Who said “whose” is only for people? (Using “whose inanimate”)

Legal English for Spanish Speakers

This aspect of English grammar is not limited to legal usage, but the convenience of using “whose inanimate” arises so often in legal writing that I cannot resist the temptation to address it here. Generations of native speakers of English have been taught categorically that in relative clauses “whose” should only be used when referring to people, while “which” must be used to refer to things. Thus, as a simple example, the expression cuyo contenido se tiene aquí por reproducido will most often be translated using “of which” as “the content of which is incorporated by reference herein.” However, the use of “whose” in this example would be perfectly correct: “whose content is incorporated by reference herein.”

The authoritative Fowler’s* English usage dictionary includes numerous examples of “whose” used as a relative pronoun with an inanimate antecedent. In the Burchfield edition, which contains many examples of this usage taken from the Oxford English Dictionary, Fowler puts this matter to rest by saying,

“…in the starch that stiffens English style one of the most effective ingredients is the rule that whose (as a relative pronoun) shall refer only to persons. …Let us, in the name of common sense, prohibit the prohibition of whose inanimate; good writing is surely difficult enough without the forbidding of things that have historical grammar, and present intelligibility, and obvious convenience, on their side, and lack only—starch.”

And lawyer-lexicographer Bryan Garner has expressed the same opinion in both of his usage dictionaries:**

“Whose may usefully refer to nonpersons (an idea whose time has come). This use of “whose,” formerly decried by some 19th-century grammarians and their predecessors, is often an inescapable way of avoiding clumsiness.”


*The New Fowler’s Modern English Usage, R.W. Burchfield, ed. Oxford: OUP, 1998.

**Bryan Garner, Garner’s Dictionary of Legal Usage and Garner’s Modern American Usage, both 3rd ed., OUP, 2011 and 2009.

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