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5 By prohibiting multiple punishments for a single criminal act Penal Code section 654. affords protection beyond and different from that given by either the constitutional proscrip-. tion of subsequent jeopardy or the implementation of that doctrine by Penal Code section 1023..
3 The term multiple punishment is used in this comment to signify consecutive sentences. for crimes arising out of the same act. 4 The modem plea of once in jeopardy is a descendent of the old common law pleas of. autre lois acquit (former acquittal) and autre lois convict (former conviction).