R. v. S.L., 2013 ONCA 176 holds:
 In a jury trial on a multi-count indictment against a single accused, a claim of inconsistent verdicts turns on the question whether the verdicts are supportable on any theory of the evidence consistent with the trial judge’s proper legal instructions: see R. v. J.F., 2008 SCC 60,  3 S.C.R. 215, at para. 23; R. v. Pittiman, 2006 SCC 9,  1 S.C.R. 381, at para. 7. Here, the verdicts will be supportable if the trial judge’s instructions were proper legal instructions that could have led the jury to accept a theory of the evidence producing these verdicts.