What trial tactics should a lawyer know before he steps into court?

I think the most tough job for a lawyer is to remember the rule numbers. There are actually two dangers when lawyers reach the rule numbers. The first is that they will state the wrong number. All of us should admit that we sometimes look at the rules to remember the numbers. Many of us feel that uttering the wrong number is worse than uttering no number at all. Second if you are less willing to admit it, there is a chance where you can confuse the judge. Unless the judge offers the reason for ruling, you may never know that the judge was confused.

Friends, according to me the most important thing a lawyer should remember is the limitation of instruction. Upon request, a party can obtain a limiting instruction when evidence is admitted for a limited purpose. A lawyer cannot expect the judge to explain how evidence may be used. Many judges will not give specific instruction to the jury, which they think may cause more harm than good.

Too often Trial lawyers  amidst clutter of rules, precedents and statutes tend to overlook the fact that that basic requirement of law  is common sense. While articulating a legal framework to interpret facts available, scant attention is given to the fundamental benchmark upon which law visualises legal relations. The principle " As a man or woman of ordinary prudence would have done or abstained" is the underlying basis in contemplation and analysis of all legal relations under scrutiny. Instead of trying to fit facts into a  preconceived legal-interpretative framework, a trial lawyer needs to be open minded to facts and the logical relationships they present. Keeping a case simple  always persuades the judge to your point of view. Analysis of facts as a person with commonsense would do, obviates the pitfall of getting lost in legal frameworks into which one cant squeeze in facts.