The unanimity direction principles from Zandipour apply to continuous assaults by prisoners on prison officers — where the assault is one continuous episode, no unanimity direction is required as to the precise act causing serious injury. Assaults by prisoners on corrections officers performing their duties are an aggravating circumstance attracting paramount considerations of denunciation and general deterrence. The De Simoni principle does not prevent a sentencing judge from taking into account that an assault continued after the victim was on the ground and unable to defend himself, where that circumstance forms part of the offence charged rather than constituting a separate, uncharged offence.
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