Where a jury acquits on one count but convicts on another involving similar conduct, the verdicts are not inconsistent if the evidence supporting each count is qualitatively different. Defence counsel's failure to cross-examine witnesses who gave no unfavourable evidence on the relevant counts does not constitute a miscarriage of justice where the failure is explicable as an informed forensic decision. A direction requiring the jury to find conduct was engaged in for sexual pleasure is at least as stringent as the tests in R v Bryant.
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