simple device of adopting the ordinary meaning
of words, does not meet the ends as a fair and a reasonable construction. Exclusive
reliance on the bare dictionary meaning of words’ may not necessarily assist a proper
construction of the statutory provision in which the words occur. Often enough interpreting
the provision, it becomes necessary to have regard to the subject matter of the statute and
the object which it is intended to achieve.

According to this rule, the words of a statute must be construed ut res magis valeat quam
pareat, so as to give a sensible meaning to them. A provision of law cannot be so
interpreted as to divorce it entirely from common sense; every word or expression used in
an Act should receive a natural and fair meaning.

It is the duty of a Court in constructing a statute to give effect to the intention of the
legislature. If, therefore, giving of literal meaning to a word used by the draftsman
particularly in penal statute would defeat the object of the legislature, which is to suppress a
mischief, the Court can depart from the dictionary meaning which will advance the remedy
and suppress the mischief.

It is only when the language of a statute, in its ordinary meaning and grammatical
construction, leads to a manifest contradiction of the apparent purpose of the enactment, or
to some inconvenience or absurdity, hardship of injustice, presumably not intended, a
construction may be put upon it which modifies the meaning of the words and even the
structure of the sentence ​(Tirath Singh v. Bachittar Singh, A.I.R. 1955 S.C. 830).

Courts can depart from dictionary meaning of a word and give it a meaning which will
advance the remedy and suppress the mischief provided the Court does not have to
conjecture or surmise. A construction will be adopted in accordance with the policy and
object of the statute ​(Kanwar Singh v. Delhi Administration, AIR 1965 S.C. 871).​ To
make the discovered intention fit the words used in the statute, actual expression used in it
may be modified ​(Newman Manufacturing Co. Ltd. v. Marrables, (1931) 2 KB 297,
Williams v. Ellis, 1880 49 L.J.M.C.).​ If the Court considers that the litera legis is not clear,
it, must interpret according to the purpose, policy or spirit of the statute (ratio-legis). It is,
thus, evident that no invariable rule can be established for literal interpretation.

In ​RBI v. Peerless General Finance and Investment Co. Ltd. (1987) 1 SCC 424.​ the
Supreme Court stated. If a statute is looked at in the context of its enactment, with the
glasses of the statute makers provided by such context, its scheme, the sections, clauses,
phrases and words may take colour and appear different than when the statute is looked at
without the glasses provided by the context. With these glasses we must look at the Act as
a whole and discover what each section, each clauses each phrase and each word is
meant and designed to say as to fit into the scheme of the entire Act.(See also ​Chairman
Indira Vikas Pradhikaran v. Pure Industrial Coke and Chemicals Ltd., AIR 2007 SC
2458).

(d) Rule of Harmonious Construction

A statute must be read as a whole and one provision of the Act should be construed with
reference to other provisions in the same Act so as to make a consistent enactment of the
whole statute. Such a construction has the merit of avoiding any inconsistency or
repugnancy either within a section or between a section and other parts of the statute. It is
the duty of the Courts to avoid “a head on clash” between two sections of the same Act and,
“whenever it is possible to do so, to construct provisions which appear to conflict so that
they harmonise”​ (Raj Krishna v. Pinod Kanungo, A.I.R. 1954 S.C. 202 at 203).

Where in an enactment, there are two provisions which cannot be reconciled with each
other, they should be so interpreted that, if possible, effect may be given to both. This is
what is known as the “rule of harmonius construction”.

The Supreme Court applied this rule in resolving a conflict between Articles 25(2)(b) and
26(b) of the Constitution and it was held that the right of every religious denomination or any
section thereof to manage its own affairs in matters of religion [Article 26(b)] is subject to a
law made by a State providing for social welfare and reform or throwing open of Hindu
religious institutions of a public character to all classes and sections of Hindus [Article
25(2)(b)]. See ​Venkataramana Devaru v. State of Mysore, A.I.R. 1958 S.C. 255.

(e) Rule of Ejusdem Generis

Ejusdem Generis, literally means “of the same kind or species”. The rule can be stated thus:

(a) In an enumeration of different subjects in an Act, general words following specific words
may be construed with reference to the antecedent matters, and the construction may be
narrowed down by treating them as applying to things of the same kind as those previously
mentioned, unless of course, there is something to show that a wide sense was intended;
(b) If the particular words exhaust the whole genus, then the general words are construed
as embracing a larger genus.

