A jury's failure to reach a verdict on some counts in a multi-count sexual offence trial cannot be equated with an acquittal and does not of itself render guilty verdicts on other counts unsafe or unsatisfactory. The Markuleski direction (that doubt on one count should create doubt on all counts) is not required in every multi-count case; the appropriate directions vary and a direction that the jury should consider the reason for their doubt and whether it affects their assessment of other evidence may be sufficient.
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