A trial judge faced with a juror's allegation of bullying by another juror may adopt a procedure of discharging the complaining juror and posing self-assessment questions to the remaining jurors about their ability to discharge their duty, rather than conducting a detailed investigation into the substance of the complaint. The stance adopted by experienced defence counsel at trial in endorsing such a procedure is a significant factor on appeal. The distinction between external influences on a jury and internal jury dynamics does not render the self-assessment approach inappropriate.
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