Section 191(1) of the Crimes Act 1958 (Vic) creates a single offence capable of commission in alternative ways (knowing false statement/promise/forecast, reckless false statement/promise/forecast, or dishonest concealment of material facts). A charge alleging more than one mode of commission in a single count is not bad for patent duplicity. However, where multiple particulars are alleged, the jury must be directed that they must be unanimous on at least one particular. The Court provided a model form of charge and minimum jury directions for s 191(1)(b) offences.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.