In other words, the ejusdem generis rule is that, where there are general words following
particular and specific words, the general words following particular and specific words must
be confined to things of the same kind as those specified, unless there is a clear
manifestation of a contrary purpose. It is merely a rule of construction to aid the Courts to
find out the true intention of the Legislature ​(Jage Ram v. State of Haryana, A.I.R. 1971
S.C. 1033).​ To apply the rule the following conditions must exist:

(1) The statute contains an enumeration by specific words,

(2) The members of the enumeration constitute a class,

(3) The class is not exhausted by the enumeration,

(4) A general term follows the enumeration,

(5) There is a distinct genus which comprises more than one species, and
(6) There is no clearly manifested intent that the general term be given a broader meaning
that the doctrine requires. ​(See Thakura Singh v. Revenue Minister, AIR 1965 J & K 102)

The rule of ejusdem generis must be applied with great caution because, it implies a
departure from the natural meaning of words, in order to give them a meaning or supposed
intention of the legislature. The rule must be controlled by the fundamental rule that statutes
must be construed so as to carry out the object sought to be accomplished. The rule
requires that specific words are all of one genus, in which case, the general words may be
presumed to be restricted to that genus.

Whether the rule of ejusdem generis should be applied or not to a particular provision
depends upon the purpose and object of the provision which is intended to be achieved.

(ii) Other Rules of Interpretation

(a) Expressio Unis Est Exclusio Alterius

The rule means that express mention of one thing implies the exclusion of another.

At the same time, general words in a statute must receive a general construction, unless
there is in the statute some ground for limiting and restraining their meaning by reasonable
construction; because many things are put into a statute ex abundanti cautela, and it is not
to be assumed that anything not specifically included is for that reason alone excluded from
the protection of the statute. The method of construction according to this maxim must be
carefully watched. The failure to make the ‘expressio’ complete may arise from accident.
Similarly, the ‘exclusio’ is often the result of inadvertence or accident because it never
struck the draftsman that the thing supposed to be excluded requires specific mention. The
maxim ought not to be applied when its application leads to inconsistency or injustice.

Similarly, it cannot be applied when the language of the Statute is plain with clear meaning
(Parbhani Transport Co-operative Society ltd v Regional Transport Authority, AIR
1960 SC 801)

(b) Contemporanea Expositio Est Optima Et Fortissima in Lege

The maxim means that the best way to give the meaning to a document or proposition of a
law is to read it as it would have read when it was made.Where the words used in a statute
have undergone alteration in meaning in course of time, the words will be construed to bear
the same meaning as they had when the statute was passed on the principle expressed in
the maxim. In simple words, old statutes should be interpreted as they would have been at
the date when they were passed and prior usage and interpretation by those who have an
interest or duty in enforcing the Act, and the legal profession of the time, are presumptive
evidence of their meaning when the meaning is doubtful.
But if the statute appears to be capable of only interpretation, the fact that a wrong meaning
had been attached to it for many years, will be immaterial and the correct meaning will be
given by the Courts except when title to property may be affected or when every day
transactions have been entered into on such wrong interpretation.

(c) Noscitur a Sociis

The ‘Noscitur a Sociis’ i.e. “It is known by its associates”. In other words, meaning of a word
should be known from its accompanying or associating words. It is not a sound principle in
interpretation of statutes, to lay emphasis on one word disjuncted from its preceding and
succeeding words. A word in a statutory provision is to be read in collocation with its
companion words. The pristine principle based on the maxim ‘noscitur a socitis’ has much
relevance in understanding the import of words in a statutory provision ​(K. Bhagirathi G.
Shenoy v. K.P. Ballakuraya, AIR 1999 SC 2143).

The rule states that where two or more words which are susceptible of analogous meaning
are coupled together, they are understood in their cognate sense. It is only where the
intention of the legislature in associating wider words with words of narrower significance, is
doubtful that the present rule of construction can be usefully applied.

The same words bear the same meaning in the same statute. It is a matter of common
sense that a particular word should be attributed with same meaning throughout a Statute.
But this rule will not apply:

(i) when the context excluded that principle.

(ii) if sufficient reason can be assigned, it is proper to construe a word in one part of an Act
in a different sense from that which it bears in another part of the Act.

(iii) where it would cause injustice or absurdity.

