A juror's independent internet research into a legal concept (here, the meaning of 'indictable offence') does not constitute a material irregularity resulting in a miscarriage of justice where the information obtained was not relevant to any issue the jury had to decide, was not inaccurate or inconsistent with the trial judge's directions, and was not prejudicial to the accused. The strength of the prosecution case is a relevant consideration in applying the Marsland test.
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