EWCA Crim 1
The need for a jury direction of the type from R. v Brown (Kevin) (1984) 1 B.C.C. 98970 would seldom occur and would not occur when what was alleged was a course of conduct. It was necessary only in those cases where two or more different ways of committing the same offence were alleged in the same count.
CA (Crim Div) (Hooper LJ, Saunders J, Stadlen J)