[2007] EWCA Crim 3269
The purpose of a Brown direction was to avoid the mischief where the jury could reach a verdict of guilty by alternative routes but one of the routes might lead some members of the jury to conclude that it should reach a verdict of not guilty. A Brown direction was not required where all routes to a verdict inevitably led to a verdict of guilty.
CA (Crim Div) (Latham LJ (VP CA Crim), Cooke J, Cranston J)
17/12/2007