Subject-verb agreement is the discipline of making a verb match its subject in number (singular or plural) and person. It sounds like a schoolroom nicety, yet it is one of the highest-yield topics in the language paper of every judiciary examination, and it quietly governs how statutes are read. A singular subject takes a singular verb (the accused was present); a plural subject takes a plural verb (the accused persons were present). The traps lie in the gap between grammatical number and notional meaning — collective nouns, paired conjunctions, intervening phrases and indefinite pronouns — and examiners crowd those traps. This chapter builds the rule from first principles, drills every recognised exception, and then shows how the very same instinct for number decides real disputes, from Tej Kiran Jain v. N. Sanjiva Reddy on the breadth of a word to Section 13 of the General Clauses Act, 1897, which tells courts when singular silently includes the plural.
Why Agreement Matters in a Law Paper
In the English component of judiciary papers — whether the UP, Bihar, Rajasthan or Delhi format — subject-verb agreement appears as direct error-spotting, sentence-correction and fill-in-the-blank items, and it is the single rule most often tested because it can be examined in one short clause without ambiguity. A candidate who internalises the rule earns marks mechanically rather than by feel. But the deeper reason to master it is professional: a verb that disagrees with its subject can change who or how many the law is talking about. When a section says “the person who commits theft shall be punished”, the singular verb tracks a singular doer; the moment drafting shifts to “persons who commit theft shall be punished” the reach widens. Read this chapter alongside Parts of Speech, because you cannot make a verb agree with a subject until you can reliably find the subject — and the subject is always a noun or pronoun, never the object of a preposition sitting next to the verb.
The Core Rule: Match Number and Person
The foundational rule has two halves. First, number: a singular subject demands a singular verb, a plural subject a plural verb. In the present tense the singular verb is the one that carries the ‑s (he writes), while the plural verb is bare (they write) — a deliberate inversion that confuses many candidates, because the ‑s ending signals plurality on nouns but singularity on verbs. Second, person: the verb must agree with first, second or third person (I am, you are, she is). Most examination errors are number errors, but person errors surface with the verb to be and in reported speech, which you will meet again in Direct and Indirect Speech. The test is mechanical: isolate the true subject, strip away every modifier, decide its number, then select the verb. A sentence is only as correct as the link between that headword and its verb.
Two structural points keep candidates safe. Number on a verb is visible mainly in the present tense and in the verb to be; in the simple past most verbs do not change form (he filed / they filed), so error-spotting on agreement clusters around present-tense verbs and around is/are, was/were, has/have. That is exactly where examiners set their items. Second, agreement is a property of the finite verb only — the verb that carries tense. Infinitives (to argue), participles (arguing, argued) and gerunds do not inflect for the subject's number, so once you have located the finite verb you have located the only word that must agree. A useful self-check is to mentally substitute a bare pronoun for the whole subject: if it/he/she fits, the verb is singular; if they fits, the verb is plural. This trick neutralises every decorative phrase that an examiner piles between the headword and the verb.
Step One: Find the Real Subject
Agreement errors almost always begin with a misidentified subject. Words that intervene between the subject and the verb do not change the subject's number. In “The bundle of documents was filed”, the subject is bundle (singular), not documents; the phrase “of documents” is a prepositional modifier and is irrelevant to the verb. This is the most exploited trap in error-spotting: an examiner inserts a plural noun in a prepositional phrase immediately before the verb to lure you into a plural verb. Phrases introduced by along with, together with, as well as, including, in addition to, accompanied by and besides are parenthetical — they do not add to the subject. Thus “The Magistrate, along with the clerks, was present” stays singular, because only Magistrate is the grammatical subject. Mastering prepositions — covered in Prepositions — directly improves your agreement accuracy, because every false subject hides inside a prepositional phrase.
The same caution applies to long post-modifying clauses. In “The order passed by the courts below, which the parties have repeatedly challenged, is set aside”, the verb tracks the singular order across two intervening clauses; the plural courts and parties are bystanders. When a subject is itself a clause or an infinitive phrase, treat it as singular: “To examine the witnesses afresh was the only course open” and “What the appellants seek is a fresh trial.” Titles of single works and statutes are singular even when they look plural: “The Indian Penal Code is a colonial statute”; “Salmond on Jurisprudence remains a standard.” The rule is constant — find the headword, ignore the scenery, and let the verb answer only to the head.
