A Markuleski direction is not required where 11 of 12 jurors accepted the complainant's evidence on all counts and the prosecution case is not accurately described as 'word against word' due to independent support for the complainant's credibility. The movement from a 10/2 to 11/1 split on one count after a majority verdict direction does not, without more, give rise to an inference that a juror compromised or was overborne.
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