Ejusdem Generis, Noscitur a Sociis and Reddendo Singula Singulis

Words take their meaning from the company they keep. Three related maxims put this idea to work. Ejusdem generis limits general words that follow a list of specific ones. Noscitur a sociis lets a doubtful word take colour from its neighbours. Reddendo singula singulis matches words in one list to their counterparts in another. Each is a rule of language, not of law, and gives way where the legislature's intention is clearly different. This note explains all three with their conditions and leading cases.

1. Ejusdem Generis

Ejusdem generis means 'of the same kind'. Where general words follow particular words that form a distinct class or genus, the general words are read as limited to things of the same kind as the particular words, and not given their widest meaning.

Figure 1: Five conditions: Amar Chandra Chakraborty (1972)

• The conditions. In Amar Chandra Chakraborty v Collector of Excise (1972) the Supreme Court held the rule applies only where the statute enumerates specific words, those words form a class or category, the class is not exhausted by the enumeration, a general term follows the enumeration, and there is no indication of a different legislative intent.
• Applied there. The Court refused to read any cause other than in s.43 of the Bengal Excise Act as limited by the causes in s.42, since those causes did not form a single genus.
• Powell v Kempton Park (1899). A statute prohibited keeping a house, office, room or other place for betting. The words formed a class of indoor places, so an open-air enclosure at a racecourse was held not to be an 'other place'.
• No genus, no rule. If the specific words are disparate, or there is only one specific word, there is no genus to limit the general words.

2. Noscitur a Sociis

Noscitur a sociis means 'a word is known by the company it keeps'. Where a word of doubtful meaning is associated with other words, its meaning may be gathered from them. It is wider than ejusdem generis, which is one particular application of it, because it does not require a list followed by general words.

• IRC v Frere (1965). In the phrase interest, annuities or other annual payments, the word interest was read in the light of its companions as meaning annual interest, not short interest.
• Ahmedabad Teachers (2004). The Supreme Court held that teachers were not employees under the Payment of Gratuity Act as it then stood, since the definition covered persons employed to do skilled, semi-skilled, unskilled, manual, supervisory, technical or clerical work, and teaching did not fall within those associated categories. Parliament later amended the Act to cover teachers.
• The limit. In State of Bombay v Hospital Mazdoor Sabha (1960) the Court cautioned that noscitur a sociis is only a rule of construction, and cannot be used to cut down words the legislature has deliberately used in a wide sense; hospitals were held to fall within industry.

3. Reddendo Singula Singulis

Reddendo singula singulis means 'referring each to each'. Where a sentence contains several antecedents and several consequents, they are read distributively, each word being applied to its appropriate object. The classic example is a provision punishing anyone who shall draw or load any sword or gun: it is read as drawing a sword or loading a gun, since one does not load a sword or draw a gun.

• Use. Applied where the grammar of a sentence pairs words in two lists that naturally correspond.
• Limit. Not applied where the context shows that every antecedent is meant to apply to every consequent.

4. The Three Maxims Compared

Figure 2: Three rules of language

5. Frequently Asked Questions

What is the rule of ejusdem generis?

Where general words follow particular words that form a class, the general words are limited to things of the same class. In Amar Chandra Chakraborty v Collector of Excise (1972) the Supreme Court held that the rule applies only where specific words are enumerated, they form a class, the class is not exhausted, general words follow, and there is no indication of a different legislative intent.

How is noscitur a sociis different from ejusdem generis?

Noscitur a sociis is the broader principle that a word takes its meaning from its associated words. Ejusdem generis is a particular application of it, confined to general words that follow a list of specific words forming a class. Noscitur a sociis can apply to any group of associated words, whatever their order.

What is reddendo singula singulis?

It is the rule that where a provision contains several words in one part that correspond to several words in another, each is applied to its appropriate counterpart. A provision punishing anyone who shall draw or load any sword or gun is read as drawing a sword or loading a gun, because each verb fits only one of the objects.

6. Related Topics

• Topic 16: Other Maxims of Interpretation. The remaining maxims.
• Topic 17: Meaning of Words. Ordinary, technical and associated meanings.