Compound Subjects Joined by ‘And’
Two or more subjects joined by and normally form a plural subject and take a plural verb: “The plaintiff and the defendant were heard.” There are two refinements. First, when the joined nouns describe a single idea or a single person or thing, the verb stays singular: “Bread and butter is a poor breakfast” and “The counsel and adviser of the company was present” (one person holding both roles). Second, when each subject is preceded by each or every, the verb is singular despite the and: “Every accused and every witness was examined.” This pairing of grammar with notional unity is exactly the instinct courts apply to drafting: where a statute lists items connected by “and”, the question whether they are read conjunctively (all required) or as a single composite concept can decide a case, which is why the conjunctive-disjunctive “and/or” problem recurs throughout statutory interpretation.
Either…Or, Neither…Nor and the Proximity Rule
When singular subjects are joined by or, nor, either…or or neither…nor, the verb is singular: “Neither the petitioner nor the respondent was ready.” The difficulty arises when the two subjects differ in number. The governing principle is the proximity rule (the rule of the nearer subject): the verb agrees with the subject closest to it. Hence “Neither the Judge nor the assessors were convinced” (plural verb, because assessors is nearest) but “Neither the assessors nor the Judge was convinced” (singular verb, because Judge is nearest). The same nearer-subject logic governs person: “Either you or I am mistaken.” Because such constructions read awkwardly, good drafters reorder the sentence to put the plural or the first-person element last. Examiners love this rule precisely because candidates apply a blanket “or means singular” reflex and miss the mixed-number case.
Collective Nouns: Bench, Jury, Committee
A collective noun — Bench, jury, committee, Government, company, Court, Tribunal — names a group as a unit. In Indian and British usage the verb is normally singular when the group acts as one body: “The Bench has reserved judgment”; “The Committee was unanimous.” The verb turns plural only when attention shifts to the individual members acting separately: “The jury were divided in their opinions” — here the members hold differing views, so the plural and the plural pronoun their are correct. The litmus test is the accompanying pronoun: if the sentence would naturally use it/its, use a singular verb; if it would use they/their, use a plural verb. Be consistent within a sentence — mixing “The Committee has decided to publish their report” is a classic flagged error. Legal drafting overwhelmingly treats institutions as singular units (“the Court is of the view”), and you should default to the singular unless plurality of action is explicit.
A related construction is the number of versus the number of distinction, which examiners reuse every season. “A number of petitions were filed” is plural — a number of functions as a plural quantifier meaning “many” — whereas “The number of petitions was large” is singular, because here number is the headword and is itself singular. The same split governs a variety of, a group of, a series of, a pair of: read “a variety of arguments were advanced” (plural) against “the variety of arguments was striking” (singular). Two collective traps complete the set: the word police always takes a plural verb in British and Indian usage (“The police have arrested the suspects”), and public takes a singular verb when it means the body of people as a unit but a plural when individuals are meant. Default to the singular for the institution and switch only on a clear cue of severalty.
Indefinite Pronouns and Quantifiers
Indefinite pronouns are a graded set. The following are always singular and take a singular verb: each, either, neither, everyone, everybody, everything, someone, somebody, something, anyone, anybody, no one, nobody, nothing, one. Thus “Each of the petitions was dismissed” and “Everyone of the accused was released on bail” — the plural “of the petitions/accused” is a decoy; the headword each/everyone is singular. A second set is always plural: both, few, many, several — “Few were chosen.” The most examined set is the variable group — some, any, none, all, most, more, half — whose number follows the noun they refer to: “All of the evidence was tendered” (uncountable, singular) but “All of the witnesses were present” (countable, plural). None traditionally takes a singular verb (“none is”) though modern usage accepts the plural when the reference is plainly to several. Pair this with Articles, Definite and Indefinite, because the article preceding the noun often signals its countability and hence the verb's number.
Two refinements repay attention. Each and every remain singular even when they govern several joined nouns: “Each section, sub-section and proviso has to be read together.” And the pronoun they/their is now widely accepted as a singular gender-neutral reference (the singular they), so “Every applicant must verify their affidavit” is acceptable modern usage even though strict traditional grammar preferred his; for error-spotting, however, follow the answer key's convention and keep the verb singular regardless (“every applicant verifies”). Finally, watch fractions and percentages, which behave like some/all and take their number from the noun that follows: “Half of the estate was bequeathed” (singular mass) but “Half of the legatees were minors” (plural count); “Forty per cent of the evidence is hearsay” but “forty per cent of the witnesses are hostile.”
