The sole point of this website it to provide information to anyone in the future that is appealling to Court of Appeal (Criminal Division) to augrue the gorund for having a Brown Direction in self-defnce where to both limbs are used. When This ground is answered this website will be repurpose to an general self-defnce website.
The Court of Appeal made it clear that it was a fundamental principle that in arriving at their verdict, the jury, even if they had not agreed as to part of the evidence, had to be unanimous that each ingredient necessary to constitute the offence had been established.This was establish in R v Brown (1984) 79 Cr App R 115.
R v Williams [2012] EWCA Crim 2516 Lord Justice Treacy observed a relevant judgement in R v Keeton [1995] 2 Cr App R 241 at page 249G it was stated at [54] : "...it is only in cases where truly alternative bases for a finding of guilt are being put forward by the Crown and where there is a risk that the jury might feel that it is permissible for some of them to be satisfied by one basis and others by another, that the Brown direction need be given. It is not appropriate to complicate what are essentially straightforward cases with a Brown direction."