Koteshwar Vittal Kamat v. K. Rangappa Baliga (1969)

Reddendo singula singulis — rendering each to each — is short to state and easy to get wrong, because the stock textbook example given for it is really an example of a different rule. This case is the true distributive application, and it is the one to give in an answer.

It also shows a subsidiary rule doing something the primary rules cannot. The words of the proviso are not ambiguous in the ordinary sense; the difficulty is that a sentence lists two subjects and two verbs, and a purely sequential reading pairs them wrongly. The maxim tells the court to distribute the words to the parts of the sentence they belong to.

The proviso to Article 304 of the Constitution 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"

The sentence contains two subjects — bill and amendment — and two verbs — introduced and moved. Read literally and distributively across both, it would speak of a bill being moved and an amendment being introduced. That is not how either word is used in legislative practice: a bill is introduced, and an amendment is moved.

The Court applied reddendo singula singulis: "introduced" applies to "bill", and "moved" applies to "amendment" — because a bill is introduced and an amendment is moved.

The maxim works by allocating each term in one list to its correspondent in another, rather than reading every term against every other. The steps are mechanical once seen:

1. Identify the lists. Here: two subjects, two verbs.
2. Ask which pairing the subject matter requires. Legislative usage answers it: bills are introduced; amendments are moved.
3. Distribute accordingly, and read the provision as though the pairing had been spelled out.

The result is not a departure from the words. Every word in the proviso is given effect; only the pairing is settled, and it is settled by what the words mean in their own field of use.

The distinction to keep. Some accounts of reddendo singula singulis give a different example: in "firemen, policemen, and doctors in a hospital", the words in a hospital qualify only doctors. Strictly, that is better described as the rule of last antecedent — that relative and qualifying words and phrases are applied to the antecedent immediately preceding them. The two ideas are related, since both allocate words to the part of the sentence they belong to, but the Article 304 case is the true distributive application. In an answer, give the Koteshwar example for reddendo singula singulis and mention the last-antecedent rule separately.

It opens the reddendo singula singulis limb of the standard question on subsidiary rules, which asks you to explain noscitur a sociis, ejusdem generis and reddendo singula singulis with cases, and it is the only Indian illustration the paper needs for that limb. Quote the proviso, show the wrong pairing, then the right one.

It disposes of an argument built on a mechanically sequential reading of a sentence that contains parallel lists, and it disposes of the confusion between this maxim and the last-antecedent rule, provided you name the difference.

It does not decide anything about the substantive requirement of the President's previous sanction under Article 304(b); the case is cited in this paper for the technique of construction only. Nor does it license redistributing words where the sentence, read in its ordinary order, already makes sense — the maxim answers a pairing problem, not a meaning problem.