(iv) where different circumstances are being dealt with.

(v) where the words are used in a different context. Many do not distinguish between the
rule and the ejusdem generis doctrine. But there is a subtle distinction as pointed out in the
case of ​State of Bombay v. Hospital Mazdoor Sabha, (1960) 2 SCR 866.

(d) Strict and Liberal Construction

In Wiberforce on Statute Law, it is said that what is meant by ‘strict construction’ is that
“Acts, are not to be regarded as including anything which is not within their letter as well as
their spirit, which is not clearly and intelligibly described in the very words of the statute, as
well as manifestly intended”, while by ‘liberal construction’ is meant that “everything is to be
done in advancement of the remedy that can be done consistently with any construction of
the statute”. Generally criminal laws are given strict interpretation and unless the accused is
found guilty strictly as per the provisions of the law, he cannot be punished. For instance,
when an Act provided for punishment for causing wound by cutting or stabbing and the
accused caused wound by biting, it was not covered under that provision as cutting or
stabbing implied using an external instrument while biting and causing wound does not
involve any external instrument. Labour and welfare laws, on the other hand are given
liberal interpretation as they are beneficial pieces of legislation. Beneficial construction to
suppress the mischief and advance the remedy is generally preferred.

A Court invokes the rule which produces a result that satisfies its sense of justice in the
case before it. “Although the literal rule is the one most frequently referred to in express
terms, the Courts treat all three (viz., the literal rule, the golden rule and the mischief rule)
as valid and refer to them as occasion demands, but do not assign any reasons for
choosing one rather than another. Sometimes a Court discusses all the three approaches.
Sometimes it expressly rejects the ‘mischief rule’ in favour of the ‘literal rule’. Sometimes it
prefers, although never expressly, the ‘mischief rule’ to the ‘literal rule’.

(e)Reddendo Singula Singlis-

Reddendo singula singulis is a Latin term that means by referring each to each; referring each
phrase or expression to its corresponding object. In simple words ‘reddendo singula singulis’
means that when a list of words has a modifying phase at the end, the phrase refers only to the
last. It is a rule of construction used usually in distributing property.

For example, when a will says “I devise and bequeath all my real and personal property to A”,
the principle of reddendo singula singulis would apply as if it read “I devise all my real property,
and bequeath all my personal property, to B”, since the word devise is appropriate only to real
property and the term bequeath is appropriate only to personal property.

Where there are general words of description, following a record of particular things, such
general words are to be construed distributively, 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 is to say, each phrase, word or expression is
to be referred to its suitable objects.

The best example of reddendo singula singulis is quoted from Wharton’s law Lexicon, “If anyone
shall draw or load any sword or gun, the word draw is applied to sword only and the word load
to gun only, the former verb to former noun and latter to latter, because it is impossible to load a
sword or to draw a gun, and so of other applications of different sets of words to one another.”

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 provide 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.

Case Laws:

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. The Supreme Court stated that, where a sentence contains
several antecedents and several consequents they are to be read distributively. That is, the
words are to be applied to the subjects to which they appear by context most properly to relate
and to which they are most applicable

Samantha v. State of Andhra Pradesh, it was a case in which the word ‘person’ of sec. 3 of
A.P. Scheduled Area Land Transfer Regulation 1959, have to be interpreted. The Supreme
Court held that, the maxim “reddendo singula singulis” will apply to the interpretation of the word
“person” so that the general meaning of the word “person” in its generic sense with its width
would not be cut down by the specific qualification of one species, i.e., natural “person” when it
is capable to encompass in its ambit, natural persons, juristic persons and constitutional
mechanism of governance in a democratic set up.

It was also held in a wider sense that, the restricted interpretation would defeat with objective of
the Constitution. The word “person” would be so interpreted as to include State or juristic person
corporate sole or persona ficta. Transfer of land by the juristic persons or allotment of land by
the State to the non-tribals would stand prohibited, achieving the object of Para 5 (2) of the Fifth
Schedule of the Constitution and S.3 of the Regulation. If the word ‘person’ is interpreted to
mean only natural persons, it tends to defeat the object of the Constitution, the genus and the
Regulation, its species.

