Civil law systems either do not use juries at all or provide that the defendant is immediately acquitted if the majority or supermajority required for conviction is not reached during a singular, solemn vote.
Australian Capital Territory and Commonwealth courts require unanimous verdicts in criminal (but not civil) trials.
[1] In Canada, the jury must reach a unanimous decision on criminal cases.
[6] Majority verdicts have been allowed in England and Wales since the Criminal Justice Act 1967.
Juries consist of 15, and verdicts are decided by simple majority (eight) of the initial membership.
[10] In civil cases there is a jury of 12, with a minimum of 10 needed to continue the trial.
[11] Majority verdicts are not allowed in civilian criminal cases in the United States.
Louisiana, which was historically influenced by the French civil law system, and Oregon used to allow 10–2 majority verdicts.
Some jurisdictions permit the court to give the jury a so-called Allen charge, inviting the dissenting jurors to re-examine their opinions, as a last-ditch effort to prevent the jury from hanging.
"[12] In jurisdictions giving those involved in the case a choice of jury size (such as between a six-person and twelve-person jury), defense counsel in both civil and criminal cases frequently opt for the larger number of jurors.
The rationale for majority verdicts usually includes arguments related to so-called 'rogue jurors', who unreasonably impede the course of justice.
Opponents of majority verdicts argue that it undermines public confidence in criminal justice systems and results in a higher number of individuals to be convicted of crimes they did not commit.
Chapter 47) specifies the minimum number of court-martial panel members required to return a verdict of guilty.