The rule is that "Referential and qualifying phrases, where no contrary intention appears, refer solely to the last antecedent.
While courts invoked the principle previously, it was Jabez Gridley Sutherland, a noted attorney, legislator, judge and politician, who in 1891 in his influential treatise stated, “Relative and qualifying words and phrases, grammatically and legally, where no contrary intention appears, refer solely to the last antecedent.” J. Sutherland, Statutes and Statutory Construction, § 420 (1891) (footnote citations omitted).
He noted, “[i]t is better always to adhere to a plain, common-sense interpretation of the words of a statute than to apply to them a refined and technical grammatical construction.
“Qualifying words have been applied to several preceding sections where the nature of the provisions and the obvious sense required it.” Id.
He noted further that where there is “improbability of a contrary design[,]… an independent proposition” may apply alike to all antecedents which are of the “same class.” See id.