What Is Tenthlining?
The Kenyan court rule that requires every 10th line of a legal document to be numbered in the margin: where it comes from, and how to do it in seconds.
Definition
Tenthlining (also written "tenth lining" or "tenth-lining") is the practice of numbering every tenth line of a legal document in the right-hand margin, alongside consecutive page numbers in the top or bottom right-hand corner. It lets a judge, opposing counsel, or clerk cite an exact line, such as "the admission at page 3, line 40," without ambiguity. In Kenya, it isn't optional formatting; it's a requirement set out in court practice directions, and registries can and do reject documents that don't comply.
Where the requirement comes from
The tenth-line numbering rule appears across Kenya's judicial hierarchy:
Supreme Court (General) Practice Directions, 2020, Paragraph 11
"The pages of each document shall be consecutively numbered, on the top right-hand corner and every tenth line of each document shall be numbered in sequence, on the right-hand margin."
Source: Kenya Law, Supreme Court General Practice Directions 2020Court of Appeal Practice Directions for Civil Appeals and Applications, 2015
Requires every tenth line of every document, including the memorandum of appeal, affidavits, written submissions, and the record of appeal, to be numbered in the right-hand margin.
Source: Kenya Law, Court of Appeal Practice Direction 2015High Court Practice Directions, 2022
Extends the same tenth-line numbering requirement to records of appeal and pleadings filed in the High Court.
Source: Kenya Law, Practice Directions 2022Always confirm the exact paragraph and current version against the official Kenya Law or Judiciary publication before relying on it for a filing, since practice directions are amended from time to time.
Why it matters
Failure to comply isn't a technicality. A court registry is entitled to refuse a document that doesn't meet formatting requirements. That can mean a missed filing deadline and the costs that follow, on top of having to redo and resubmit the entire document.
Not unique to Kenya
Line-numbered court documents are a broader common-law court tradition, not a Kenya-specific quirk. California's Rules of Court, for example, require every page of a pleading to carry consecutively numbered lines in the left margin, with at least three line numbers for every vertical inch on the page. Legal commentators also note that many U.S. trial courts expect line numbers on pleadings and motions as a matter of local practice, even where the exact interval and placement rules differ by jurisdiction.
Kenya's version of the rule is distinct in its detail: every tenth line, numbered in the right-hand margin, alongside separate page numbers in the corner, rather than every single line down the left margin as in California. Different convention, same goal: letting anyone in the room point to one exact line without confusion.
California Rule of Court 2.108 · Line Numbering in Trial-Court Pleadings and Motions, Volokh Conspiracy
Tenthlining tool vs. doing it by hand
Manually inserting line numbers every tenth line in Word or Adobe means placing numbered text boxes down the margin and re-aligning every one of them each time the document is edited and text reflows. That's slow, and easy to get wrong on a long affidavit or a multi-document bundle.
A tenthlining tool automates the whole thing: upload the PDF and get a court-compliant, tamper-proof, e-filing-ready document back in seconds. Tenthliner is built specifically for this. It works on native digital PDFs, scanned documents, and handwritten documents alike.
Try Tenthliner free: 50 credits, no card needed