Are these sketches simply drawn by hand with a lot of effort or is there a trick to them?
Credit: Naruto, Vol. 1: Uzumaki Naruto (9781569319000)
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One way I think is common among comic artists is through instancing*: after having drawn a few of the figures in different positions, you can copy instances of these individual figures unto the panel using either
a lightbox or light table, when working with traditional tools, or
image editing software (e.g. Photoshop or Clip Studio Paint), when taking a digital approach.
Alternatively, some specialized software allows for importing 3D models that can be positioned, after which a render can be made that looks like a drawing.
However, at close inspection, this particular image doesn't show obvious signs of instancing, so I think this was all drawn by hand by Kishimoto.
That, or the instances were edited afterward (using any of the approaches mentioned).
* I'm not sure 'instancing' is the term used in the comic world, though: I know it from 3D editing software and game engines, where it is common.