I believe that the code requires: a minimum of 2 recept circuits for the kitchen (and related areas) and a minimum of 2 recept circuits for the kitchen counter.
A total of 2 recept cicruits can serve both of these requirements.
If a third circuit is present and does not serve the counter top area, it may serve light fixtures also.
Like others have said, it is perhaps not the best of practice to have lights on the kitchen area circuits in any case.
