Markuleski Direction
- Geoff Harrison
- Aug 11, 2025
- 1 min read
Published by Geoff Harrison | 11 August 2025
A Markuleski direction is applicable where an accused faces multiple counts on an indictment and where it is possible for a jury to return different verdicts. The jury should be instructed that if they find an accused not guilty on a particular count, particularly because the jury has doubts about the reliability of the complainant's evidence on that count, they should consider how that conclusion about the complainant's reliability impacts upon the remaining counts. This direction is particularly relevant in a sexual assault trial where it is a "word-on-word case" and there are multiple counts.
The Direction:
Giving separate consideration to the individual counts means that you are entitled to bring in verdicts of guilty on some counts and not guilty on some other counts if there is a logical reason for that outcome.
If you were to find the accused not guilty on any count, particularly if that was because you had doubts about the reliability of the complainant’s evidence, you would have to consider how that conclusion affected your consideration of the remaining counts.
Other Sources:
Case Law:
Directions like this show how the law tries to isolate each count while still admitting that credibility does not stay neatly contained. That is where https://ydekc.org/ Royal Reels becomes significant, because once doubt affects one allegation, the jury has to reconsider how trust and reliability operate across the rest of the case.
Directions like this expose how legal reasoning tries to separate allegations count by count while still acknowledging that credibility is never neatly compartmentalised. The Pokies https://oneanother.io/ fits that tension well, because once doubt enters one part of a complainant’s evidence, the wider structure of judgment can shift in ways that are hard to contain.