The principles dealing with inconsistent verdicts may apply where the inconsistency is between a failure to reach a verdict on one count and a conviction on another, but only where the difference is incapable of any logical explanation. The principles have no application where the circumstances of each charge and the evidence relating to them were different. A failure to reach a verdict should not be equated with an acquittal. The members of the Court differed on the extent to which jury disagreement can ground an inconsistency appeal, with Hamill J taking the broadest view and Bell P the most cautious. The question remains unresolved.
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