Inversion: ‘There Is’, ‘Here Comes’ and Questions
When a sentence opens with there or here, the word is an introductory adverb, not the subject; the real subject follows the verb, and the verb must agree with it. So “There is a serious flaw in the indictment” (singular subject flaw) but “There are serious flaws in the indictment” (plural subject flaws). The same inversion governs “Here come the witnesses” and questions: “Were the documents produced?” Candidates routinely default to “there is” regardless of what follows; examiners exploit this by placing a plural subject after “there is.” The cure is to locate the post-verb subject before choosing the verb. Where a list follows, agreement is by the nearer subject: “There was a Judge and two clerks present” is accepted because the nearest element after the verb is singular, though many drafters prefer the plural for a manifestly plural total.
Relative Clauses: ‘One of those who…’
In a relative clause introduced by who, which or that, the verb agrees with the antecedent — the noun the relative pronoun stands for. The notorious construction is “one of those who…”. In “He is one of those advocates who argue fearlessly”, the relative who refers back to advocates (plural), so the verb is plural argue, not argues. Contrast “He is the only one of those advocates who argues fearlessly” — the word only restricts the antecedent to one, so the verb turns singular. Identifying the antecedent correctly is the same skill that lets a court decide what a qualifying clause in a statute attaches to, and it is the foundation for the English for Judiciary language paper as a whole. Read the clause backwards from the verb to its true antecedent and the number resolves itself.
Tricky Nouns: Plural Form, Singular Sense
Some nouns wear a plural ‑s yet are singular in meaning and take a singular verb: news (“The news is grave”), and the academic and technical subjects mathematics, physics, statistics, politics, economics, ethics when treated as a field of study (“Statistics is a tool of proof”) — though the same words turn plural when they denote individual figures (“The statistics were disputed”). Diseases and games such as measles, mumps, billiards are singular. Conversely, certain nouns are inherently plural and take a plural verb: scissors, trousers, spectacles, premises, proceedings, assets, alms, tidings, belongings — “The proceedings were adjourned”; “The premises were searched.” Watch the legal staples: data and media are technically plural (datum, medium) though increasingly used as singular collectives. Expressions of quantity, distance, time and money are singular when they denote one amount: “Ten thousand rupees is the penalty”; “Five years is the maximum sentence.” The same applies to “Two-thirds of the bench was required” when the fraction names a single threshold. The guiding idea is notional unity: when the quantity is conceived as one lump, the verb is singular even though the number on the noun is plural.
From Grammar to Law: Number in Statutory Interpretation
The grammarian's concern with number is also the legislature's. Section 13 of the General Clauses Act, 1897 provides that, in all Central Acts and Regulations, unless there is anything repugnant in the subject or context, (1) words importing the masculine gender shall be taken to include females; and (2) words in the singular shall include the plural, and vice versa. This single provision spares the draftsman from writing “person or persons” and “he or she” in every clause, and it tells courts that a singular noun in a statute presumptively covers the plural. The presumption is rebuttable: the words “unless there is anything repugnant in the subject or context” mean that where the structure of a section shows the legislature meant exactly one, the singular is not stretched. Thus agreement in statutes is not merely cosmetic — it is a default rule of construction, and a litigant's case can rise or fall on whether a singular word in a section is read to embrace many.
Two practical consequences follow for a reader of statutes. First, because singular presumptively includes plural, a power conferred on “a Magistrate” or “the Court” to do an act is not defeated merely because more than one person or forum is involved; the draftsman's singular is shorthand, not a numerical limit. Second, the saving words “unless there is anything repugnant in the subject or context” are doing real work — they are the textual hook on which a court hangs a refusal to apply the default. Where a section's scheme, its penalties, or its surrounding provisions show that exactly one person, one act or one thing was intended, the singular stays singular. The interpreter's task therefore mirrors the grammarian's: first read the words in their plain number, then ask whether the context repels the ordinary reading. This is the bridge between the language paper and the interpretation-of-statutes paper, and it is why precision about number is a lawyer's habit, not a schoolroom relic.