In Bishop v. Deakin​, section 59(1) of the Local Government Act 1933 construed reddendo
singula singulis. The said section provided that “A person shall be disqualified for being elected
or being a member of 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.”In this case Clanson, J., observed that the section provided two
disqualifications: first what is to be disqualification for election to the local body and second;
what is to be disqualification for being a member after election. This was followed in case of
Chief election Commissioner of India v. Saka Venkata Subba Rao.

Conclusion:

This rule of reddendo singula singulis provides that if a sentence has ambiguity in explaining the
words such as the sentence contains more than one subject and object then, each subject
should be connected to its appropriate object only. If it is not done then there will be a
dangerous meaning of the sentence and the intention of the legislature behind making the
statute would be reversed.

For example, a person instructs her assistant to check a customer‘s file for emails or documents
written by the Manager. Although confusing, an smart assistant would not apply the Rule, but
would read the modifying clause as written by the Manager, as modifying both the first and last
antecedent and search for both emails written by the Manager and documents written by the
Manager. But suppose the person had asked the assistant to check a customer‘s file for the
Manager‘s emails or documents containing the word rewarded. That request may be more
confusing than the first. Should the assistant check the file for the Manager‘s emails containing
Rewarded, or does the modifying clause containing the word Rewarded only apply to the last
antecedent document. Application of the Rule would dictate that the person is seeking all of the
Manager‘s emails, regardless of whether Rewarded is mentioned, as well as all documents
written by any author that contain a word Rewarded. Although the last category may also
include some of the Manager‘s emails, a failure to apply the Rule would necessarily lead to a
failure to get all of the requested documents, because the assistant would have limited his
search of the Manager‘s emails to only those in which ―Rewarded is referenced.

(f) Ul Res Magis Valent Quam Pereat-

The maxim “Ut Res Magis Valeat Quam Pereat” is a rule of construction which literally
means the construction of a rule should give effect to the rule rather than destroying it
.i.e., when there are two constructions possible from a provision, of which one gives
effect to the provision and the other renders the provision inoperative, the former which
gives effect to the provision is adopted and the latter is discarded. It generally starts with
a presumption in favor of constitutionality and prefer a construction which embarks the
statute within the competency of the legislature. But it is to be noted that when the
presumption of constitution fails, then the statutes cannot be rendered valid or operative
accordingly. The landmark case of Indra Sawhney (2000)​, where the Supreme Court
struck down the state legislation as it was violative of constitution and ultra-vires of the
legislative competency.

1. Ejusdem Generis

According to the Black’s Law Dictionary (8th edition, 2004) the principle of Ejusdem
Generis is where general words follow an enumeration of persons or things, by words of
a particular and specific meaning, such general words are not to be construed in their
widest extent, but are to be held as applying only to persons or things of the same
general kind or class as those specifically mentioned. It is a canon of statutory
construction, where general words follow the enumeration of particular classes of
things, the general words will be construed as applying only to things of the same
general class as those enumerated.
The expression Ejusdem Generis means of the same kind. Normally, general words
should be given their natural meaning like all other words unless the context requires
otherwise. But when a general word follows specific words of a distinct category, the
general word may be given a restricted meaning of the same category. The general
expression takes it’s meaning from the preceding particular expressions because the
legislature by using the particular words of a distinct genus has shown its intention to
that effect. This principle is limited in its application to general word following less
general word only. If the specific words do not belong to a distinct. Genus, this rule is
inapplicable. Consequently, if a general word follows only one particular word, that
single particular word does not constitute a distinct genus and, therefore, Ejusdem
Generis rule cannot be applied in such a case.
Exceptional stray instances are, however, available where one word genus has been
created by the courts and the general word following such a genus given a restricted
meaning. If the particular words exhaust the whole genus, the general word following
these particular words is construed as embracing a larger genus. The principle of
Ejusdem Generis is not a universal application. If the context of legislation rules out the
applicability of this rule, it has no part to play in the interpretation of general words. The
basis of the principle of Ejusdem Generis is that if the legislature intended general
words to be used in unrestricted sense, it would not have bothered to use particular
words at all.

2. Noscitur a Socis

The principle of Noscitur a Sociis is a rule of construction. It is one of the rules of

language used by court to interpret legislation. This means that, the meaning of an
unclear word or phrase should be determined by the words immediately surrounding it.
In other words, the meaning of a word is to be judged by the company it keeps. The
questionable meaning of a doubtful word can be derived from its association with other
words. It can be used wherever a statutory provision contains a word or phrase that is
capable of bearing more than one meaning.
This rule is explained in Maxwell on the interpretation of statutes (12th edition ) in
following words “ When two or more words susceptible of analogous meaning are
coupled together, they are understood to be used in their cognate sense.” The words
take their colour from and are quantified by each other, the meaning of the general
words being restricted to a sense analogous to that of the less general.

