Differential verdicts in sexual assault cases involving multiple counts can be reconciled where acquittals on earlier counts are explicable by the jury giving the accused the benefit of the doubt on knowledge of lack of consent, or by doubts about the complainant's reliability (as distinct from credibility) due to alcohol-induced memory fragmentation. A Zoneff direction is not required where the Crown has not suggested the accused lied but merely invited the jury to reject the accused's version. An Edwards direction on post-offence conduct is not required where the Crown expressly disavows reliance on the conduct as consciousness of guilt.
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