Ind. Trial Rule 51

Submission in stages

Effective January 1, 2011

(A) Preliminary Instructions.

When the jury has been sworn the court shall instruct the jury in accordance with Jury Rule

20. Each party shall have reasonable opportunity to examine these preliminary instructions

and state his specific objections thereto out of the presence of the jury and before any party

has stated his case. (The court may of its own motion and, if requested by either party, shall

reread to the jury all or any part of such preliminary instructions along with the other instructions given to the jury at the close of the case. A request to reread any preliminary instruction

does not count against the ten [10] instructions provided in subsection (D) below.) The

parties shall be given reasonable opportunity to submit requested instructions prior to the

swearing of the jury, and object to instructions requested or proposed to be given.

(B) Final Instructions.

The judge shall instruct the jury as to the law upon the issues presented by the evidence in

accordance with Jury Rule 26.

(C) Objections and requested instructions before submission.

At the close of the evidence and before argument each party may file written requests that

the court instruct the jury on the law as set forth in the requests. The court shall inform counsel of its proposed action upon the requests prior to their arguments to the jury. No party

may claim as error the giving of an instruction unless he objects thereto before the jury

retires to consider its verdict, stating distinctly the matter to which he objects and the

grounds of his objection. Opportunity shall be given to make the objection out of the hearing

of the jury. The court shall note all instructions given, refused or tendered, and all written

objections submitted thereto, shall be filed in open court and become a part of the record.

Objections made orally shall be taken by the reporter and thereby shall become a part of the

record.

(D) Limit upon requested instructions.

Each party shall be entitled to tender no more than ten [10] requested instructions, including

pattern instructions, to be given to the jury; however, the court in its discretion for good

cause shown may fix a greater number. Each tendered instruction shall be confined to one

[1] relevant legal principle. No party shall be entitled to predicate error upon the refusal of a

trial court to give any tendered instruction in excess of the number fixed by this rule or the

number fixed by the court order, whichever is greater.

(E) Indiana Pattern Jury Instructions (Criminal)/Indiana Model Jury

Instructions (Civil).

Any party requesting a trial court to give any instruction from the Indiana Pattern Jury Instructions (Criminal)/Indiana Model Jury Instructions (Civil), prepared under the sponsorship of the

Indiana Judges Association, may make such request in writing without copying the instruction

verbatim, by merely designating the number thereof in the publication.