24/06/16 What’s the Difference between ‘Every,’ ‘Each,’ & ‘Any’?

e-legal lesson

Every is used to refer to all of the individual members of a set without exception. Each means every one of two or more people or things, regarded and identified separately. Use of both words in each and every is an indication of the overlap between the two words.

In certain contexts, one can use every and each without risk of ambiguity, as in the following example:
The Company shall purchase

[every] [each] vehicle included in the Roe Assets.

But if you use language of discretion, as in the following example, every and each become ambiguous.
The Company may purchase [every] [each] vehicle included in the Roe Assets.

The effect would be the same if in the previous example you were to say instead all vehicles.

Any exhibits similar ambiguity, except that it manifests itself in language of obligation. Analogous to the use of any in the following example (a) to convey the meaning of (b) is how any is used in the sentence Take the name of any person who comes through the door: the speaker presumably had in mind that any means every, with the added implication that no one might come through the door. And analogous to use of any in (a) to convey the meaning of (c) is how it’s used in Pick any card – the reasonable interpretation is that one is being invited to pick a single card. By contrast, with language of discretion (see (d)) the question is whether the drafter intended any to mean “one,” as in (e), or “one or more,” as in (f).

  1. The Company shall purchase any vehicle included in the Roe Assets.
  2. The Company shall purchase no fewer than all vehicles included in the Roe Assets.
  3. The Company shall purchase one of the vehicles included in the Roe Assets.
  4. The Company may purchase any vehicle included in the Roe Assets.
  5. The Company may purchase only one of the vehicles included in the Roe Assets.
  6. The Company may purchase one or more of the vehicles included in the Roe Assets.