[2013] EWCA Crim 1852
In giving a majority verdict direction, a trial judge should not have added the words "if, after give and take and full discussion, you honestly cannot [reach a unanimous verdict], then I can accept [a majority verdict]". In doing so, he had erroneously given a partial Watson direction. However, the words added almost nothing to the advice that the jury would have received if the judge had given a standard majority verdict direction and the jury's verdict was therefore not unsafe.
CA (Crim Div) (Pitchford LJ, Keith J, Blair J)
29/10/2013