19. There is a clear distinction between counts or charges made in an indictment and the material facts that underpin that charge or count.  The count or charge is the legal characterisation of the material facts which support that count or charge.  In pleading an indictment, the Prosecution is required to specify the alleged legal prohibition infringed (the count or charge) and the acts or omissions of the Accused that give rise to that allegation of infringement of a legal prohibition (material facts).  The distinction between the two is one that is quite easily drawn.