R v Burge : R v Pegg (1995) 1 Cr App R 163 identified four circumstances where a Lucas direction was usually given, but it did not follow that a Lucas direction had to be given where one or more of the circumstances existed. Cases where verdicts were logically inconsistent were rare. For that ground to succeed the verdicts must be contradictory so that one verdict cannot stand without the other.

CA (Crim Div) (Roch LJ, Potts J, Butterfield J)


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