Where evidence in support of a s.47A charge discloses only one category of sexual conduct and the complainant confirms it occurred on more than three occasions, the jury unanimity requirement from KBT v The Queen is satisfied by a direction that the jury must agree on at least three acts of that type, without a further direction requiring unanimity on the same three specific acts. The inclusion of a s.47A count on a presentment alongside specific counts does not of itself require a propensity direction. The actus reus of the s.47A offence is the commission of three or more sexual acts, not the maintenance of a sexual relationship.
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