In multi-count sexual offence trials where the case is substantially word against word, the trial judge should as a general rule direct the jury that if it has a reasonable doubt about the complainant's evidence on any count, it should take that doubt into account in assessing the complainant's credibility on all other counts. The absence of such a direction, combined with an inadequate Crofts direction on delay in complaint, may result in a miscarriage of justice. The application of Jones v The Queen to inconsistent verdicts turns on the particular facts of each case, including whether there is an identifiable basis for the jury's differentiation between counts; the mere fact that a jury acquits on some counts and convicts on others does not of itself render the verdicts unreasonable.
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