Yes, normally the bulky chloride ligands stay as far apart as possible in the coordination sphere. In the tetrahydrate CoCl2.4H2O, it appears that hydrogen bonds between chlorides and the hydrogen atoms in water molecules in the next CoCl2(H2O)4 molecule along make the cis structure more favourable. It shows that it is the balance of small things that can tip the balance and determine a structure..
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