What is the test for unanimous verdicts?

The seminal case is Latour v. The King (1950), 1950 CanLII 12 (SCC), 98 C.C.C. 258, [1951] 1 D.L.R. 834, [1951] S.C.R. 19. In that case the trial judge instructed the jury in this way: "This is an important case and you must agree upon a verdict. That means that you must be unanimous." At pp. 269-70, Mr. Justice Fauteux said: This is all that was said on the subject. If one of the jurors could have reasonably understood from this direction — and it may be open to such construction — that there was an obligation to agree upon a verdict, the direction would be bad in law. For it is not only the right but the duty of a juror to disagree if, after full and sincere consideration of the facts of the case, in the light of the directions received on the law, he is unable conscientiously, to accept, after honest discussion with his colleagues, the views of the latter. To render a verdict, the jurors must be unanimous but this does not mean that they are obliged to agree, but that only a unanimity of views shall constitute a verdict bringing the case to an end. The obligation is not to agree but to cooperate honestly in the study of the facts of a case for its proper determination according to law.