The Kienapple principle is also known as the rule against multiple convictions (from the decision in R. v. Kienapple, 1974 CanLII 14 (SCC), [1975] 1 S.C.R. 729, 15 C.C.C. (2d) 524). It “proposes that an individual should not be subjected to more than one conviction arising out of the same ‘cause or matter’ or the same ‘delict’, consisting of a single criminal act committed in circumstances where the offences alleged are comprised of the same or substantially the same facts and elements” (see Jordan, “Application and Limitations of the Rule Prohibiting Multiple Convictions: Kienapple v. The Queen to R. v. Prince” (1985) 14 Man. L.J. 341).
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