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Various word-processing system have been developed to identify grammatical errors and mark learners' essays. However, they are not specifically developed for Malaysian ESL (English as a second language) learners. A marking tool which is capable to identify errors in ESL writing for these learners is very much needed. Though there are numerous techniques adopted in grammar checking and automated essay marking system, research on the formation and use of heuristics to aid the construction of automated essay marking system has been scarce. This paper aims to introduce a heuristics based approach that can be utilized for grammar checking of tenses. This approach, which uses natural language processing technique, can be applied as part of the software requirement for a CBEM (Computer Based Essay Marking) system for ESL learners. The preliminary result based on the training set shows that the heuristics are useful and can improve the effectiveness of automated essay marking tool for detecting grammatical errors of tenses in ESL writing.