Rule 3A:16 - Instructions(a)Giving of Instructions. In a felony case, the instructions must be reduced to writing. In all cases the court must instruct the jury before arguments of counsel to the jury.(b)Proposed Instructions. If directed by the court the parties must submit proposed instructions to the court at such reasonable time before or during the trial as the court may specify and, whether or not proposed instructions have been submitted earlier, the parties may submit proposed instructions at the conclusion of all the evidence.(c)Objections. Before instructing the jury, the court must advise counsel of the instructions to be given and must give counsel the opportunity to make objections thereto. Objections must be made out of the presence of the jury, and before the court instructs the jury unless the court grants leave to make objections at a later time.(d)Alternative Forms of Verdicts; Separate Verdicts. The court may submit alternate forms of verdicts to the jury. The jury must be instructed to return a separate verdict on each count of an indictment or presentment.Amended by order dated September 3, 2020, effective 9/3/2020; amended by order dated November 23, 2020, effective 3/1/2021.