Tenth Lining in Kenyan Courts: The Formatting Rules, Court by Court

If you file documents in Kenyan courts, tenth lining is not optional polish — it is a stated formatting requirement. This guide covers where the requirement comes from, what each court expects, and a checklist to run before you file.

Where the requirement comes from

The clearest statement is in the Court of Appeal Practice Directions for civil appeals and applications, which provide that “every tenth line of every document shall be numbered in the right hand margin.” The convention itself is older — inherited from the rules of the former Court of Appeal for Eastern Africa — which is why registries and judges across the court system treat it as standard practice, not just an appellate technicality.

What each court expects

• Court of Appeal — the strictest setting. Records of appeal must be paginated consecutively and tenth lined. A defective record invites a preliminary objection from the other side, and at minimum a costly delay while you lodge a supplementary record.
• High Court — pleadings, affidavits, witness statements, written submissions and bundles are expected to be tenth lined. Judges routinely direct parties to line references during hearings; a document without them slows your own advocacy.
• Magistrates’ Courts — the same convention applies, and busy registries are quick to bounce non-compliant filings back over the counter.

Pre-filing formatting checklist

• Every tenth line numbered in the right-hand margin (10, 20, 30 …).
• Numbering restarts or runs continuously according to your court’s convention — be consistent within the document.
• Pages numbered consecutively.
• Line numbers aligned and legible — not overlapping the text or cut off by the printer margin.
• Numbers still correct after your final round of edits. This is where manual tenth lining most often fails: one inserted paragraph shifts every number below it.

The practical problem with doing it by hand

Microsoft Word’s built-in line numbering places numbers in the left margin and counts every line, so it does not meet the requirement. The usual workarounds — margin text boxes, two-column tables, manual typing — are fragile. On a 100-page record of appeal, a single late amendment can mean an afternoon of recounting.

TenthLiner automates the whole step: upload your PDF or Word (.docx) document, pick the court format (Magistrates’ Court, High Court or Court of Appeal), preview the result, and pay per page via M-Pesa. The numbers are placed in the right-hand margin exactly where the Practice Directions want them.