3. Ut Res Magis Valeat Quam Pereat:

The maxim “Ut Res Magis Valeat Quam Pereat” is a rule of construction which literally
means the construction of a rule should give effect to the rule rather than destroying it
.i.e., when there are two constructions possible from a provision, of which one gives
effect to the provision and the other renders the provision inoperative, the former which
gives effect to the provision is adopted and the latter is discarded. It generally starts with
a presumption in favor of constitutionality and prefer a construction which embarks the
statute within the competency of the legislature. But it is to be noted that when the
presumption of constitution fails, then the statutes cannot be rendered valid or operative
accordingly. The landmark case of Indra Sawhney (2000), where the Supreme Court
struck down the state legislation as it was violative of constitution and ultra-vires of the
legislative competency.

4. Contemporanea Exposito Est Fortissima In Lege

Meaning Contemporaneous exposition is the best and strongest in law. It is said that the
best exposition of a statute or any other document is that which it has received from
contemporary authority. This maxim has been confirmed by the Apex Court in Desh
Bandhu Gupta v. Delhi Stock Exchange Asson. Ltd. AIR 1979 SC 1049, 1054.
Contemporanea exposito is a guide to the interpretation of documents or statutes. It is
one of the important external aids for interpretation. How ever great care must be taken
in its application. When a document was executed between two parties, there intention
can be known by their conduct at the time and after the execution of the instrument.
Where the words of the deed are ambiguous, the court may call in the acts done under
it as a clue to the intention of the parties. Their acts are the result of usages and
practices in the society. Therefore their acts are useful as an external aid to
interpretation of the deed. This principle may also be applied in case of statutes.
“Contemporanea expositio est optima et fortissinia in lege” means usage or practice
developed under a statute is indicative of the meaning ascribed to its words by
contemporary opinion. The maxim Contemporanea expositio as laid down by Lord Coke
was applied to construing ancient statutes, but usually not applied to interpreting Acts or
statutes which are comparatively modern.
The meaning publicly given by contemporary or long professional usage is presumed to
be true one, even where the language has etymologically or popularly a different
meaning. It is obvious that the language of a statute must be understood in the sense in
which it was understood when it was passed, and those who lived at or near that time
when it was passed may reasonably be supposed to be better acquainted than their
descendants with the circumstances to which it had relation, as well as with the sense
then attached to legislative expressions. Usages and practice developed under a statute
is indicative of the meaning ascribed to its words by contemporary opinion and in case
of an ancient statute, such reference to usage and practice is admissible.
He said a uniform notorious practice continued under an old statute and inaction of the
legislature to amend the same are important factors to show that the practice so
followed was based on correct understanding of the law. According to Lord
Ellenborough, Communis opinio is evidence of what the law is. When the practice
receives judicial or legislative approval it gains additional weight and is to be more
respected.
5. Reddendo Singula Singulis

Reddendo singula singulis is a Latin term that means by referring each to each;
referring each phrase or expression to its corresponding object. In simple words
“reddendo singula singulis” means that when a list of words has a modifying phase at
the end, the phrase refers only to the last. It is a rule of construction used usually in
distributing property. Where there are general words of description, following a record of
particular things, such general words are to be construed distributively, 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 is to say, each phrase, word or expression is to be referred to its suitable objects.
The best example of reddendo singula singulis is quoted from Wharton’s law Lexicon, “If
anyone shall draw or load any sword or gun, the word draw is applied to sword only and
the word load to gun only, the former verb to former noun and latter to latter, because it
is impossible to load a sword or to draw a gun, and so of other applications of different
sets of words to one another.” ​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 provide 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.

6. Expresssio Unius Est Exclusio Alterius

Expressio unius est exclusio alterius is a Latin phrase that means express mention of
one thing excludes all others. This is one of the rules used in interpretation of statutes.
The phrase indicates that items not on the list are assumed not to be covered by the
statute. When something is mentioned expressly in a statute it leads to the presumption
that the things not mentioned are excluded. This is an aid to construction of statutes.