A jury's unanimous verdict of manslaughter does not require that all jurors agree on the same basis or variety of manslaughter. It is sufficient that all jurors agree on the verdict of manslaughter, even if some reached that verdict via provocation and others via unlawful and dangerous act. This accords with the long-established practice confirmed in R v Isaacs (1997) 41 NSWLR 374 and R v Cramp [1999] NSWCCA 324. A trial judge is not required to direct the jury that they must be unanimous as to the particular variety of manslaughter.
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