(a) Procedural Instructions. At the commencement of and during the course of a trial, the court may orally give the jury cautionary and other instructions of law relating to trial procedure, the duty and function of the jury, and may acquaint the jury generally with the nature of the case.
Rule 51.Instructions to Jury
Chapter VI: Trials · Not amended since adoption on record · Last verified July 14, 2026
In one sentenceRule 51 lets the court give the jury oral procedural instructions at any point in the trial, but requires each party's six allowed substantive instructions on the law to be submitted in writing, labeled by party, and read to the jury after the evidence closes.
Full Text of Rule 51
(b) Substantive Instructions. Each party to an action may submit six instructions on the substantive law of the case. However, the court may permit the submission of additional instructions as justice requires. The court may instruct the jury of its own initiative.
(1) When Submitted. Instructions proposed by parties shall be submitted to the court at the pre-trial hearing as provided by Rule 16. In the event a pre-trial hearing is not conducted, proposed instructions shall be delivered to the court and counsel for all parties not later than twenty-four hours prior to the time the action is scheduled to be tried.
(2) Identification. The court’s substantive instructions shall be numbered and prefixed with the letter C. Plaintiff’s instructions shall be numbered and prefixed with the letter P. Defendant’s instructions shall be numbered and prefixed with the letter D. In multi-party actions, Roman numerals shall be used to identify the proposed instructions of similarly aligned parties; the Roman numerals shall be placed after the alphabetical designation of P or D, as the case may be, and shall conform to the sequential listing of parties plaintiff or defendant as stated in the complaint.
Instructions shall not otherwise be identified with a party.
(3) Objections. No party may assign as error the granting or the denying of an instruction unless he objects thereto at any time before the instructions are presented to the jury; opportunity shall be given to make the objection out of the hearing of the jury. All objections shall be stated into the record and shall state distinctly the matter to which objection is made and the grounds therefor.
(c) Instructions to be Written. Except as allowed by Rule 51(a), all instructions shall be in writing.
(d) When Read; Available to Counsel and Jurors. Instructions shall be read by the court to the jury at the close of all the evidence and prior to oral argument; they shall be available to counsel for use during argument. Instructions shall be carried by the jury into the jury room when it retires to consider its verdict.
Advisory Committee Notes
It is the trial court’s responsibility to properly instruct the jury. “[W]here under the evidence a party is entitled to have the jury instructed regarding a particular issue and where the party requests an instruction which for whatever reason is inadequate in form or content, the trial judge has the responsibility either to reform and correct the proffered instruction himself or to advise counsel on the record of the perceived deficiencies therein and to afford counsel a reasonable opportunity to prepare a new corrected instruction.” Mississippi Valley Silica Co., Inc. v. Eastman, 92 So. 3d 666, 669 (Miss. 2012) (quoting Byrd v. McGill, 478 So. 2d 302, 303 (Miss. 1985)). See Rule 3.07 of the Uniform Circuit and County Court Rules for additional provisions governing jury instructions. See also Mississippi Model Jury Instructions of 2012 which were prepared by a commission appointed by the Mississippi Supreme Court. Although not formally adopted or approved by the Supreme Court of Mississippi, the “Plain Language Model Jury Instructions” have been placed on the Supreme Court website as an aid to trial judges and attorneys.
Plain-English Summary
Rule 51 splits jury instructions into two kinds. Procedural instructions cover the mechanics of trial — the jury's role, what to expect, cautionary guidance — and the court can give these orally, at the start of trial or at any point along the way. Substantive instructions state the actual law that governs the case, and here the rule is stricter: each party gets six, though the court can allow more when justice calls for it, and the court may also instruct the jury on its own initiative.
Timing and labeling matter. Proposed substantive instructions go to the court at the pretrial hearing under Rule 16; if there's no pretrial hearing, they're due to the court and opposing counsel at least twenty-four hours before trial. Each instruction carries a letter — C for the court, P for the plaintiff, D for the defendant — and in cases with multiple parties on the same side, Roman numerals sort them in the order those parties appear in the complaint. An objection to giving or refusing an instruction has to happen before the instructions go to the jury, with a chance to argue it outside the jury's hearing, and the objection must state the specific matter and grounds on the record — a vague objection preserves nothing for appeal.
Substantive instructions must be in writing, with the oral-instruction option in (a) as the only exception. They're read to the jury once all the evidence is in and before closing argument, stay available to counsel during argument, and go into the jury room with the jurors when they retire to deliberate.
Frequently Asked Questions
How many jury instructions can each side submit in a Mississippi civil trial?
Rule 51(b) gives each party six instructions on the substantive law of the case, though the court may permit additional instructions as justice requires, and the court can instruct the jury on its own initiative as well.
When do I have to submit my proposed jury instructions?
Instructions go to the court at the pretrial hearing held under Rule 16. If the case has no pretrial hearing, proposed instructions must reach the court and all counsel no later than twenty-four hours before trial is scheduled to begin.
How are jury instructions labeled in a Mississippi case?
The court's instructions are numbered with a C prefix, the plaintiff's with a P prefix, and the defendant's with a D prefix. In cases with multiple parties aligned on the same side, Roman numerals follow the letter and track the order those parties are listed in the complaint.
What do I need to do to preserve an objection to a jury instruction?
Rule 51(b)(3) requires the objection before the instructions are presented to the jury, with an opportunity to argue it outside the jury's hearing. The objection must be stated on the record and must identify distinctly what is being objected to and the grounds for the objection.
Can the judge instruct the jury out loud instead of handing over a written instruction?
Only for the procedural instructions covered by Rule 51(a) — cautionary guidance, explanations of the jury's role, and background on the case. Substantive instructions on the governing law must be in writing.
Source & verification. Rule text and Advisory Committee Notes are
reproduced verbatim from the Mississippi Rules of Civil Procedure, adopted by the
Supreme Court of Mississippi. Last verified July 14, 2026.
· Official source
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