Make sure you torque them down with the car on the ground or stands under the axle. you don't want the body jacked up and the axle hanging down. Also recheck a couple times after driving.
I would think that torquing them with the axle hanging down with no load would be the best, that way you are not fighting any load on the bolts while torquing the nuts.
Then check them again when you put it on the wheels.