When One Word's Number Decided a Case
The clearest illustration that grammar and number control meaning is Tej Kiran Jain v. N. Sanjiva Reddy, (1970) 2 SCC 272, where the Supreme Court read Article 105(2) of the Constitution, which immunises a Member of Parliament from court proceedings for “anything said… in Parliament.” The Court held that the article “means what it says in language which could not be plainer,” and that the word “anything” is “of the widest import and is equivalent to everything” — so no exception could be read in for defamatory speech. The decision is a model of the literal rule: where the words are unambiguous, the court takes them in their plain grammatical sense. The same fidelity to the words' grammar appears in Bengal Immunity Co. Ltd. v. State of Bihar, AIR 1955 SC 661, where the Court parsed Article 286 — attending to its clauses, explanation and structure — to hold that a State could not tax inter-State sales, reading the provision as a connected grammatical whole rather than in isolated fragments. And in State of Bombay v. R.M.D. Chamarbaugwala, AIR 1957 SC 699, the Court reaffirmed that the words and their setting govern the reach of a provision. In each, the court did precisely what an examiner asks of you — fix the subject, respect the number, and read the words as they stand.
The lesson generalises into the literal or grammatical rule of construction: where the words of a statute are plain and admit of only one meaning, the court gives effect to that meaning whatever the apparent consequences, because the words are the surest guide to the legislature's intention. Grammar — including the number of the verb and the reach of a quantifier such as “anything” or “every person” — is therefore not background detail but the operative material a court works with. A misplaced singular, an ambiguous and/or, or a verb that disagrees with its subject can introduce exactly the ambiguity that litigation then has to resolve, often years later and at great cost. For the candidate, the practical takeaway is twofold: in the language paper, treat agreement as a mechanical, rule-bound exercise that yields certain marks; in the law papers, remember that the same attentiveness to subject, verb and number is what separates a confident reading of a section from a hesitant one.
High-Frequency Errors and a Quick Checklist
Distil the chapter into a checklist you can run in seconds under examination pressure. (1) Ignore intervening phrases — strip out of…, along with…, as well as… before choosing the verb. (2) And = plural, except for single-idea pairs and each/every subjects. (3) Or/nor = nearer subject governs number and person. (4) Collective nouns are singular unless members act severally. (5) Each, every, everyone, anybody, none, one are singular; both, few, many, several are plural; some, all, most, none follow their referent. (6) There is/are agrees with the post-verb subject. (7) In “one of those who”, the verb is plural unless only intervenes. (8) News, mathematics, money and time amounts are singular; scissors, premises, proceedings are plural. Drill these against past papers, and revisit Tenses and Their Usage, because agreement and tense together determine the verb form, and a correct tense on a mismatched number still loses the mark.
Frequently asked questions
What is the single most common subject-verb agreement trap in judiciary papers?
A plural noun placed inside a prepositional phrase right before the verb. In “The bundle of documents was filed,” the subject is bundle (singular), not documents. Always strip out of…, along with…, as well as… before choosing the verb.
Does the verb after ‘either…or’ / ‘neither…nor’ take singular or plural?
It follows the proximity rule — the verb agrees with the nearer subject. “Neither the Judge nor the assessors were convinced” (plural, nearest is assessors) but “Neither the assessors nor the Judge was convinced” (singular, nearest is Judge). The same rule governs person: “Either you or I am mistaken.”
Is a collective noun like ‘Bench’ or ‘jury’ singular or plural?
Singular when the group acts as one unit (“The Bench has reserved judgment”), plural only when the members act separately (“The jury were divided in their opinions”). The accompanying pronoun is the test: it/its means singular verb, they/their means plural. Legal drafting defaults to the singular for institutions.
How is ‘one of those who…’ handled?
The verb agrees with the plural antecedent. “He is one of those advocates who argue fearlessly” takes the plural argue because who refers to advocates. But “the only one of those advocates who argues” turns singular, because only restricts the antecedent to one.
What does Section 13 of the General Clauses Act, 1897 say about number?
In all Central Acts and Regulations, unless there is anything repugnant in the subject or context, words importing the masculine gender include females, and words in the singular include the plural and vice versa. So a singular noun in a statute presumptively covers the plural — a rebuttable default rule of construction, not just a drafting convenience.
How did number or plain grammar decide an actual case?
In Tej Kiran Jain v. N. Sanjiva Reddy, (1970) 2 SCC 272, the Supreme Court held that the word “anything” in Article 105(2) is “of the widest import and is equivalent to everything,” so a Member of Parliament enjoys complete immunity for anything said in Parliament. The court took the words in their plain grammatical sense, the same instinct error-spotting tests.