(d) रेडेन्डो सिंगूला सिंगूलिस Reddendo Singula Singulis

Answer (d)

The maxim "Reddendo Singula Singulis" is a principle of statutory interpretation, which means "giving each thing its own meaning" or "applying one meaning to each word or provision separately." It is a rule that is applied when a statute or a legal document contains provisions that are listed together, but each one needs to be understood or interpreted in isolation, applying its specific context or meaning.

Explanation of the Maxim:

•             The maxim essentially dictates that when multiple things are mentioned together, and each thing has a distinct relationship with its corresponding term, they must be interpreted separately in relation to the object or subject they refer to.

•             It is used to ensure that each word, phrase, or provision is interpreted according to its specific reference, without assuming that the meaning of one element applies to others unless stated otherwise.

Application of the Maxim in Statutory Interpretation:

This maxim is typically applied when a statute contains a list of things or terms. Instead of giving the entire list a general or collective interpretation, each item in the list is given its own independent meaning based on the context it appears in.

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Decided Cases Illustrating Reddendo Singula Singulis:

1. "Attorney General v. The Advocate-General for Scotland" (1917) AC 10 (HL)

•             Case Overview: This case dealt with the interpretation of a phrase that listed several categories of people and functions in relation to the appointment of legal officers. The question arose regarding whether all categories were subject to the same rules or if each should be interpreted individually.

•             Application of the Maxim: The House of Lords applied Reddendo Singula Singulis to interpret each category (like legal officers) individually, meaning that the rules applicable to each category were considered separate from one another, based on their specific nature.

•             Outcome: It was held that each term in the statute should be given its own specific meaning, as they referred to different legal concepts, thus enforcing the maxim.

2. "St. John Shipping Corporation v. Joseph Rank Ltd." (1957) 1 QB 267 (CA)

•             Case Overview: This case involved the interpretation of a clause in a contract, which contained a series of provisions relating to indemnity and liability.

•             Application of the Maxim: The Court of Appeal invoked Reddendo Singula Singulis to argue that each provision in the contract should be understood separately. It determined that the rules of indemnity did not apply uniformly across all situations, as the provisions referred to different forms of liabilities and actions.

•             Outcome: The court concluded that different interpretations applied to different parts of the contract, ensuring that each item was treated independently rather than as a collective provision.

3. "M. K. Prabhakaran v. State of Kerala" (1996) 2 SCC 410

•             Case Overview: This case involved the interpretation of a statutory provision that referred to the qualifications of candidates for election to a specific office. The provision included a list of qualifications, but it was not clear whether all qualifications applied to every candidate in a uniform way.

•             Application of the Maxim: The Supreme Court applied the principle of Reddendo Singula Singulis, ruling that each qualification mentioned in the statute applied separately to each category of candidates. The rule specified that certain qualifications applied only to certain classes, and each qualification should be interpreted according to the candidate it referred to.

•             Outcome: The Court applied the maxim to ensure that each qualification was interpreted separately and correctly in relation to the class of candidates it was intended for.

4. "In re: S. K. Gupta" (1997) 5 SCC 199

•             Case Overview: This case focused on the interpretation of a provision that dealt with multiple categories of offenses, with the question being whether the penalties applied uniformly to all categories.

•             Application of the Maxim: The Court invoked Reddendo Singula Singulis to interpret the statute's provisions, stating that the penalty for each offense category was independent and should be treated separately, as each offense had distinct characteristics that required specific consideration.

•             Outcome: The Court concluded that the penalties should be individually applied, upholding the principle of interpreting each part of the law separately.

Conclusion:

The maxim Reddendo Singula Singulis ensures that the language of a statute or legal document is applied with precision. By interpreting each item or provision in isolation, courts can avoid generalizing and can properly apply the law as it was intended. This maxim plays an important role in the interpretation of statutes, ensuring that every term or clause is treated in its own context, maintaining clarity and fairness in legal proceedings.